Consumers First Comment Letter to the Federal Government on the Hospital Inpatient Prospective Payment System Proposed Rule

Consumers First is an alliance that brings together the interests of consumers, children, employers, labor unions, and primary care working to change the fundamental economic incentives and design of the health care system. Our work is to realign the incentives and design of health care, so the system truly delivers the health and high-value care that all families across the nation deserve.

Medicare payment policy often establishes a standard that is then adopted by other payers, including commercial insurers and Medicaid. Changes made to the Medicare Inpatient Prospective Payment System (IPPS) for Calendar Year 2021 offer an important opportunity to strengthen the Medicare program and to signal to other payers the need to realign the economic incentives of health care payment and delivery to truly meet the needs of all families, children, seniors, and adults across the country. The recommendations made by Consumers First could catalyze the transformational change needed in our payment system to drive high value care into the health care system and across health care markets in the U.S.

Given our focus on transforming health care payment and delivery systems to provide high value care to consumers, our comment letter focus on the following sections of the proposed rule:

• Hospital Value-Based Payment Program
• Hospital Inpatient Quality Reporting Program
• Market-Based MS-DRG Relative Weight Proposed Data Collection and Potential Change in Methodology for Calculating MS-DRG Relative Weight