Association Comments on CMS Domestic Procurement Proposals

America's Essential Hospitals has commented on the Centers for Medicare & Medicaid Services' (CMS') advance notice of proposed rulemaking on fostering a more resilient supply chain for American-made personal protective equipment and essential medicines.

CMS sought input on adopting a new structural quality measure to the Hospital Inpatient Quality Reporting Program to promote investments in domestic procurement. CMS is also considering a possible new "Secure American Medical Supplies" designation that hospitals could earn by demonstrating their commitment to domestic procurement. This designation could facilitate Medicare payment adjustments to account for the higher cost of sourcing domestic supplies.

America's Essential Hospitals urged CMS to consider ways to measure supply sourcing that would minimize provider burden while improving data accuracy, such as requiring reporting by suppliers instead of providers. Additionally, the association noted that payments to hospitals meeting the "Secure American Medical Supplies" designation can only be effective if they do not subtract from other Medicare payments that hospitals receive. Finally, the association recommended targeting payments through an essential health system designation to support emergency preparedness and strengthen domestic supply chains.

Contact Director of Policy Rob Nelb, MPH, at [email protected] or 202.585.0127 with questions.