WSHA Comments on Medicare Proposed Inpatient Prospective Payment Hospital Rule for 2025

June 12, 2024

On June 10, WSHA submitted comments on the Centers for Medicare and Medicaid Services’ (CMS) proposed Inpatient Prospective Payment System rule for FY 2025 after receiving feedback from hospital Chief Financial Officers and Government Affairs staff.

Our comments included:

  • The proposed marketbasket increase does not reflect the increased costs of providing hospital care. CMS should increase the proposed marketbasket increase and reduce or eliminate the productivity adjustment.
  • The proposed mandatory TEAM model has many problematic design elements and assumptions that will create unreasonable financial risk for hospitals.  CMS should delay implementation until these issues are rectified or, at a minimum, make hospital participation voluntary.
  • WSHA appreciates the proposal to provide some additional funding to specified small independent PPS hospitals for purposes of maintaining buffer stock of essential drugs, but much more is needed to ensure drug manufacturers provide equitable access to drug supply for vulnerable hospitals.
  • WSHA and member hospitals are concerned that the proposal to impact access and delivery of obstetrical services through changes to hospital conditions of participation will reduce financial sustainability and access to obstetrical services unless accompanied by additional funding and resources. This is a particular concern for smaller hospitals that already face financial issues due to a low volume of labor and deliveries.
  • We support CMS review of the Medicare methodology and payment weights for obstetrical services. Medicare weights are often used by commercial payors and impact payment and sustainability of obstetrical services.

The final rule will be published on or around August 1 and take effect October 1.  (Andrew Busz,


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