Each year the Centers for Medicare & Medicaid Services (CMS) invites stakeholders to submit comments on the proposed changes to Inpatient Prospective Payment System (IPPS) rule. We appreciate the opportunity to submit comments to CMS on the proposed changes.
We wish to emphasize our most important recommendation: We strongly advise CMS to significantly expand ASC measures. This proposed rule includes no expansion of measures, which is deeply concerning to Leapfrog and the purchasers involved in our work. More and more surgical procedures are being shifted to ASCs, which means millions more patients will entrust their lives to ASCs. CMS has a significant role to play in ensuring ASCs are accountable for the trust their patients give them.
In addition, our comments emphasize the following points:
- It is too early to eliminate the Inpatient Only List: Leapfrog urges CMS to strengthen and expand quality and safety measurement and public reporting for ASCs so patients and purchasers can evaluate the safety and outcomes of care as increasingly complex procedures move to these settings.
- Pair Hospital Price Transparency with quality data: Leapfrog commends CMS for continuing to prioritize hospital price transparency and making cost information more accessible and useful to consumers and purchasers. However, price will not drive affordability or better care unless it is paired with quality data. Consumers do not want to purchase poor or unsafe care, no matter the price. Nor is poor or unsafe care ever a cost-effective option, because it typically results in longer lengths of stay and expensive health complications. Leapfrog urges CMS to ensure that quality and safety information is meaningfully integrated with price data so patients and purchasers can assess the true value of care and make informed health care decisions.
The Leapfrog Group, including our Board, members and interested parties, appreciates the opportunity to share our comments on the proposed changes to the CY 2027 rule.