American Society of Plastic Surgeons
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FEDERAL | ASPS Comments on 2018 Inpatient Proposed Rule

ASPS responded swiftly to the publication of proposed changes to the Medicare Hospital Inpatient Payment System. In a document that spans over 1,800-pages, CMS has suggested several changes to electronic clinical quality measures and the certification requirements for EHRs, which are slated to take effect in 2018. While the proposals appear favorable to physicians, ASPS reminded the Agency of the unintended consequences that can occur if changes are not made incrementally. The Society responded to the Agency's request for feedback with recommendations on how to account for social risk factors in the hospital value-based payment program, as well as the appropriate role of physician-owned hospitals in the delivery system. ASPS offered suggestions to alleviate administrative burdens, including following the spirit of legislative proposals drafted to address these very issues.

The document also included a proposal to create quality measures based on information provided via the informed consent process. ASPS encouraged the Agency to reconsider which specialties will be required to participate, as well as the volume and range of services included in the first year of the program. The Agency will spend the next several months reviewing all submitted comments. A Final Rule is expected to be published in November 2017.

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