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
CY 2025 PFS
Summary of telehealth, behavioral health, and health equity policies finalized in the CY 2025 Medicare Physician Fee Schedule final rule.
CY 2025 Medicare HH final rule brief
On Nov. 1, CMS posted the calendar fiscal year 2025 Medicare Home Health Prospective Payment System (HH PPS) final rule effective Jan. 1, 2025 through Dec. 31, 2025.
CY 2025 Medicare OPPS final rule brief
On Nov. 1, CMS posted the calendar fiscal year 2025 Medicare Outpatient Prospective Payment System (OPPS) final rule effective Jan. 1, 2025 through Dec. 31, 2025.
FY 2025 Medicare LTCH final rule brief
On August 1, CMS posted the federal fiscal year 2025 Medicare Long-Term Care Hospital (LTCH) Prospective Payment System final rule effective Oct. 1, 2024 through Sept. 30, 2025.
FY 2025 Medicare IPF final rule brief
On July 31, CMS posted the federal fiscal year 2025 Medicare Inpatient Psychiatric Facility (IPF) Prospective Payment System final rule effective Oct. 1, 2024 through Sept. 30, 2025.
FY 2025 Medicare IPPS final rule brief
On August 1, CMS posted the federal fiscal year 2025 Medicare Inpatient Prospective Payment System (IPPS) final rule effective Oct. 1, 2024 through Sept. 30, 2025.
FY 2025 Medicare SNF final rule brief
On July 31, CMS posted the federal fiscal year 2025 Medicare Skilled Nursing Facility (SNF) Prospective Payment System final rule effective Oct. 1, 2024 through Sept. 30, 2025.
FY 2025 Medicare IRF final rule brief
On July 31, CMS posted the federal fiscal year 2025 Medicare Inpatient Rehabilitation Facility (IRF) Prospective Payment System final rule effective Oct. 1, 2024 through Sept. 30, 2025.
CY 2025 Medicare OPPS proposed rule brief
On July 22, CMS posted the calendar year 2025 Medicare Outpatient Prospective Payment System (OPPS) proposed rule effective Jan. 1, 2025 through Dec. 31, 2025.
CY 2025 Medicare HH proposed rule brief
On June 26, CMS posted the calendar year 2025 Medicare Home Health Prospective Payment System (HH PPS) proposed rule effective Jan. 1, 2025 through Dec. 31, 2025.
FY 2025 Medicare IPF proposed rule brief
On March 28, CMS posted the federal fiscal year 2025 Medicare Inpatient Psychiatric Facility (IPF) Prospective Payment System proposed rule effective Oct. 1, 2024 through Sept. 30, 2025.
FY 2025 Medicare LTCH Proposed Rule Brief
On April 10, CMS posted the federal fiscal year 2025 Medicare Long-Term Care Hospital (LTCH) Prospective Payment System proposed rule effective Oct. 1, 2024 through Sept. 30, 2025.
FY 2025 IPPS Proposed Rule
CMS released its annual proposed rule updating the Medicare Inpatient Prospective Payment System effective Oct. 1, 2024 through Sept. 30, 2025.
FY 2025 Medicare SNF Proposed Rule Brief
On March 28, CMS posted the federal fiscal year 2025 Medicare Skilled Nursing Facility (SNF) Prospective Payment System proposed rule effective Oct. 1, 2024 through Sept. 30, 2025.
FY 2025 Medicare IRF Proposed Rule Brief
On March 27, CMS posted the federal fiscal year 2025 Medicare Inpatient Rehabilitation Facility (IRF) Prospective Payment System proposed rule effective Oct. 1, 2024 through Sept. 30, 2025.
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.
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.
Proposed Changes to Hospital Price Transparency Requirements
CMS proposed several changes to hospital price transparency requirements in the CY24 OPPS proposed rule.
Proposed 340B Payment Remedy
Details on CMS’ proposed payment remedy in response to its unlawful 340B payment policy implemented in CY 2018.
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.
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.
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.
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.
CY 2023 OPPS Final Rule
CMS finalized outpatient prospective payment system updates, effective Jan. 1, 2023 through Dec. 31, 2023.
