Regulatory Issues

Federal regulatory agencies can impact hospital and health system operations. IHA plays an influential role with healthcare-related policy proposals.

  • Medicare Payment
  • Operations
  • Comment Letters
Dec 20, 2023

CY24 Medicare HH Final Rule

On Nov. 1, CMS posted the calendar year 2024 Medicare Home Health Prospective Payment System final rule effective Jan. 1, 2024 through Dec. 31, 2024.

Nov 29, 2023

CY 2024 Medicare PFS Final Rule (CMS-1784-F)

On Nov. 2, the Centers for Medicare & Medicaid Services (CMS) released its calendar year (CY)
2024 physician fee schedule (PFS) final rule.

Nov 27, 2023

CY24 Medicare OPPS Final Rule (CMS-1786-F)

On Nov. 2, CMS posted the calendar year 2024 Medicare Outpatient Prospective Payment System final rule effective Jan. 1, 2024 through Dec. 31, 2024.

Sep 01, 2023

FY24 Medicare IPPS Final Rule (CMS-1785-F)

On Aug. 1, CMS posted the fiscal year 2024 (FY24) Medicare Inpatient Prospective Payment System (IPPS) final rule effective Oct. 1, 2023 through Sept. 30, 2024.

Aug 21, 2023

CY24 Medicare OPPS Proposed Rule - CMS - 1786-P

On July 31, the Centers for Medicare & Medicaid Services (CMS) published its calendar year 2024 (CY24) outpatient prospective payment system (OPPS) proposed rule.

Aug 21, 2023

Proposed Changes to Hospital Price Transparency Requirements

CMS proposed several changes to hospital price transparency requirements in the CY24 OPPS proposed rule.

Jul 20, 2023

CY24 Home Health PPS Proposed Rule

CMS published its annual proposed rule updating the Medicare Home Health prospective payment system effective Jan. 1, 2024 through Dec. 31, 2024.

Jul 13, 2023

Proposed 340B Payment Remedy

Details on CMS’ proposed payment remedy in response to its unlawful 340B payment policy implemented in CY 2018.

May 11, 2023

FY 2024 IPPS Proposed Rule

CMS published its annual proposed rule updating the Medicare inpatient prospective payment system effective Oct. 1, 2023 through Sept. 30, 2024.

Apr 25, 2023

FY 2024 IRF PPS Proposed Rule

CMS published its annual proposed rule updating the Medicare inpatient rehabilitation facility prospective payment system effective Oct. 1, 2023 through Sept. 30, 2024.

Apr 25, 2023

FY 2024 IPF PPS Proposed Rule

CMS published its annual proposed rule updating the Medicare inpatient psychiatric facility prospective payment system effective Oct. 1, 2023 through Sept. 30, 2024.

Apr 25, 2023

FY 2024 SNF PPS Proposed Rule

CMS published its annual proposed rule updating the Medicare skilled nursing facility prospective payment system effective Oct. 1, 2023 through Sept. 30, 2024.

Nov 11, 2022

CY 2023 OPPS Final Rule

CMS finalized outpatient prospective payment system updates, effective Jan. 1, 2023 through Dec. 31, 2023.

Nov 11, 2022

Rural Emergency Hospitals – CoPs

CMS finalized Medicare Conditions of Participation for rural emergency hospitals, effective Jan. 1, 2023.

Nov 11, 2022

Rural Emergency Hospitals

CMS finalized policies and procedures specific to rural emergency hospitals, effective Jan. 1, 2023.

Nov 08, 2022

Update on 340B Drug Pricing Program

CMS restored the 340B reimbursement to average sales price plus 6% for calendar year 2023.

Nov 01, 2022

CY 2023 HH PPS Final Rule

CMS published the home health prospective payment system final rule effective Jan. 1, 2023 through Dec. 31, 2023.

Aug 19, 2022

FY 2023 IPPS Final Rule

CMS published the inpatient prospective payment system final rule effective Oct. 1, 2022 through Sept. 31, 2023.

