American College Of Surgeons - Inspiring Quality: Highest Standards, Better Outcomes

ACS Submits Comments on FY 2020 IPPS and Promoting Interoperability Proposed Rule

The American College of Surgeons (ACS) submitted comments June 24 in response to Centers for Medicare & Medicaid Services’ (CMS) fiscal year (FY) 2020 Hospital Inpatient Prospective Payment Systems (IPPS) and Promoting Interoperability Programs Proposed Rule, which was released May 3. Under the provisions proposed in this rule, CMS projects that total Medicare spending on inpatient hospital services will increase by approximately $4.7 billion in FY 2020. The proposed CMS rule updates payments and policies for the inpatient hospital programs and initiatives. It also provides opportunities to provide feedback on the future of quality measures and increased efficiency of Electronic Health Records (EHRs).

The College encouraged CMS to reduce burden on physicians by adopting open-source standards for data exchange and the utilization of cloud platforms as well as aligning quality measures across the various inpatient hospital quality programs. The ACS also strongly urged CMS to retain and use risk-adjusted clinical outcome measures, patient reported outcomes (PROs), and evidence-based standards, such as the protocols in the ACS manual Optimal Resources for Surgical Quality and Safety (also known as the Red Book), to promote a culture of continuous quality improvement and ensure that hospitals have the resources necessary to provide optimal care. 

CMS also sought stakeholder feedback on the agency’s policies to provide additional payment for new medical technologies that demonstrate substantial clinical improvement over existing technologies. The ACS supported such add-on payments for new technologies under IPPS for the purposes of reducing financial barriers to investment and adoption by hospitals. The College encouraged CMS to provide greater clarity on the criteria new technologies must meet to be eligible for additional payment to ensure that ambiguities within the existing criteria do not hinder access to technologies that may significantly enhance the diagnosis and treatment of Medicare beneficiaries.

To read the full text of the comments on this rule, see the letter here. For more information, contact

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