Rural Emergency Hospitals – CoPs
CMS finalized Medicare Conditions of Participation for rural emergency hospitals, effective Jan. 1, 2023.
Rural Emergency Hospitals
CMS finalized policies and procedures specific to rural emergency hospitals, effective Jan. 1, 2023.
Update on 340B Drug Pricing Program
CMS restored the 340B reimbursement to average sales price plus 6% for calendar year 2023.
CY 2023 HH PPS Final Rule
CMS published the home health prospective payment system final rule effective Jan. 1, 2023 through Dec. 31, 2023.
FY 2023 IPPS Final Rule
CMS published the inpatient prospective payment system final rule effective Oct. 1, 2022 through Sept. 31, 2023.
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.
FY 2023 SNF Final Rule
CMS published the skilled nursing facility prospective payment system final rule effective Oct. 1, 2022 through Sept. 31, 2023.
FY 2023 IRF Final Rule
CMS published the inpatient rehabilitation facility prospective payment system final rule effective Oct. 1, 2022 through Sept. 31, 2023.
FY 2023 Hospice Finale Rule
CMS published the Medicare hospice payment final rule effective Oct. 1, 2022 through Sept. 31, 2023.
FY 2023 IPF Final Rule
CMS published the inpatient psychiatric facility prospective payment system final rule effective Oct. 1, 2022 through Sept. 31, 2023.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.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.
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.
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.
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.
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.
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.
New MA Appeals Provider Complaint Process
CMS has revised the complaint process provider organizations should use to submit complaints related to Medicare Advantage claim disputes and plan appeals.
Recording: Hospital Wage Index: Maximizing Medicare Reimbursement (5.9.24)
This webinar walks IHA members through the wage index development process, the impact of recent court cases and policy changes, and the opportunities before hospitals. Password: pDtV3mRA
340B ADR Final Rule
HRSA published a final rule revising the 340B ADR process required under the Affordable Care Act.
Recording: CMS Interoperability and Prior Authorization Final Rule (4.3.24)
CMS provided IHA members with an overview of the interoperability and prior authorization final rule (CMS-0057-F). Password: pMtq3rug
CMS Final 340B Payment Remedy
CMS finalized a payment remedy in response to underpayments to 340B hospitals from 2018 through 2022.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Delayed Due Dates for Medicare Cost Reports
CMS delays the due date for several upcoming cost report submissions.
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.
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.
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).
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).
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).
IHA Comments on CY25 Medicare PFS Proposed Rule
On Sept. 4, IHA submitted comments to the Centers for Medicare & Medicaid Services’ (CMS) on the calendar year (CY) 2025 Medicare Physician Fee Schedule (PFS) proposed rule.
IHA Comments on CY25 Medicare Outpatient Payments
IHA expressed disappointment with CMS’ inadequate CY25 OPPS rate update, and asked the agency to forgo new Conditions of Participation.
IHA Comments on FY2025 IPPS Proposed Rule
IHA comments urge CMS to reexamine the current time-lagged policies and methodologies utilized in updating hospital Medicare payment rates.
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.
IHA Comments on 2024 IDR Proposed Fees
IHA submitted comments on the proposed 300% increase in IDR administrative fees for 2024.
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).
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.
IHA Comments on CMS’ Proposed 340B Payment Remedy
IHA supports CMS’ proposed lump sum repayment, but urges the Agency not to pursue budget neutrality.
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.
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.
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.
Comments on Prior Authorization Proposed Rule
IHA comments urge further standardization of prior authorization processes and shortened decision timelines across payers.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Comments on FFY 2022 IPF Proposed Rule
IHA submitted comments urging CMS to pursue National Quality Forum endorsement of proposed quality program measures.
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.
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.
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.
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.
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.
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.
Comments on Medicare Advantage Proposed Rule
IHA submitted comments urging CMS to forgo proposals that would allow MA plans to assemble narrower provider networks.
Comments on Proposed 340B Provider Survey
IHA commented on the proposed collection of 340B provider acquisition costs.
OPPS Price Transparency Comments
IHA commented on on the proposed rule that would establish new price transparency requirements.
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.
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.
340B Drug Ceiling Price Effective Date
Comments due to HRSA by Nov. 23