On June 30, GNYHA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed rule for fiscal year (FY) 2010 Medicare inpatient prospective payment system (PPS) rates. The letter addressed the following issues:

Documentation and coding improvement
GNYHA supported the American Hospital Association’s recommendations to reduce the proposed cuts to Federal rates to pay for anticipated case mix increases due to documentation and coding improvement in the wake of the revised Comorbidity and Complications list.

IME
GNYHA again opposed a plan to eliminate the indirect medical education (IME) adjustment in the capital PPS and opposed the Medicare Payment Advisory Commission’s (MedPAC’s) recommendation to cut the IME adjustment to finance quality incentive payments.

Labor-related share
GNYHA strongly opposed the proposal to reduce the labor portion of the operating rate, and instead urged CMS to increase the labor share, as supported by the Agency’s new market basket research.

Area wage index
GNYHA reiterated its opposition to MedPAC’s recommendation to use Bureau of Labor Statistics (BLS) data for the area wage index because the BLS data do not include fringe benefit and contract labor costs.

Quality-related proposals
GNYHA recommended that CMS postpone public reporting of the Agency for Health Research and Quality (AHRQ) patient safety and inpatient quality indicators until the Medicare patient data include present-on-admission indicators and all secondary diagnoses for risk adjustment. GNYHA also recommended that CMS replace its current readmission model with one that considers both comorbidities and complications. GNYHA also expressed opposition to the Senate Finance Committee’s proposal to base quality incentive payments on relative rather than absolute performance levels, among other features.