The CMS FY2015 Budget Justification included language simply stating that CMS must coordinate with the HRSA Office of Rural Health Policy and receive recommendation from the White House Rural Council. Despite this assertion, several policies remain problematic for rural providers and facilities, including the outpatient therapy supervision requirement and the 96 hour rule.
Letters
Throughout the year, the AHA comments on a vast number of proposed and interim final rules put forth by the federal regulatory agencies. In addition, AHA communicates with federal legislators to convey the hospital field's position on potential legislative changes that would impact patients and patient care. Below are the most recent letters from the AHA to these bodies.
Latest
As the organizations representing more than 5,000 hospitals and health systems across the country, we respectfully urge you to delay the effective date of October 9, 2014 for provisions in the final rule on Disposal of Controlled Substances that would adversely affect hospitals.
Beginning August 1, 2014, the Beneficiary and Family Centered Care Quality Improvement Organization (BFCC-QIO) Program was restructured from a state-based program, with an individual QIO contractor in each of the 53 states and territories, to five BFCC regional contracts covering the same 53 states and territories.
The American Hospital Association (AHA) is writing to request clarification regarding how the appeals settlement offer, announced by the Centers for Medicare & Medicaid Services (CMS) on Aug. 29, 2014, impacts the contingency fees Recovery Audit Contractors (RACs) received for previously denied claims that are part of the settlement.
The undersigned organizations write to express immediate concerns confronting our respective members’ ability to successfully participate in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program in 2015 and we offer recommendations on increasing program flexibility.
The recently released EHR Meaningful Use in 2014 Flexibility regulation addressed challenges in FY 2014. However, for hospitals, the challenges will remain in place at the start of FY 2015 (Oct. 1, 2014), when hospitals will be expected to meet all of the program requirements for the entire fiscal year. It is unrealistic to expect that all of the significant implementation issues will be resolved for all hospitals.
The American Hospital Association (AHA) is pleased to support H.R. 5481, the Flexibility in Health IT Reporting (Flex-IT) Act of 2014. Your legislation requires the Centers for Medicare & Medicaid Services (CMS) to make a necessary adjustment to how it implements the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs, which provide incentives and penalties to encourage “meaningful use” of EHRs by hospitals and physicians.
The American Hospital Association (AHA) is pleased to support H.R. 5227, the “Making the Education of Nurses Dependable for Schools Act (MEND).” This legislation is critical to ensuring the viability of our nation’s hospital-based nursing education programs and a robust supply of nurses to provide health care to patients.
The AHA applauds the work of the Committee to fight fraud, waste and abuse, and your work on this legislation specifically. While we generally support the efforts of this bill, we appreciate your seeking our input so we can identify some potential unintended consequences or areas where additional reform can be made.
The AHA supports CMS’s proposal to eliminate the requirement that a face-to-face encounter include the narrative explanation, which will facilitate smoother transitions for hospitals discharging patients to home care and for hospital-based HH agencies initiating services.