The Health Law Section submitted comments on the proposed rule issued by the Centers for Medicare and Medicaid Services (CMS) entitled “Medicare Program;Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2018 Rates; Quality Reporting Requirements for Specific Providers; Medicare and Medicaid Electronic Health Record (EHR) Incentive Program Requirements for Eligible Hospitals, Critical Access Hospitals, and Eligible Professionals; Provider-Based Status of Indian Health Service and Tribal Facilities and Organizations; Costs Reporting and Provider Requirements; Agreement Termination Notices” and published in the April 28, 2017 Federal Register (CMS 1677-P; 82 Fed. Reg. 19796- 20231) (the Proposed Rule).
The views expressed herein are presented on behalf of the Section. No government attorneys or government professional participated in the drafting of submission of these comments. Accordingly, the views expressed in these comments should not be construed as representing the policy or views of any government employee who is a member of the Section or its Council. These comments have not been approved by the House of Delegates or the Board of Governors of the American Bar Association and, accordingly should not be construed as representing the position of the American Bar Association.
The Section wants to thank Allie Petrova and Ayeisha Cox who contributed to these comments.
Click here to view the comments.