Aug 19, 2022

FY 2023 LTCH Final Rule

CMS published the long term care hospital prospective payment system final rule effective Oct. 1, 2022 through Sept. 31, 2023.

Aug 02, 2022

FY 2023 SNF Final Rule

CMS published the skilled nursing facility prospective payment system final rule effective Oct. 1, 2022 through Sept. 31, 2023.

Aug 02, 2022

FY 2023 IRF Final Rule

CMS published the inpatient rehabilitation facility prospective payment system final rule effective Oct. 1, 2022 through Sept. 31, 2023.

Aug 02, 2022

FY 2023 Hospice Finale Rule

CMS published the Medicare hospice payment final rule effective Oct. 1, 2022 through Sept. 31, 2023.

Aug 02, 2022

FY 2023 IPF Final Rule

CMS published the inpatient psychiatric facility prospective payment system final rule effective Oct. 1, 2022 through Sept. 31, 2023.

Jul 27, 2022

CY 2023 OPPS Proposed Rule

CMS published its annual proposed rule updating the Medicare outpatient prospective payment system effective Jan. 1, 2023 through Dec. 31, 2023.

Jun 30, 2022

CY 2023 HH Proposed Rule

CMS published its annual proposed rule updating the Medicare Home Health prospective payment system effective Jan. 1, 2023 through Dec. 31, 2023.

May 09, 2022

FFY 2023 PR LTCH

CMS published its annual proposed rule updating the Medicare Long-Term Care Hospital prospective payment system effective Oct. 1, 2022 through Sept. 30, 2023.

Apr 28, 2022

FFY 2023 SNF Proposed Rule

CMS published its annual proposed rule updating the Medicare Skilled Nursing Facility Prospective Payment System, effective Oct. 1, 2022 through Sept. 30, 2023.

Apr 27, 2022

FFY 2023 IPPS Proposed Rule

CMS published its annual proposed rule update the Medicare Inpatient Prospective Payment System, effective Oct. 1, 2022 through Sept. 30, 2023.

Apr 11, 2022

FFY 2023 Hospice Proposed Rule

CMS published its annual proposed rule updating the Medicare Hospice payment system effective Oct. 1, 2022 through Sept. 30, 2023.

Apr 11, 2022

FFY 2023 IPF PPS Proposed Rule

CMS published its annual proposed rule updating the Medicare Inpatient Psychiatric Facility prospective payment system effective Oct. 1, 2022 through Sept. 30, 2023.

Apr 11, 2022

FFY 2023 IRF PPS Proposed Rule

CMS published its annual proposed rule updating the Medicare Inpatient Rehabilitation Facility prospective payment system effective Oct. 1, 2022 through Sept. 30, 2023.

Dec 13, 2021

CY 2022 OPPS Final Rule

CMS published its annual final rule updating the Medicare outpatient prospective payment system effective Jan. 1, 2022 through Dec. 31, 2022. See IHA's fact sheet on the final rule.

Dec 03, 2021

CY 2022 Home Health PPS Final Rule

CMS published its annual final rule updating the Medicare home health prospective payment system effective Jan. 1, 2022 through Dec. 31, 2022.

Sep 02, 2021

FFY 2022 Hospice PPS Final Rule

CMS published its annual final rule updating the Medicare Hospice prospective payment system effective Oct. 1, 2021 through Sept. 30, 2022.

Aug 26, 2021

FFY 2022 Long Term Care Hospital Final Rule Fact Sheet

CMS published its annual final rule updating the Medicare Long Term Care Hospital (LTCH) prospective payment system effective Oct. 1, 2021 through Sept. 30, 2022.

Aug 17, 2021

FFY 2022 IPPS Final Rule

CMS published its federal fiscal year 2022 final rule updating the Medicare inpatient prospective payment system. Additional rulemaking is forthcoming.

Aug 16, 2021

FFY 2022 IPF PPS Final Rule

CMS published its federal fiscal year 2022 final rule updating the Medicare inpatient psychiatric facility PPS, including required reporting of COVID-19 healthcare personnel vaccination rates.

