Stacey Hughes, Executive Vice President, American Hospital Association

August 2, 2021

The AHA appreciates CMS listening to our concerns by repealing the requirement that hospitals and health systems disclose privately negotiated contract terms with payers on the Medicare cost report. This policy was originally adopted for the stated purpose of better aligning fee-for-service Medicare payments with market rates. However, privately negotiated rates take into account a number of unique circumstances between a private payer and a hospital and are not an appropriate benchmark for fee-for-service Medicare payments.

In addition, we appreciate that CMS is continuing to review comments on its organ acquisition proposed policies. We continue to urge the agency to engage with stakeholders, including providers, in developing any modifications. We also appreciate that CMS is continuing to review comments on proposed changes related to Medicare-funded residency slots and we look forward to working with them to develop a workable policy to help ease current physician shortages and strengthen the health care delivery system.

Further, we are pleased that the agency recognizes that the COVID-19 pandemic has resulted in non-representative performance in its hospital quality measurement and value programs, requiring temporary policy adjustments. We also thank CMS for extending the add-on payment for new COVID-19 treatments through the year in which the current public health emergency ends. This will help ensure hospitals and health systems have the resources to treat COVID-19 patients.

Lastly, the AHA strongly supports COVID-19 vaccinations of both health care workers and the communities they serve. We have worked closely with the hospital field and the federal government to encourage vaccination to help protect both our patients and health care workforce from the virus. While CMS's new quality measure on the rate of health care personnel COVID-19 vaccination likely needs further refinement to ensure it accurately reflects hospitals' progress in vaccinating their workforce, we will work with CMS, CDC and hospitals to facilitate the reporting of the measure starting on October 1.