The Centers for Medicare and Medicaid Services (CMS) published proposed rules for the Hospital Inpatient Prospective Payment System (IPPS) and Skilled Nursing Facility Prospective Payment System (SNF PPS) for fiscal year 2009. CMS is soliciting comments on the IPPS proposed rule until June 13, 2008 and on the SNF PPS until June 30, 2008. Providers should take the opportunity to comment on the proposed rules, as each addresses numerous issues that could have direct impact on operations and arrangements.

The IPPS proposed rule increases operating payments up to 4.1 percent from the prior year, due largely to a 3 percent market basket update. Hospitals that fail to report on quality measures will still face a 2 percent penalty. It is important to note, however, that CMS has proposed the addition of 43 new quality measures to the current list of 30 on which hospitals must report.

Other significant changes to the Hospital Inpatient Prospective Payment System proposed by CMS include:

  • Alternatives to the "stand in the shoes" provisions contained in the Stark III rules

  • A corollary provision to the "stand in the shoes" provisions related to designated health services (DHS) entities

  • Clarification of the period of disallowance for DHS entities

For more information on the proposed rule for the Hospital Inpatient Prospective Payment System, please see the Waller Lansden bulletin at this link.

The Skilled Nursing Facility Prospective Payment System proposed rule is highlighted by a recalibration of the case-mix adjustment index that is projected to result in a net decrease in payments to providers of 0.3 percent The recalibration is based on claims data that CMS has reviewed since it adjusted the index in 2006 using forecasted utilization data.

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