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“Second, we ask that Congress remove national policies that impede progress, integration of healthcare providers and undermine efforts to reduce costs and improve quality. While new models of payment and care are helping hospitals and other providers transform the way care is delivered, regulatory barriers still exist in the current healthcare system that limit the extent to which hospitals and other providers are able to improve the quality, efficiency and accessibility of the healthcare they deliver. We still need to eliminate obstacles such as some of those that exist in the self-referral and antitrust provisions that prevent physicians and hospitals from integrating their services. For example, beneficiaries should be allowed to receive information from providers that could influence where they seek care such as information on the quality of different care sites. Other existing Medicare policies, such as requiring a three-day hospital stay before Medicare will cover skilled nursing facility services, create perverse incentives to admit and keep patients in the hospital at a time when we are trying to avoid inpatient stays altogether by better care coordination.

“Thirdly, we ask for a continued effort to streamline the Medicare program and reduce the regulatory burden on providers. Congress should push CMS to continue reviewing the cost report, the conditions or participation, the measurement framework, and the payment error review programs to simplify, coordinate, and bring these policies in line with the new world of payment under delivery system reform. The efficiencies gained from simplifying these policies will result in additional time and resources being freed up for providing high-value care to patients.

“Finally, as the process set forth in the Budget Control Act and other deficit reduction efforts move forward, we urge Congress to put in place a mechanism to account for savings that are achieved by hospitals in the Medicare program. If any level of sequestration occurs and hospitals are successful in keeping the trend growth rate below what is projected, this work should be “credited” to them in future sequestration. In other words, if hospitals are able to achieve even deeper savings than the sequestrated amount through implementing delivery system reforms and other innovations, that amount should be debited from the future years’ sequestration amount.

“We believe it is short-sighted to introduce more instability and penalize hospitals when spending growth is at a historic low and hospitals are making herculean efforts to transform healthcare. We urge Congress to recognize and encourage this progress, not cut payments that fund this needed work.”