Messages to the Administration
In a letter to the Centers for Medicare & Medicaid Services, NAUH comments on the agency’s proposal to establish individual states’ baselines for the ten-year phase-down of supplemental payments to hospitals made through Medicaid managed care organizations. In the letter, NAUH objected to the arbitrariness of the deadline CMS proposes establishing for setting the baseline, the agency’s decision to set that deadline a full year before the ten-year phase-down is scheduled to begin, and the problem this previously unannounced deadline now poses for a handful of states that coincidentally did not submit their proposed Medicaid pass-through payment rates to CMS for review prior to the new July 5, 2016 deadline.
In a letter to the Centers for Medicare & Medicaid Services (CMS), NAUH comments on the agency’s proposal to change how it calculates eligible hospitals’ Medicaid DSH payments. In particular, NAUH objects to the manner in which CMS proposes changing how it treats payments from Medicare and third-party payers for Medicaid patients when calculating eligible hospitals’ Medicaid DSH payments. In its letter, NAUH notes that the proposed methodology contradicts congressional intent and is especially harmful to private urban safety-net hospitals.
In a letter to the Centers for Medicare & Medicaid Services (CMS), NAUH comments on the agency’s proposal to implement site-neutral payment policies for Medicare-covered outpatient services. NAUH’s letter raises objections to how the proposed rule addresses the relocation of existing hospital-based outpatient departments; how it addresses the expansion of services at existing departments; how it proposes addressing the sale of existing departments; and how it could affect such departments’ future eligibility in the section 340B prescription drug discount program.
In a letter to the Centers for Medicare & Medicaid Services (CMS), NAUH comments on Medicare’s proposal for how it envisions paying hospitals for inpatient services in FY 2017. While addressing a number of aspects of that proposal, NAUH’s letter focuses on proposed changes in how Medicare disproportionate share (Medicare DSH) uncompensated care payments would be calculated, noting the unreliable data CMS proposes using for that calculation and suggesting an alternative methodology for making these calculations.
At their December meeting, members of the Medicare Payment Advisory Commission discussed the possibility of recommending to the Centers for Medicare & Medicaid Services that it calculate eligible hospitals’ Medicare DSH uncompensated care payments using the S-10 form from hospitals’ Medicare cost report, which ostensibly quantifies the uncompensated care hospitals provide. NAUH has long opposed such an approach and wrote to MedPAC detailing the basis for this opposition.