"Congress directed CMS (the Centers for Medicare & Medicaid Services) to remove $11 billion in inpatient prospective payment system payments to account for alleged overpayments associated with documentation and coding changes," she wrote.
"The AHA firmly believes that no additional adjustments for documentation and coding should be considered," adding that "we disagree with MedPAC staff's assertion that changes in documentation and coding related to the move to Medicare Severity Diagnosis-Related Groups (MS-DRGs) inflated payments in FY 2010."
Fishman characterized the MedPAC recommendation on "a flawed analysis" that "additional overpayments were made in FY 2010," she wrote.
"Using this same flawed methodology, MedPAC and CMS actually maintained that real case mix was negative during the initial years following the implementation of MS-DRGs. However, numerous other indicators suggest that Medicare patients are getting sicker in ways that were not appropriately accounted for under the old DRG system. As identified in the attached TrendWatch report, rates of chronic conditions are rising."
Four out of five Medicare beneficiaries suffer from chronic diseases and two-thirds of them have two or more chronic diseases, she wrote.