Messages to the Administration
Comments on Proposed Guidance for the 340B Drug Pricing Program, October 26, 2015.In response to proposed guidelines for the 340B Drug Pricing Program by the Health Resources and Services Administration, NAUH submitted formal comments expressing disagreement with several aspects of the proposed guidance, including its exclusion of drugs prescribed for hospital patients upon discharge; the exclusion of drugs prescribed by physicians who are not employed by or independent contractors of hospitals; the exclusion of infusion drugs; and more.
Comments on Proposed Comprehensive Care for Joint Replacement Model, September 04, 2015.The Centers for Medicare & Medicaid Services (CMS) and the Center for Medicare and Medicaid Innovation have formally proposed a new program, the Comprehensive Care for Joint Replacement Model, to foster better coordination of services and efficiency in the delivery of knee and hip replacements. In a letter to CMS, NAUH expresses support for the overall concept of the program but conveys its concerns about five aspects of the proposal, including its savings assumptions; the assignment of virtually all risk to hospitals; the breadth of services for which hospitals would be at risk; the program’s lack of socio-economic risk adjustment; and the inclusion of non-elective joint replacement surgeries.
Proposed Changes in Medicare Inpatient Payment Policies, June 12, 2015.In a letter to the Centers for Medicare & Medicaid Services (CMS), NAUH comments on Medicare’s proposed FY 2016 inpatient prospective payment system regulation. NAUH’s letter addresses Medicare disproportionate share (Medicare DSH) payments, including the size of the proposed Medicare DSH pool, the manner in which the funds in that pool would be distributed, and the prospect of a meaningful increase in the number of DSH-eligible hospitals in the coming years. It also addresses hospital inpatient rates, Medicare’s hospital readmissions reduction program, Medicare short hospital stay policy, and proposed FY 2016 outlier payments.