AHA submits comments on CY 2024 OPPS proposed rule, including price transparency

In comments submitted today, AHA expressed strong concern about the proposed hospital outpatient market basket update, noting it “does not capture either the unprecedented inflationary environment or the other persistent financial headwinds hospitals and health systems are experiencing.” The letter urged the Centers for Medicare & Medicaid Services to examine ways to account for these increased costs to ensure that beneficiaries continue to have access to quality outpatient care.

“We also urge the agency to reduce the productivity cut for CY 2024 as such a cut does not align with hospital and health systems’ public health emergency experiences related to actual losses in productivity during the COVID-19 pandemic,” AHA wrote. 

Among other comments, the association expressed interest in working with CMS to improve the hospital price transparency rule and align it with Transparency in Coverage and No Surprises Act requirements, and concern with the agency’s proposal to make separate payments under the inpatient and potentially the outpatient PPS for the additional costs to establish and maintain access to a buffer stock of domestically manufactured essential drugs.  

“While the AHA strongly agrees that it is necessary to support practices that can curtail shortages, we also continue to believe that much more must be done in addressing these concerns,” AHA wrote.