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
FY 2027 Medicare LTCH proposed rule brief
On April 10, CMS posted the fiscal year 2027 Medicare Long-Term Hospital Prospective Payment System (LTCH PPS) proposed rule effective Oct. 1, 2026 through Sept. 30, 2027.
FY 2027 Medicare IPPS proposed rule brief
On April 10, CMS posted the fiscal year 2027 Medicare Inpatient Prospective Payment System (IPPS) proposed rule effective Oct. 1, 2026 through Sept. 30, 2027.
FY 2027 Medicare SNF proposed rule brief
On April 2, CMS posted the fiscal year 2027 Medicare Skilled Nursing Facility (IPF) proposed rule effective Oct. 1, 2026 through Sept. 30, 2027.
FY 2027 Medicare IRF proposed rule brief
On April 2, CMS posted the fiscal year 2027 Medicare Inpatient Rehabilitation Facility (IRF) proposed rule effective Oct. 1, 2026 through Sept. 30, 2027.
FY 2027 Medicare IPF proposed rule brief
On April 3, CMS posted the fiscal year 2027 Medicare Inpatient Psychiatric Facility (IPF) proposed rule effective Oct. 1, 2026 through Sept. 30, 2027.
CY 2026 Medicare OPPS final rule brief
On Nov. 21, CMS posted the calendar year 2026 Medicare Outpatient Prospective Payment System (OPPS) final rule effective Jan. 1, 2026 through Dec. 31, 2026.
CY 2026 Medicare HH final rule brief
On Nov. 28, CMS posted the calendar year 2026 Medicare Home Health (HH) final rule effective Jan. 1, 2026 through Dec. 31, 2026.
CY 2026 Medicare OPPS Top 10 List
This Top 10 List outlines ten policies finalized in the CY 2026 OPPS rule that we want IHA members to be aware of and understand.
CY 2026 Medicare PFS Final Rule Memo
On Oct. 31, the Centers for Medicare & Medicaid Services (CMS) released its Calendar Year (CY) 2026 Physician Fee Schedule final rule.
FY 2026 Medicare IPF final rule brief
On July 31, CMS posted the fiscal year 2026 Medicare Inpatient Psychiatric Facility (IPF) final rule effective Oct. 1, 2025 through Sept. 30, 2026.
FY 2026 Medicare IRF final rule brief
On August 1, CMS posted the fiscal year 2026 Medicare Inpatient Rehabilitation Facility (IRF) final rule effective Oct. 1, 2025 through Sept. 30, 2026.
FY 2026 Medicare LTCH final rule brief
On July 31, CMS posted the fiscal year 2026 Medicare Long-Term Care Hospital (LTCH) final rule effective Oct. 1, 2025 through Sept. 30, 2026.
FY 2026 Medicare SNF final rule brief
On July 31, CMS posted the fiscal year 2026 Medicare Skilled Nursing Facility (IPF) final rule effective Oct. 1, 2025 through Sept. 30, 2026.
FY 2026 Medicare IPPS final rule brief
On July 31, CMS posted the fiscal year 2026 Medicare Inpatient Prospective Payment System (IPPS) final rule effective Oct. 1, 2025 through Sept. 30, 2026.
CY 2026 Medicare OPPS proposed rule brief
On July 15, CMS posted the calendar year 2026 Medicare Outpatient Prospective Payment System (OPPS) proposed rule effective Jan. 1, 2026 through Dec. 31, 2026.
CY 2026 Medicare HH proposed rule brief
On June 30, CMS posted the calendar year 2026 Medicare Home Health (HH) Prospective Payment System proposed rule effective Jan. 1, 2026 through Dec. 31, 2026.
FY 2026 Medicare IPPS proposed rule brief
On April 11, CMS posted the fiscal year 2026 Medicare Inpatient Prospective Payment System (IPPS) proposed rule effective Oct. 1, 2025 through Sept. 30, 2026.
FY 2026 Medicare LTCH proposed rule brief
On April 11, CMS posted the fiscal year 2026 Medicare Long-Term Care Hospital Prospective Payment System (LTCH PPS) proposed rule effective Oct. 1, 2025 through Sept. 30, 2026.
FY 2026 Medicare IPF proposed rule brief
On April 11, CMS posted the fiscal year 2026 Medicare Inpatient Psychiatric Facility Prospective Payment System (IPF PPS) proposed rule effective Oct. 1, 2025 through Sept. 30, 2026.
FY 2026 Medicare IRF proposed rule brief
On April 11, CMS posted the fiscal year 2026 Medicare Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) proposed rule effective Oct. 1, 2025 through Sept. 30, 2026.
FY 2026 Medicare SNF proposed rule brief
On April 11, CMS posted the fiscal year 2026 Medicare Skilled Nursing Facility Prospective Payment System (SNF PPS) proposed rule effective Oct. 1, 2025 through Sept. 30, 2026.
CY 2025 Medicare PFS Final Rule Memo
Summary of telehealth, behavioral health, and health equity policies finalized in the CY 2025 Medicare Physician Fee Schedule final rule.
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.
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.
Telehealth Coverage and Practice Waiver Updates
This document provides updates to IHA members on federal and state telehealth coverage and practice waivers.
Proposed Rule Seeks to Strengthen Federal Oversight of Organ Procurement
On Jan. 30, CMS issued a proposed rule that updates conditions of coverage for Organ Procurement Organizations, strengthening federal oversight of these organizations.
CMS Proposed Rules Banning Gender-Affirming Care for Children
CMS proposed new hospital conditions of participation that would ban the provision of and federal payment for most gender-affirming care services for children.
Medicare Advantage Provider Complaint Submission Form
Organizations representing Medicare providers and seeking assistance from CMS in resolving Medicare Advantage claims issues must complete this form by following these instructions.
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.
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 Submits Comments on Federal 340B Rebate Model
IHA submitted comments to the U.S. Dept. of Health and Human Services Health Resources and Services Administration (HRSA) on the 340B Rebate Model Pilot Program.
IHA Comments on Federal Investigation of Imported Medical Device and Equipment, Tariffs
IHA expressed concerns regarding tariff policies on medical supplies that would disrupt the current supply chain, financially challenge providers, and negatively impact access to healthcare.
IHA Comments on CY 2026 Medicare Outpatient Payment Proposed Rule
IHA submitted comments on the CY 2026 OPPS proposed rule, requesting the reversal of several proposed policy changes.
IHA Comments on CY 2026 Medicare Physician Fee Schedule Proposed Rule
The Illinois Health and Hospital Association (IHA) comments on the calendar year (CY) 2026 Medicare Physician Fee Schedule (PFS) proposed rule.
IHA Comments on 340B Rebate Model Pilot Program
IHA submitted comments on HRSA’s 340B Rebate Model Pilot Program, describing the need for rigorous program oversight and enforcement from HRSA.
IHA Comments on Proposed MA Data Collection
IHA submitted comments on CMS’ proposed collection of service-level MA plan data.
IHA Comments on FY 2026 IPPS Proposed Rule
On June 5, IHA submitted comments to CMS on the FY 26 IPPS proposed rule, focusing on payment methodologies and social drivers of health.
IHA Comments on Regulatory Burden RFI
On June 5, IHA submitted comments to the administration on current rules and regulations that are administratively burdensome and negatively impact access to care and hospital operations.
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 Comments on CMS’ Proposed 340B Payment Remedy
IHA supports CMS’ proposed lump sum repayment, but urges the Agency not to pursue budget neutrality.