Aug 16, 2021

FFY 2022 IRF PPS Final Rule

CMS published its FFY 2022 final rule updating the Medicare inpatient rehabilitation facility prospective payment system including required reporting of COVID healthcare personnel vaccination rates.

Aug 16, 2021

FFY 2022 SNF PPS Final Rule

CMS published its federal FY 2022 final rule updating the Medicare skilled nursing facility prospective payment system, including required reporting of COVID healthcare personnel vaccination rates.

Aug 04, 2021

CY 2022 OPPS Proposed Rule

CMS published its calendar year 2022 proposed rule updating the Medicare outpatient prospective payment system, including updates to the hospital price transparency rule.

Jul 20, 2021

CY 2022 HH PPS Proposed Rule

CMS published its annual proposed rule updating the Medicare home health prospective payment system effective Jan. 1, 2022 through Dec. 31, 2022.

May 06, 2021

FFY 2022 LTCH Proposed Rule

CMS published its annual proposed rule updating the Medicare long-term acute care hospital prospective payment system effective Oct. 1, 2021 through September 30, 2022.

May 04, 2021

FFY 2022 IPPS Proposed Rule

CMS published its annual proposed rule updating the Medicare inpatient prospective payment system effective Oct. 1, 2021 through Sept. 30, 2022.

Apr 15, 2021

FFY 2022 Hospice Proposed Rule

CMS published its annual proposed rule updating the Medicare hospice prospective payment system effective Oct. 1, 2021 through Sept. 30, 2022.

Apr 15, 2021

FFY 2022 SNF Proposed Rule

CMS published its annual proposed rule updating the Medicare skilled nursing facility (SNF) prospective payment system effective Oct. 1, 2021 through Sept. 30, 2022.

Apr 15, 2021

FFY 2022 IPF Proposed Rule

CMS published its annual proposed rule updating the Medicare inpatient psychiatric facility (IPF) prospective payment system effective Oct. 1, 2021 through Sept. 30, 2022.

Apr 15, 2021

FFY 2022 IRF Proposed Rule

CMS published its annual proposed rule updating the Medicare inpatient rehabilitation facility (IRF) prospective payment system effective Oct. 1, 2021 through Sept. 30, 2022.

Jan 19, 2021

CMS to Reprocess 2019 Excepted Off-Campus PBD Claims

CMS will begin reprocessing and recouping reimbursement made for certain 2019 outpatient services provided at excepted off-campus Provider-Based Departments.

Dec 10, 2020

CY 2021 OPPS Final Rule Fact Sheet

CMS published its annual final rule updating the Outpatient Prospective Payment System, effective Jan. 1, 2021. The final rule includes new COVID-19 hospital reporting requirements.

Dec 04, 2020

CY 2021 Final Rule Medicare Physician Fee Schedule Fact Sheet

CMS published its annual final rule updating the Medicare Physician Fee Schedule, effective Jan. 1, 2021, including changes to Medicare telehealth policy.

Nov 16, 2020

CY 2021 Final Rule Medicare Home Health Fact Sheet

CMS published its annual final rule updating the Medicare Home Health Prospective Payment System, effective Jan. 1, 2021 to Dec. 31, 2021.

Sep 10, 2020

FFY 2021 Final Rule Medicare Hospice Fact Sheet

CMS published its annual final rule updating the Medicare Hospice Prospective Payment System wage index, payment rates and quality-reporting program effective Oct. 1, 2020-Sept. 30, 2021.
Sep 10, 2020

FFY 2021 Medicare LTCH Final Rule

On Sept. 3, CMS published its annual final rule updating the LTCH Prospective Payment System effective Oct. 1, 2020 through Sept. 30, 2021.

Sep 10, 2020

FFY 2021 Medicare IPPS Final Rule

On Sept. 3, CMS published its annual final rule updating the Inpatient Prospective Payment System effective Oct. 1, 2020 through Sept. 30, 2021.

