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Commenting yesterday on the Medicare Payment Advisory Commission’s draft recommendations for 2021, AHA said it supports the recommendation to provide current law market-basket updates for the hospital inpatient and outpatient prospective payment systems, but urged the commission to consider a higher update in light of the “sustained and substantial” negative Medicare margins hospitals face. The association said it supports the concept of appropriately linking quality performance to payment, but has significant concerns with the design of the Hospital Value Incentive Program. AHA also urged the commission to recommend a full market-basket update for long-term care hospitals, inpatient rehabilitation facilities and hospital-based skilled nursing facilities. Among other comments, the letter highlights access challenges faced by LTCH site-neutral patients, and urges MedPAC to analyze and report on access to care and clinical outcomes for these vulnerable patients. It also responds to the commission’s prior discussion on how to design a value incentive program for post-acute care.