AHA STATEMENT ON INTERPRETIVE GUIDANCE ON CMS DATA COLLECTION AND
MEDICARE CONDITIONS OF PARTICIPATION INTERIM FINAL RULE
President and CEO
American Hospital Association
October 6, 2020
Tying data reporting to participation in the Medicare program remains an overly heavy-handed approach that could jeopardize access to hospital care for all Americans. The impact of barring hospitals from Medicare and Medicaid has the potential to harm more than those program’s enrollees, and threatens more than just the life-saving care hospitals are providing to COVID-19 patients. The reality is many hospitals could not keep their doors open should they no longer receive payment from Medicare and Medicaid, affecting care for all Americans in the midst of a global pandemic.
Today’s interpretive guidance on COVID data reporting does answer some of the questions hospitals and health systems have been asking about compliance since the interim final rule was released six weeks ago. In particular, the Administration will provide hospitals with information on whether their data are making it into HHS Protect and they will give hospitals the necessary time to adjust their data collection to come into compliance if need be. The guidance also reduces the reporting burden on psychiatric and rehabilitation hospitals, which generally do not treat COVID-19 patients.
America’s hospitals and health systems remain focused on patient care and battling COVID-19, while also providing the government with the public health data it needs, in spite of ever-changing requests. The federal agencies have specified that data can only get into HHS Protect if it goes through a private contractor or through the department of health for the state in which the hospital is located. We have observed errors in data processing and confusion about exactly what was being requested at the hospital, state, contractor, and federal level and have worked diligently with the federal agencies to identify and correct those problems. This has resulted in at least 94% of hospitals submitting data. This level of success was made possible by partnership, not mandates.
The entire hospital field remains fully committed to ensuring that the federal government gets the data it needs and urges HHS to only request data that are essential to critical decisions so that hospital staff can remain focused on their primary responsibility -- caring for patients.