NAACOS Highlights of the Final 2022 Medicare
Hospital Inpatient Prospective Payment System Rule
In early August, the Centers for Medicare & Medicaid Services (CMS) released the final 2022 Medicare Hospital Inpatient Prospective Payment System (IPPS) Rule and related factsheet. NAACOS provided comments on three sections of the proposed rule, including policy changes to the Medicare Shared Savings Program (MSSP), a health equity request for information (RFI), and an RFI on the use of Fast Healthcare Interoperability Resources (FHIR). The final regulation includes policies that update Medicare fee-for-service payment rates and policies for inpatient hospitals and long-term care hospitals for Fiscal Year (FY) 2022 and a provision for MSSP ACOs.
Overview:
This rule builds on the administration’s priorities to close health care equity gaps and support greater access to life-saving care during the COVID-19 public health emergency (PHE) and beyond. The final regulation also includes policies that update Medicare fee-for-service (FFS) payment rates and policies for inpatient hospitals and long-term care hospitals for FY 2022. Provisions in this rule seek to sustain hospital and health system readiness to respond to future PHEs, enhance the healthcare workforce in underserved communities, and revise payment and quality reporting methods to mitigate the negative impacts of the pandemic and future events. This includes the establishment of measure suppression policy in response to COVID-19 PHE in the Hospital Readmissions Reduction Program (HRRP), Hospital-Acquired Condition (HAC) Reduction Program, and Hospital Value-Based Purchasing (VBP) Program. This policy will allow CMS to suppress the use of a measure if the agency determines that the PHE has affected the measures significantly. Importantly, the rule includes a provision for MSSP ACOs.
Medicare Shared Savings Program:
In response to NAACOS advocacy, this rule finalizes policies for MSSP ACOs participating in the Basic Track’s glide path the option to pause their automatic advancement along increasing levels of risk and reward for Performance Year (PY) 2022 and remain in the same level of the glide path in which the ACO participated in PY 2021. NAACOS supports allowing this freeze and is pleased with the flexibility provided to ACOs. However, it is important to note that this “freeze” only applies to MSSPs ACOs in the Pathways structure, and that ACOs in Tracks 1, 2, 3 and 1+ still must enter the Pathways structure in 2022.Unfortunately, CMS finalized its proposed policy to automatically advance ACOs in 2023 to the level in which they would have been without the glide path freeze, despite NAACOS advocating that it would be fair to maintain a more gradual risk increase given the pandemic. Therefore, ACOs who elect this “freeze” under now-finalized policy will have a dramatic jump in risk for PY 2023.