OPPS Comments Focus on Observation Status

While the AHA is supportive of time-based admission policies where an observation outpatient would automatically be deemed inpatient status after one or two days, it cautioned that the system would expose hospitals "to increased risk of retrospective review and audit by RACs and MACs."

It noted that implementing a time-based policy also would "require a comprehensive review and revision of other Medicare requirements including other payment regulations and Medicare conditions of participation."

Among the AHA recommendations is that CMS implement a policy so that observation time beyond a specified time limit would not trigger an automatic admission but would become a new decision point for the attending physician to decide whether to admit the patient.

APC calculations
CMS proposes to change the way it calculates APC relative weights by shifting from median cost data to geometric mean cost. CMS contend that the new system will better capture the ranges of costs of services.

The AHA supports the proposal but urged CMS to proceed "cautiously and transparently to ensure that there are no unintended consequences for hospitals and their patients."