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The AHA today submitted comments on the Centers for Medicare & Medicaid Services’ fiscal year 2020 proposed rule for the long-term care hospital prospective payment system. For cost-reporting periods beginning on or after Oct. 1, 2019, CMS proposes applying a payment penalty when 50% or fewer of an LTCH’s discharges are paid the standard rate, with the penalty applied in a subsequent cost-reporting period. AHA offers recommendations to streamline and simplify the processes for assessing 50% Rule compliance and reinstating facilities that fall out of compliance. In addition, the association continues to ask CMS to address in the final rule the “chronic and substantial” underpayment of site-neutral cases and its impact on patients, and to eliminate the second budget neutrality adjustment exacerbating the underpayment. AHA also continues to encourage CMS to adopt only quality measures endorsed by the National Quality Forum. In addition, the association urged the agency to adopt only highly reliable and useful standardized patient assessment data, and to be transparent about the collection of social determinants of health data and how it will be used in CMS programs. AHA will submit separate comments on the rule’s inpatient proposals.