FFY 2023 IPPS PROPOSED RULE COMMENTS DUE JUNE 17, 5 PM EDT
This Friday June 17th at 5 PM, comments are due on CMS’s proposed FFY 2023 IPPS rate setting. In commenting –
- Refer to file code CMS–1771–P.
- Submit electronically through this regulation link then select the COMMENT button at left, below the title; or
- Submitted by mail to: Centers for Medicare &Medicaid Services, Department of Health and Human Services, Attention: CMS–1771–P, P.O. Box 8013, Baltimore, MD 21244–1850.
Please feel free to see Toyon’s comments here on our website. Providers may also download a word version of these comments with designated [highlighted] areas to populate for your hospital or health system.
Toyon’s comments are focused on reimbursement issues, as well as cost reporting proposals requiring additional clarification, as summarized in the table below.
| # | Issue | FFY 2023 Proposal | Summarized Comment |
| 1 |
Market Basket |
2.7% Update 3.1% Market Basket -0.4% ACA Adjustment |
8.0% Update Based on recent Medicare cost increases[1] |
| 2 | Outliers |
$43,214 Fixed Loss Threshold (40% increase from PY) |
Reduce threshold in anticipation of fewer COVID-19 hospitalizations in FFY 2023 |
| 3 |
UC DSH Factor 1 |
-$542M Reduction to FFY 2023 UC DSH Payments |
-$542M Reduction to FFY 2023 UC DSH Payments Increase Factor 1 discharge adjustment considering forecasts of increased Medicare utilization |
| 4 | UC DSH Factor 2 |
65.71% -0.03 from prior yr -0.07 from penultimate yr |
65.71% -0.03 from prior yr -0.07 from penultimate yr Increase Factor 2 to reflect projections of increases to the national uninsured population |
| 5 | Empirical DSH Section 1115 Waiver Days | Medicaid patients regarded as eligible from 1115 Waiver w/ essential health benefits (EHB) | Clarification on premium assistance days “for which the premium assistance is equal to or greater than 90 percent of the cost of the coverage” |
| 6 | NP95 Respirator Payments | Reimbursement for the incremental cost of using wholly domestically produced N95 respirators | Supported and request CMS reimburse for all patients (not only Medicare) in bi-weekly lump sum payments |
Please feel free to email Fred Fisher at fred.fisher@toyonassociates.com with any questions.
[1] Analysis of Medicare cost per discharge change from FFY 2019 to FFY 2020 per Medicare cost report data from the Healthcare Cost Report Information System (HCRIS). Medicare cost per Worksheet D-1 Part II, Line 49, Column 1. Medicare discharges per Worksheet S-3 Part I L14.00 C13.00.
