Difference between Proposed and Final Rule Files

Purpose

A number of CMS Limited Data Set (LDS) files are released first as a Proposed Rule file and then as a Final Rule file. This article provides a brief description of the differences between those two files.

Current Version Date:
06/29/2018
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A number of CMS Limited Data Set (LDS) files are released first as a Proposed Rule file and then as a Final Rule file. They include:

  • MedPAR - Hospital (National),
  • MedPAR - Long-Term Care Hospital,
  • Hospital Outpatient Prospective Payment System (OPPS),
  • Hospital Outpatient Prospective Payment System (OPPS) – Partial Hospitalization Program, 
  • End Stage Renal Disease Prospective Payment System (ESRD PPS), and
  • Ambulatory Surgical Center (ASC) Payment System.

The release of these files coincides with the publication of Proposed and Final Rules published in the Federal Register. The Proposed Rule files are available so analysis can be done and comments can be made about proposed changes to the payment system.

Both the Proposed Rule and Final Rule versions of the files contain the same data elements and reflect the same dates of service. However, the final rule includes an additional 3 months of claim run off. In general, there will be roughly 2-3% more claims appearing in the Final Rule than in the Proposed Rule.

Information about the latest years available of the files can be found in the CMS LDS Worksheet found on the Limited Data Set (LDS) Files webpage.

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Article Information

Author:
Faith Asper, MHS, CIPP/G
Acknowledgements:
ResDAC would like to acknowledge Erin Mann for assistance with this article.
Level:
Introduction
Topic:
Data Files or Variables
Program:
Medicare
Category:
Medicare Fee-For-Service Claims
Disclaimer:
The process and materials mentioned as part of this KnowledgeBase article are current, as of the publication date on the article, to the best of our knowledge. The examples provided are correct in the aggregate but may not apply to every subgroup or circumstance that a researcher may wish to study. It is up to the researcher to conduct analysis and confirm that the patterns described in this KnowledgeBase article apply to his/her particular study. If your research findings appear to contradict the advice provided, please contact ResDAC at resdac@umn.edu.