Messages to the Administration
In a letter to the Centers for Medicare & Medicaid Services (CMS), NAUH comments on a proposed regulation to implement Affordable Care Act-mandated cuts in future Medicaid disproportionate share hospital payments (Medicaid DSH). NAUH’s letter urges CMS to delay all Medicaid DSH cuts for one year, as proposed in the administration’s proposed FY 2014 budget, and urges CMS to consider modifying selected aspects of the methodology it has proposed for reducing future Medicaid DSH payments.
In a letter to the Centers for Medicare & Medicaid Services (CMS), NAUH comments on Medicare’s proposed FY 2014 inpatient prospective payment system regulation. NAUH’s letter addresses Medicare disproportionate share (Medicare DSH) payments, the coding adjustment for inpatient payments, the outlier threshold, the labor-related share adjustment, the value-based purchasing program, the hospital readmissions reduction program, and graduate medical education. NAUH also proposes its own, detailed formula for recalculating the size of the FY 2014 Medicare DSH pool based on the difference between the calendar year in which the Congressional Budget Office projected the rate at which the number of insured people would grow and the fiscal year for which the Medicare DSH pool needs to be calculated.
NAUH asks the Centers for Medicare & Medicaid Services (CMS) to delay implementation of the new, anticipated methodology for calculating hospitals’ Medicare disproportionate share payments (Medicare DSH) because of problems with the uncompensated care data upon which such calculations would be based. NAUH urges CMS to use the delay to audit the uncompensated care data hospitals have provided on their Medicare S-10 forms and to refine the instructions for completing the S-10 based on the audits’ findings.