Federal Advocate Articles
KHA Submits CMS Comment Letter on IPPS

CMS (June 12, 2024) - On June 10, the Kansas Hospital Association submitted a comment letter related to the release 
of the Centers for Medicare & Medicaid Services Inpatient Prospective Payment System and Long-Term Care Hospital Prospective Payment System 2025 Proposed Rule, CMS-1808-P

Highlights of KHA’s response to the 2025 IPPS Proposed Rule include:

  • Expressed concern with the minimal 2.6 percent increase in IPPS payment. At a minimum, hospitals should receive the 3.7 percent increase in payment that Medicare Advantage plans received for 2025.
  • Submitted multiple recommendations for adjustment of the proposed new bundled payment model Transforming Episode Accountability Model. The model is currently proposed to be mandatory for all PPS hospitals that are selected in 20 percent of the country. KHA also believes CMS should increase the low-volume thresholds to not overly burden hospitals with smaller volumes, and CMS should revise the risk structure of the model.
  • Made various comments regarding Graduate Medical Education requests for information.
  • Expressed opposition to CMS’ potential future proposal of creating Conditions of Participation for Obstetrics care.
  • Emphasized the importance of increasing reimbursement for maternity services to better sustain hospitals’ ability to offer OB care.

CMS will consider all comments submitted for potential revisions to the rule and is expected to release the 2025 IPPS final rule at the beginning of August.