September 15, 2022 – Vizient submitted comments on the Centers for Medicare & Medicaid Services’ (CMS) calendar year (CY) 2023 Medicare Hospital Outpatient Prospective Payment System (OPPS) proposed rule.
In our comments, Vizient reiterated concerns that the proposed payment update does not adequately reflect the financial challenges hospitals are facing. For example, Vizient noted that the proposed market basket update of 3.1 percent was insufficient particularly given increased costs of transportation, purchased services and labor.
“It is imperative that CMS carefully review the drastic cost increases our members will continue to face through 2023, especially in the context of the COVID-19 pandemic and rising inflation and labor expenses,” said Shoshana Krilow, senior vice president of public policy and government relations for Vizient. “We encourage CMS to reconsider the proposed approach to help ensure that hospitals and health systems do not suffer financially.”
Vizient also addressed several policy proposals related to experiences from the COVID-19 Public Health Emergency (PHE). For example, Vizient expressed support for CMS’s efforts to maintain access to mental health services for Medicare beneficiaries at home and provided recommendations related to the agency’s proposed payment adjustment under the OPPS and inpatient prospective payment system for wholly domestically made National Institute for Occupational Safety & Health (NIOSH)-approved surgical N95 respirators. As CMS unwinds the PHE, Vizient remains committed to working closely with the agency, healthcare stakeholders and our members to help navigate various policy changes and ensure a seamless transition.
Additionally, Vizient provided recommendations related to the Overall Hospital Star Ratings program and the 340B Drug Pricing Program, among others. Regarding the 340B Program, Vizient strongly urged the agency to work with hospitals in developing an adequate remedy for hospitals that had their reimbursements significantly reduced unlawfully.
Earlier this month, Vizient also shared feedback with CMS in response to the CY 2023 Physician Fee Schedule proposed rule. Vizient provided recommendations related to telehealth, the Medicare Shared Savings Program and health equity in our comments to the agency. Vizient appreciates CMS’s efforts to update these key Medicare policies and the opportunity to share recommendations regarding the potential impact of these policies on our members.