AHPA submitted comments on: CMS-1849-P; Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2027 Rates; Requirements for Quality Programs; and Other Policy Changes.

Click here for the full comment letter. Below are some key takeaways.

• Implement episode-based payment models with clear rules, appropriate safeguards, and manageable financial risk:
  AHPA supports the goals of the nationwide Comprehensive Care for Joint Replacement Expanded Model and several updates to the Transforming Episode Accountability Model. However, it recommends clear episode-overlap rules, CMS-led beneficiary communications, cybersecurity protections, clinically relevant quality measures, timely data and target prices, stable benchmarks, and a gradual path to full downside risk for hospitals without bundled-payment experience. AHPA also recommends tailored frameworks for ambulatory surgical centers and physician-owned hospitals rather than applying hospital-based requirements without modification.
• Further refine the proposed sepsis readmission measure before applying financial penalties:
  AHPA supports efforts to improve sepsis outcomes but cautions that the proposed measure includes a broad and clinically diverse patient population. It recommends clarifying the measure’s diagnosis codes and exclusions, considering severity stratification, evaluating the relationship between mortality and readmissions, and providing an extended confidential reporting period before using the measure for Hospital Readmissions Reduction Program payment adjustments.
• Modernize quality reporting and interoperability while reducing unnecessary administrative burden:
  AHPA supports including Medicare Advantage patients in certain quality measures, shortening performance periods, removing topped-out or lower-value measures, and encouraging early electronic prior authorization adoption without initial penalties. It recommends clear attribution rules for new digital measures, coordinated implementation timelines, and removal of reporting requirements that offer diminishing value as interoperability becomes part of routine operations.
• Protect hospital-based nursing and allied health education programs:
  AHPA urges CMS to withdraw, substantially revise, or delay proposals that could understate the reasonable costs of operating nursing and allied health education programs. It recommends preserving reimbursement for appropriately allocated direct and indirect costs, using flexible cost-accounting standards, protecting programs that rely in good faith on existing accreditation requirements, and delaying any finalized changes for at least two full cost-reporting periods.
• Restore Section 1115 waiver days to Medicare DSH calculations:
  AHPA recommends returning to the historical inclusion of Section 1115 waiver days in the Medicare Disproportionate Share Hospital calculation. It warns that excluding these days disproportionately affects hospitals in Medicaid non-expansion states and may cause some hospitals to fall below the eligibility threshold for the 340B Drug Pricing Program, jeopardizing resources used for uncompensated care, oncology services, rural outreach, and other services for vulnerable patients.