When Congress and the President enact a new bill, the federal agencies are charged with creating the detail and implementing the law. These regulations, also called rules, are the guiding requirements for our hospitals, health facilities and providers.  By submitting comment letters to federal regulatory agencies, CHI helps shape proposed rules into fair, reasonable, and workable final rules.

CMS Proposes Major Changes to Physician Payment Rules, June 2016
CHI recently commented on proposed MACRA regulations, which put in place sweeping changes to Medicare payments for physicians, advanced practice registered nurses and physician assistants, tying payment more closely to value and quality. Overall, CHI supports the steps CMS has taken in this proposed rule to create a physician payment structure that will help clinicians move toward more integrated, accountable care models. CHI’s organizational goals align with CMS’s mission to improve quality and value throughout the health care system, and we understand that like hospital payments, physician payments must be accountable to quality and value as well. The proposed rule is not perfect and we recommended a number of important changes. We will continue to work with CMS to improve the physician payment model and Medicare payments overall.

CMS Recommends Changes to Inpatient Payment Rule, June 2016
CHI recently commented on CMS’s proposed inpatient hospital payment rule, urging CMS to delay or reduce a negative 1.5% coding adjustment, to modify the way the agency is planning to reimburse hospitals for three years of inappropriate two-midnight coding cuts, and to continue studying the impact of sociodemographic risk adjustment on quality measures.

CHI Opposes Part B Demonstration Project, May 2016
CMS recently proposed a a two-phase, four-track demonstration project intended to reduce payment for Medicare Part B drugs. CHI opposed this proposal, voicing concern that the entirety of this proposal will not reduce pharmaceutical costs but rather will unreasonably penalize hospitals and physicians based on faulty assumptions about prescribing practices with a potential unintended consequence of limiting patient access to care.

CHI Offers Support for ACO Benchmarking Proposal, March 2016
CMS is proposing significant changes to the way Accountable Care Organizations’ (ACOs) reimbursements are calculated, including cost benchmarking, beneficiary assignment methodology changes, and extending the first track of ACO participation. CHI submitted a comment letter generally supportive of the proposed changes, with a few specific areas where CMS could improve the program.

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