The Leapfrog Group Submits Comments to Fiscal Year 2024 CMS IPPS Proposed Rule

June 9, 2023

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. 

Read Leapfrog's Letter.

This letter was submitted on June 9, 2023 and

includes signatures from over 20 stakeholder organizations

representing employers and consumers. 

In the fiscal year 2024 proposed rule, there is one area of particular importance. The Leapfrog Group is opposed to the removal of the elective delivery measure based on CMS’ perception that the measure is “topped out,” which is measure removal factor #1. The data still suggests that tens of thousands of mothers and newborns are at high risk of this unnecessary and dangerous intervention. Moreover, per CMS’ analysis of the measure in the proposed rule, the rate of elective procedures is increasing (43% in the past two years).  This alarming increase is despite the fact the measure steward has increased the ICD-10 code exclusions in the measure by 26% over the last several years, suggesting the rate should be decreasing, not increasing.  We suggest it is not the time to remove the measure from public scrutiny when the rates are substantially increasing year over year and when so many lives are still at risk from known poor performance on this measure. CMS should not be moving the focus away from the measure, but further shining a light on this important clinical area that is going in the wrong direction. This is also an issue of health equity, with a large and growing body of literature suggesting maternity care disparities are an urgent issue in the United States.


Update: CMS released its final rule on August 1, 2023.

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