Aug 12, 2020

FFY 2021 IPF Final Rule

CMS published its annual final rule updating the Medicare inpatient psychiatric facility prospective payment system effective Oct. 1, 2021. See IHA’s fact sheet for important details on the rule.

Aug 10, 2020

FFY 2021 IRF Final Rule

CMS published its annual final rule updating the Medicare inpatient rehabilitation facility prospective payment system effective Oct. 1, 2021. See IHA's fact sheet for important details on the rule.

Aug 10, 2020

FFY 2021 SNF Final Rule

CMS published its annual final rule updating the Medicare skilled nursing facility prospective payment system effective Oct. 1, 2021. IHA's fact sheet provides detailed information on the rule.

Jan 09, 2020

Final Rule: CY 2020 OPPS/ASC Services with Correction Notice

On Nov.12, CMS published the final annual update regarding the Medicare outpatient prospective payment system (OPPS) and ambulatory surgical center payment system (ASC) for calendar year (CY) 2020.

Nov 21, 2023

CMS Final 340B Payment Remedy

CMS finalized a payment remedy in response to underpayments to 340B hospitals from 2018 through 2022.

Nov 15, 2023

Medicare Advantage Final Rule Implementation Handbook

The American Hospital Association developed this implementation guide to help equip hospitals and health systems with tools to better advocate for MA plan compliance with regulatory requirements.

Dec 02, 2022

2023 Medicare Behavioral Health and Telehealth Fact Sheet

This fact sheet summarizes several behavioral health and telehealth policies implemented via CY 2023 Medicare payment rules.

Nov 22, 2022

Medicare Quality Programs Reference Guide

This reference guide includes details for the 2023, 2024, and 2025 Medicare Value-Based Purchasing, Readmissions Reduction, and Hospital-Acquired Condition Reduction programs.

Jun 09, 2022

Overview of Medicare RRP and HAC Programs

An IHA webinar on June 9 provided an overview of the Medicare Readmissions Reduction Program (RRP) and Hospital Acquired Condition (HAC) Program. A recording of the webinar is available here.

May 20, 2022

Webinar: Top Medicare Reimbursement Opportunities Post COVID

An IHA webinar on May 17 identified strategies to enhance Medicare reimbursement. Access the webinar recording here (password Ehc6efgf). Click "Read More" below for the program slides.

May 18, 2022

Overview of Medicare VBP Program

An IHA webinar on May 16 provided an overview of the Medicare Value Based Purchasing (VBP) Program, which is the only Medicare quality program to recognize improvement as well as achievement.

Nov 10, 2021

Federal No Surprises Act Implementation

IHA shares concerns on the No Surprises Act, which outlined new patient protections from surprise medical bills and requirements for healthcare providers and health plans.

May 12, 2021

CMS Releases Guidance for Electronic ADT Notification CoP

CMS issued interpretative guidance concerning the Interoperability and Patient Access final rule electronic admission, discharge and transfer notification Conditions of Participation.

Mar 29, 2021

Updated Electronic ADT Enforcement Date and ONC Information

The implementation and enforcement deadline for new electronic admission, discharge and transfer notifications tied to Medicare Conditions of Participation is May 1, 2021.

Mar 22, 2021

May 1 Implementation Deadline: Electronic Exchange of Patient ADTs as Medicare CoP

As part of Medicare Conditions of Participation, hospitals, psychiatric hospitals and critical access hospitals must send electronic patient admission, discharge and transfer information by May 1.

Feb 25, 2021

March 29 Deadline: Apply for IME and DGME FTE Slots

Teaching hospitals have until March 29 to apply for IME and DGME slots made available by the recent closure of two teaching hospitals.

Dec 10, 2020

Upcoming Deadlines: Medicare Quality Program Reporting and Reweighting Extensions

Hospitals and clinicians may apply for quality data reporting exceptions due to COVID-19. See an IHA memo with deadlines and additional information.

Dec 03, 2020

FFY 2021 Medicare Bad Debt Policy Changes

CMS clarified and codified longstanding Medicare bad debt policy via the FFY 2021 IPPS final rule. See IHA's fact sheet on the recent policy changes.

