CMS-1785-P: Medicare Program: Proposed Hospital PPS for Acute Care Hospitals and the Long-Term Care

CMS posed a series of questions (p 27109); the Panel responds here with a series of statements regarding burdens on rural hospitals: ● We assume the question of burden encompasses the burden of implementing the necessary protocols and other changes allowing affirmative attestation rather than the administrative burden of the act of reporting, although with 14 measures across 8 domains there is an. [...] Safety Net Hospitals – Request for Information (p 287187) The RUPRI Health Panel applauds the effort to recognize the critical role played by safety net hospitals in providing access to all Medicare beneficiaries, as being essential points of access to the communities they serve. [...] However, we encourage CMS to rethink the Safety Net Index to reflect the role of hospitals as the anchor of the health care delivery system in many rural communities. [...] In response to the questions posed in the Request for Information (page 27189) the RUPRI Health Panel offers the following comments: ● Considerations in identifying safety net hospitals: These considerations should include financial burden of serving community members lacking insurance coverage that reimburses full cost of providing the service. [...] ● Different types of safety-net hospitals: Safety-net hospitals could be characterized based on financial measures (i.e., the SNI), the characteristics of their service area and population (I.e., the ADI), or the essential nature of the hospital to assuring the pillars of a high performing rural health system: a baseline consideration of equity with pillars of access, affordability, quality, and c.