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Trinity Health regularly provides comments to policymakers to help them lead the way toward a system that provides affordable, high-value, high-quality care to every patient, while giving health care providers more opportunities to deliver the best possible care.
We have commented on:
Electronic Health Record (EHR) Incentive Program
As one of the largest hospital systems to attest to Stage 1 meaningful use, Trinity Health is uniquely positioned to comment on the newly proposed requirements for the Medicare and Medicaid programs. Trinity Health firmly supports the EHR Incentive Program and offers recommendations for Stage 2 implementation. Expanding and enhancing EHR use will improve patient care, reduce costs, and enhance quality of care. Trinity Health's previous comments on Stage 1 implementation can be found here.
Medicare Reporting and Returning of Overpayments
Through its robust compliance program, Trinity Health demonstrates a strong commitment to accurate claims submission, continuous claims process improvements and timely correction. Trinity Health’s comments to CMS on the Medicare overpayments proposed rule detail several concerns related to the impact this rule would have on hospitals.
Draft National Priorities and Research Agenda from PCORI
As one of the largest Catholic health systems in the country, Trinity Health is actively engaged in the development of innovative care models. Trinity Health appreciates the Patient-Centered Outcomes Research Institute’s (PCORI’s) commitment to creating diverse research opportunities through its five priority areas. PCORI’s broad approach to research will facilitate greater creativity as providers work to develop health care solutions.
FDA Drug Reporting Requirements
Trinity Health applauds recent changes to improve drug reporting requirements including broadening the terms related to discontinuance notification. These changes will help reduce the occurrence of drug shortages, and allow providers to better prepare for any decreases in the availability of specific medications. With national shortages tripling in just six years, drug shortages can have devastating implications for patients as they struggle to access the drugs they need. The Food and Drug Administration’s (FDA) interim final rule signifies the FDA’s commitment to ensuring timely and appropriate care for all patients by facilitating access to necessary medications.
Medicaid DSH Definition of “Uninsured”
Trinity Health applauds CMS for proposing to broaden the definition of uninsured for purposes of setting the hospital-specific limit on Medicaid disproportionate share hospital (DSH) payments. In its comment letter, Trinity Health recommends that CMS incorporate additional costs into the final rule to better ensure that DSH payments appropriately reflect the uncompensated costs of care that all hospitals face, and will be able to better support hospitals as they strive to improve care and access for all patients.
Essential Health Benefits
As long time advocates of adequate and affordable coverage for all, Trinity Health appreciates the Department of Health and Human Services’ (HHS) efforts in defining standard minimum health benefits and recently provided comments on the HHS Essential Health Benefits (EHB) Informational Bulletin. Trinity Health strongly supports HHS’ proposal to allow for state flexibility in selecting a benchmark plan that will define EHB, while also ensuring a comprehensive level of health insurance coverage nationwide. If finalized, these proposals will allow states, providers, and payers to work together to improve patient care and reduce costs, while also providing a strong level of coverage for all consumers.
Conditions of Participation
Trinity Health strongly supports updating the Medicare and Medicaid Conditions of Participation to streamline clinical processes, eliminate duplicative efforts and roles, and allow for more flexibility, within the scope of practice, for non-physician clinicians. If finalized, CMS’ proposed changes will allow hospitals to improve patient care and enhance patient experience, while also reducing healthcare costs. Trinity Health provided comments to CMS and urged the agency to issue final guidance soon after the end of the comment period.
Health Coverage Affordability Safe Harbor for Employers
As an employer of more than 53,000 full-time equivalent employees, Trinity Health supports the proposed Internal Revenue Service (IRS) safe harbor. This safe harbor would allow employers greater flexibility in providing coverage to their employees and ensure that employees are offered affordable coverage. Trinity Health provided comments to the IRS on this issue.
Common Program Requirements for Graduate Medical Education
Trinity Health has demonstrated a significant and ongoing commitment to graduate medical education (GME) through its extensive sponsorship of and participation in both allopathic and osteopathic residency training programs. Through participation in GME, Trinity Health hospitals are working to ensure access to care for the populations in states, regions, and communities they serve. Trinity Health provided comments to the Accreditation Council for Graduate Medical Education (ACGME) on proposed changes to Common Program Requirements.
Establishment of Exchanges and Qualified Health Plans
Trinity Health strongly supports health insurance exchanges as a way of facilitating the purchase of insurance coverage and improving transparency of information to inform consumer choices of providers. Successful exchanges will expand access and facilitate consumer engagement with robust transparency around price, quality, and benefit designs. Trinity Health provided comments to the Department of Health and Human Services (HHS) on the establishment of exchanges.
Coverage of Preventive Services
Trinity Health supports the efforts of the Catholic Health Association (CHA) regarding the rule issued by the Department of Health and Human Services (HHS) on requirements for Women’s Preventive Services. We are pleased that health insurance coverage must include critical screening services without any cost sharing, but we are concerned about the inadequacy of the religious employer exemption with respect to contraceptive services and sterilization. Trinity Health provided a comment letter to HHS on this issue.
New Requirements for Tax-Exempt Hospitals
Trinity Health continually seeks to assess, respond to and account for meeting the needs of the communities it serves and have commented to the Internal Revenue Service (IRS) on requirements for tax-exempt hospitals as established under the Affordable Care Act (ACA).
Accountable Care Organizations (ACOs) or the Medicare Shared Savings Program (MSSP)
Trinity Health's comments on the Medicare Shared Savings Program as CMS developed the rule, were followed by more recent comments on the proposed rule. On May 31, 2011, Trinity Health commented to:
Value-Based Purchasing
Value-Based Purchasing (VBP) programs will pay hospitals for their actual performance on quality measures, rather than just the reporting of those measures. Trinity Health provided comments to Centers for Medicare and Medicaid Services (CMS) on the Hospital Inpatient VBP program proposed rule.
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