Jun 26, 2020

Delayed Due Dates for Medicare Cost Reports

CMS delays the due date for several upcoming cost report submissions.

Feb 26, 2020

HHS OIG Work Plan, 2020

IHA closely monitors the OIG Work Plan to keep our members informed about potential changes to the healthcare landscape. This document summarizes current OIG studies members may find most pertinent.

Jan 14, 2020

CLFS PAMA Reporting Period Changes

CMS delayed the private payer data reporting period for CDLTs from applicable laboratories, including hospital outreach laboratories, as required under the Protecting Access to Medicare Act of 2014.

Oct 25, 2019

Final Rule: Changes to Medicare Conditions of Participation

On Sept. 30, the Centers for Medicare & Medicaid Services (CMS) published in the Federal Register (FR) a final rulemaking a series of changes to the Medicare conditions of participatio n(CoP).

Oct 25, 2019

Final Rule: Revised Discharge Planning Requirements for Hospitals

On Sept. 30, CMS published a final rule modifying discharge process requirements as a condition of participation for hospitals, critical access hospitals (CAHs) and home health agencies (HHAs).

Sep 12, 2019

Proposed Specialty Care Models: Radiation Oncology and End-Stage Renal

On July 18, CMS published in the Federal Register (FR) two proposed specialty care models specific to radiation oncology and end-stage renal disease (ESRD).

Dec 19, 2023

IHA Comments on Federal IDR Operations Proposed Rule

IHA submitted comments on proposed changes to open negotiation, IDR eligibility determination, and batching requirements under the No Surprises Act.

Oct 24, 2023

IHA Comments on 2024 IDR Proposed Fees

IHA submitted comments on the proposed 300% increase in IDR administrative fees for 2024.

Sep 19, 2023

IHA Comments on Draft Merger Guidelines by DOJ, FTC

IHA comments on the Draft Merger Guidelines (Draft Guidelines) issued on July 18, 2023 by the Department of Justice (DOJ) and the Federal Trade Commission (FTC).

Sep 07, 2023

IHA Comment Letter on CY24 Outpatient Prospective Payment System Proposed Rule

IHA comments on the calendar year 2024 (CY24) Outpatient Prospective Payment System (OPPS) proposed rule.

Sep 01, 2023

IHA Comments on CMS’ Proposed 340B Payment Remedy

IHA supports CMS’ proposed lump sum repayment, but urges the Agency not to pursue budget neutrality.

Aug 15, 2023

Comments on CY24 Home Health PPS Proposed Rule

In a letter on the calendar year 2024 (CY24) Home Health prospective payment system (PPS) proposed rule, IHA urges CMS to recalculate the proposed negative rate update to support these services.

Jul 03, 2023

IHA Comment Letter on Direct Payments

In comments to CMS' director, IHA applauds the agency for authorizing State Directed Payments for Medicaid and urges that no further restrictions be placed on their use.

Jun 06, 2023

Comments on FY2024 IPPS Proposed Rule

In a letter on the fiscal year (FY) 2024 inpatient prospective payment system (IPPS) proposed rule, IHA urges CMS to recalculate the proposed rate update to better reflect hospital costs.

Mar 10, 2023

Comments on Prior Authorization Proposed Rule

IHA comments urge further standardization of prior authorization processes and shortened decision timelines across payers.

Sep 13, 2022

Comments on CY 2023 OPPS Proposed Rule

IHA urges CMS to increase the CY 2023 OPPS rate update and promptly repay hospitals impacted by its unlawful 340B reimbursement policy.

Aug 16, 2022

Comments on CY 2023 HH Proposed Rule

IHA urges CMS to increase its proposed rate update for the CY 2023 HH PPS and reconsider its proposed PDGM behavior adjustment.

Jun 16, 2022

Comments on FY 2023 IPPS Proposed Rule

In a letter on the fiscal year (FY) 2023 inpatient prospective payment system (IPPS) proposed rule, IHA urges CMS to recalculate the proposed rate update to better reflect hospital costs.

