NHHA submits comments on HRSA proposed regulation (7/21/11)
NHHA submits comments on HRSA proposed regulation implementing the Patient Protection and Affordable Care Act (ACA) provision that excludes orphan drugs for purchase under the 340B drug discount program for some types of hospitals, including Critical Access Hospitals (CAHs), rural referral centers (RRCs) and sole community hospitals (SCHs).
NHHA submitted comments to CMS on the IPPS Proposed Rule for Acute Care Hospitals for FFY 2012 (06/21/2011)
While NHHA supports a number of the proposed rule's provisions, including the rural floor budget neutrality adjustment, we have serious concerns about the documentation and coding adjustment and the readmissions proposal. NHHA is also requesting clarification and modification of CMS' proposed changes for determining defined benefit pension costs. Read the comments here
NHHA submits comment letter to CMS on the Medicare Shared Savings Program and Accountable Care Organization proposed rule (06/07/2011)
NHHA submitted its 8-page comment letter on June 6th to CMS regarding its proposed rule for Medicare Shared Savings Program and Accountable Care Organizations. Overall, "we agree with CMS’ underlying premise in drafting the rule that patient care must be provided in a more accountable and coordinated way. We also agree that providers should accept and manage appropriate risk in collaboration with other care givers across the continuum of care. Indeed, the majority of the NHHA members are focused on transitioning into an era of collaborative care and are interested in exploring new care models, including ACOs.
For these reasons, there was extraordinary anticipation in New Hampshire about the proposed rule for the SSP prior to its release and great interest in analyzing the rule with the hope that it would be possible for at least some of our hospitals, health systems and other continuing care members to participate. However, it quickly became clear to us through our many dialogues with hospital leaders, clinicians, and advocates that there was virtual unanimity that the rule, as proposed, would discourage, rather than encourage, our member hospitals and health systems from participating in the SSP."