June 12, 2023 – Vizient recently offered comments to the Centers for Medicare and Medicaid Services on the FY 2024 Inpatient Prospective Payment System Proposed Rule. Vizient responded to myriad proposals from CMS, including the woefully inadequate market basket update and the agency’s approach to advancing health equity.
Regarding hospitals’ continued cost pressures, Vizient encouraged CMS to consider a more substantial increase to the operating payment rate for hospitals paid under IPPS. Vizient called on CMS to update the proposed rate to reflect the mounting costs facing hospitals and to consider opportunities to address the inadequate rate increases from prior years.
In support of CMS’s ongoing efforts to advance health equity, Vizient applauded the agency for proposing to change the severity level designation for certain social determinants of health (SDOH) diagnosis codes and encouraged the agency to broaden this policy. Throughout our comments, Vizient provided recommendations related to health equity policies, such as the utilization of tools including the Vizient Vulnerability IndexTM, and voiced concern regarding the agency’s use of the Area Deprivation Index in policies such as the Health Equity Adjustment bonus points proposal in a CMS quality program. Vizient also offered feedback on CMS’s Request for Information on challenges facing safety-net hospitals to help ensure care is accessible to uninsured and low-income patients.