Comment Letter

HFMA Comments on the CMS Discharge Planning Proposed Rule

HFMA comments on the CMS proposed rule on Medicare and Medicaid Programs: Revisions to Requirements for Discharge Planning for Hospitals, Critical Access Hospitals, and Home Health Agencies.

By HFMA January 7, 2016

HFMA Comments on GASB’s Proposed Blending Requirements for Component Units

HFMA’s P&P Board encouraged the GASB to allow the optional single or multiple-column approach in Statement 61 for blending component units applied to all component units of business-type activities.

By HFMA October 28, 2015

HFMA Comments on the HRSA 340B Drug Pricing Program Omnibus Guidance

The 340B program stretches resources for care to indigent and at-risk populations. Without this program, these individuals would find more difficulty in finding ready access to care and medications.

By HFMA October 28, 2015

HFMA Comments on CMS’s CY16 Physician Fee Schedule Proposed Rule

HFMA comments on the 2016 Medicare Program; revisions to payment policies (including advance care planning) under the physician fee schedule for CY 2016.

By HFMA September 18, 2015

HFMA Comments on CMS’s CCJR Payment Model Proposed Rule

HFMA comments on CMS’s proposed rule for Comprehensive Care for Joint Replacement (CCJR) Payment Model for Acute Care Hospitals Furnishing Lower Extremity Joint Replacement Services.

By HFMA September 17, 2015

HFMA Comments on the FASB’s Proposal on NFP Financial Statement Presentation

HFMA comments on the FASB’s proposed Accounting Standards Update Not-for-Profit Entities (Topic 958) & Health Care Entities (Topic 954): Presentation of Financial Statements of Not-for-Profit Entities.

By HFMA August 18, 2015

HFMA Comment Letter: CMS’ FY2016 Hospital IPPS Proposed Rule

HFMA comments on the CMS analysis and discussion of the myriad Medicare hospital reimbursement decisions addressed in the 2016 IPPS Proposed Rule.

By HFMA July 1, 2015

HFMA comments on the Senate Finance Committee Chairmen’s Audit & Appeal Bill

HFMA comments on the Senate Finance Committee Chairman's Mark of the AFFRIM Act to put forth solutions to the challenges faced by hospitals and beneficiaries from overlapping recovery audit programs.  

By HFMA June 22, 2015

HFMA Comments on CMS Bundled Payments for Care Improvement (BPCI) Initiative

HFMA proactively comments on issues related to CMS’s BPCI initiative to provide recommendations to address design issues with the episodes and other operational and administrative barriers.

By HFMA May 22, 2015

HFMA Comments on Medicare Short Stay Payment Policy

HFMA comments on issues related to Medicare’s current payment policy for short stays, the Recovery Audit Contractor (RAC) program, and the impact of both on Medicare beneficiaries.

By HFMA April 20, 2015
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