Jun 06, 2022

Comments on FY 2023 SNF Proposed Rule

In a letter on the fiscal year (FY) 2023 skilled nursing facility (SNF) payment proposed rule, IHA urges CMS to improve several proposed payment policies to better support SNFs in the coming year.

May 27, 2022

Comments on FY 2023 IRF Proposed Rule

In a letter on the Inpatient Rehabilitation Facility proposed rule, IHA urges CMS to improve the proposed rate update to better reflect economic realities hospitals face.

Sep 17, 2021

Comments on CY 2022 OPPS Proposed Rule

IHA urges CMS to postpone proposed increases to civil monetary penalties for price transparency noncompliance and support making permanent certain COVID-19 telehealth and supervision waivers.

Sep 01, 2021

IHA Comments on CY22 Medicare PFS Proposed Rule

IHA sent a comment letter to CMS on the CY22 Medicare PFS proposed rule, expressing disappointment that CMS declined to permanently add new telehealth services to Medicare under the CY 2022 PFS.

Aug 27, 2021

Comments on CY 2022 Home Health PPS Proposed Rule

IHA comments focus on proposed home health quality changes, urging the administration to maintain current measurement selection processes to enhance transparency.

Jun 28, 2021

Comments on FFY 2022 IPPS LTCH Proposed Rule

IHA comments urge collaboration on measuring health equity, delaying changes to Medicare organ transplantation payments, and expanding the cap on residency positions available under the CAA.

Jun 07, 2021

Comments on FFY 2022 IPF Proposed Rule

IHA submitted comments urging CMS to pursue National Quality Forum endorsement of proposed quality program measures.

Jun 07, 2021

Comments on FFY 2022 IRF Proposed Rule

IHA submitted comments requesting CMS continue monitoring public reporting of quality data impacted by COVID and ensure adequate resources for PAC providers transitioning to electronic standards.

Jun 07, 2021

Comments on FFY 2022 SNF Proposed Rule

IHA submitted comments urging CMS to delay and phase-in recoupment of overpayments made to SNF providers in FFY 2020, and explore revisions to the SNF VBP.

Oct 05, 2020

Comments on CY 2021 PFS Proposed Rule

IHA submitted comments urging CMS to use its authority and influence to indefinitely maintain and expand telehealth access granted during the public health emergency.

Oct 05, 2020

Comments on Treatment of Medicare Part C Days in Disproportionate Patient Percentage

IHA submitted comments objecting to his proposed rule, as it retroactively imposes a rule that the Supreme Court of the United States determined invalid.

Oct 05, 2020

Comments on CY 2021 OPPS Proposed Rule

IHA submitted comments addressing supervision levels, 340B payments, prior authorization policies, discontinuation of the inpatient only list, and Overall Star Ratings changes.

Jul 09, 2020

Comments on FY 2021 IPPS Proposed Rule

IHA submitted comments addressing CMS’ proposed utilization of hospital price transparency rule data, certain proposed changes to Medicare bad debt policies, and worksheet S-10 audits.

Apr 06, 2020

Comments on Medicare Advantage Proposed Rule

IHA submitted comments urging CMS to forgo proposals that would allow MA plans to assemble narrower provider networks.

Nov 29, 2019

Comments on Proposed 340B Provider Survey

IHA commented on the proposed collection of 340B provider acquisition costs.

Sep 27, 2019

OPPS Price Transparency Comments

IHA commented on on the proposed rule that would establish new price transparency requirements.

Sep 16, 2019

IHA Submits Comments to CMS on Proposed Rule Establishing Two New Specialty Care Models

IHA submitted comments to CMS on the the proposed rule establishing two new specialty care models specific to
radiation oncology and end-stage renal disease.

Nov 19, 2018

IHA Comment Letter: 340B Ceiling Prices

Comment letter to the Health Resources and Services Administration encouraging the agency to publish its final rule in time to meet the Jan. 1, 2019 proposed date.