Today the FAH submitted comments on the FY 2023 Inpatient Rehabilitation Facility PPS and the FY 2023 Inpatient Psychiatric Hospital PPS proposed rules. The FAH highlighted our concerns that the proposed market basket forecasts are neither accurately nor adequately capturing the unique factors influencing the hospital and health care market today in general – especially with COVID 19 related workforce shortages. The letters urge CMS to provide consider the unique pandemic triggers that do not seem to be reflected in the market basket forecast and make a PHE-related exception to further increase IRF and IPF updates for FY 2023.
Additionally the IRF letter highlighted key concerns with future plans CMS solicited comments on regarding facility level adjusters and expanding the IRF transfer policy to home health discharges. For IPFs, the FAH letter offered detailed comments on a technical report on future adjustments to the psych PPS. For both rules, FAH offered detailed comments to CMS on principles and future measurement options to address improvement in health equity.