May 22, 2012

Comments to CMS’ 2011 IPPS Proposed Rule are due by June 20th

Just a reminder, comments to CMS’ 2011 Inpatient Prospective Payment System Proposed Rule are due by June 20, 2011.  Several notable provisions in the Proposed Rule include:

  • Policies for several hospital quality initiatives, including policies related to the Hospital Readmissions Reduction Program and the Hospital Value-Based Purchasing Program.
  • The addition of contrast-induced acute kidney injury as a hospital acquired condition. 
  • The removal of excisional debridement cases from the current MS-DRG and assignment of them to three new MS-DRGs that would provide more accurate, but lower, payment.
  • The creation of two new MS-DRGS for autologous bone marrow transplants.  One MS-DRG would apply to such transplants with complications or comorbidities, while another MS-DRG would apply to such transplants without any complication or comorbidity.
  • Revisions to the rules for determining pension costs for Medicare cost-finding and wage index purposes.
  • Clarification that Medicare’s 3-day/1-day payment window policy applies to both preadmission diagnostic and non-diagnostic services furnished at a physician practice wholly owned or wholly operated by the admitting hospital.
  • The exclusion of patient days and bed days for inpatient hospice services from the Medicare disproportionate share adjustment and indirect medical education adjustment.
  • Clarification of CMS’ “under arrangements” requirements.

You may access the Proposed Rule here.

A summary of the Proposed Rule is available from CMS here.

©2012 von Briesen & Roper, s.c

About the Author

Scott Thill is a member of the Health Care Practice Group. His practice focuses on general health law, including compliance-related matters. Scott received his Master of Health Administration from the University of Iowa, College of Public Health in 2008.

During law school, Scott worked for three years as a research assistant, with a focus on health law issues. He graduated with high distinction in the top ten percent of his class.

Scott is a member of the State Bar of Wisconsin, the American Health Lawyers Association and is Co-Chair of the Milwaukee Bar Association...

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