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The FAH requests that, in recognition of this unique and extraordinary situation, CMS apply an adjustment of +4.3 percentage points to the IPPS update taking into account the combined forecast error previously not adjusted for the years FY 2021 through FY 2023. [...] CMS proposed to continue to delay application of the NonCC subgroup criteria to existing MS-DRGs with a three-way severity split for FY 2025. [...] The FAH believes that the application of the Non-CC sub-criteria for the new and existing MS-DRGs further demonstrates that the methodology needs to be reassessed as this resulted in the elimination of two-way splits for with and without MCC/CC. [...] CMSAPPENDIX A FAH Detailed Comments on FY 2025 IPPS/LTCH PPS Proposed Rule (CMS-1808-P) 15 encourages the public to continue to submit comments on any factors that CMS should consider in its efforts to recognize and differentiate consumption of resources for ICD-10 MS-DRGs for consideration. [...] The FAH also continues to believe that thorough data analysis conducted with provider stakeholders is critical to allow for appropriate insight in providing comments. As stated in response to the FY 2020 proposed rule on this topic, the FAH recommended that CMS consider a technical expert panel (TEP) made up of industry stakeholders and experts to review methodologies for O.R. determination. [...] APPENDIX A FAH Detailed Comments on FY 2025 IPPS/LTCH PPS Proposed Rule (CMS-1808-P) 17 The FAH supports the CC designation for inadequate housing and instability codes and agrees that the impact to level of care of the diagnosis would be in line with CC designation. [...] Under section 1886(d)(5)(K) of the Social Security Act, CMS is required to “establish a mechanism to recognize the costs of new medical services and technologies” in a manner that provides for “additional payment . . . [...] The update is subject to the productivity adjustment and further adjustments for hospitals that fail to submit quality information and/or are not meaningful EHR users.2 CMS is proposing to use a hospital market basket of 3.0 percent to update inpatient hospital rates for FY 2025. [...] The FAH strongly urges CMS to use later data on the market basket increase for FY 2025 as it has in past years and to further adjust its estimate to account for forecast error in the FY 2021 through FY 2023 hospital market basket update which understated the actual rate of inflation by a combined 4.3 percentage points. In each of these years, the reports/medicareprogramratesstats/marketbask [...] The FAH urges CMS to clarify whether the policy being proposed with respect to a numerical standard of 90 percent constituting an “overwhelming majority” of residents is intended to be a regulatory change in policy (and, if so, how and when that change isAPPENDIX A FAH Detailed Comments on FY 2025 IPPS/LTCH PPS Proposed Rule (CMS-1808-P) 47 intended to be applied) or a discussion item whe