February 13, 2015
Sean Cavanaugh
Deputy Administrator & Director
Centers for Medicare & Medicaid Services Hubert H. Humphrey Building
200 Independence Avenue, S.W., Room 445-G Washington, DC 20201
RE: Two-Midnight Policy and Potential Short Stay Payment Solutions
Dear Mr. Cavanaugh:

On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations,
and our 43,000 individual members, the American Hospital Association (AHA) writes to urge the
Centers for Medicare & Medicaid Services (CMS) to offer potential payment solutions for hospital
stays of less than two-midnights in its proposed rule for the fiscal year (FY) 2016 inpatient
prospective payment system (PPS). We also ask CMS to extend the partial enforcement delay of the
“two-midnight” policy until the later of Oct. 1, 2015 or the agency’s implementation date of a
short stay payment (SSP) policy. Currently, CMS prohibits the recovery audit contractors (RACs)
from conducting post-payment patient status reviews for claims with dates of admission from Oct. 1,
2013 through March 31, 2015. Additionally, we ask the agency to repeal the unlawful 0.2 percent
reduction to the standardized amount that was
implemented in FY 2014.

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