Messages to the Administration
In a letter to the Centers for Medicare & Medicaid Services (CMS), NAUH expresses its opposition to the proposed reduction of Medicare payments for prescription drugs covered by the federal section 340B prescription drug discount program. NAUH argues that the program is appropriately serving the purposes for which it was created and that the proposed changes would detract from the ability of urban safety-net hospitals and other safety-net providers to continue delivering many of the services the residents of their low-income communities need that are currently made possible only through savings derived from the 340B program.
In a letter to the Centers for Medicare & Medicaid Services (CMS), NAUH argues against the proposed 50 percent reduction of payments to physicians who deliver Medicare-covered services in off-campus, provider-based hospital outpatient departments. NAUH also urges CMS to reconsider the circumstances under which hospitals can move their off-campus, provider-based hospital outpatient departments, or expand the services those departments offer, without losing their provider-based hospital outpatient department status.
In a letter to the Centers for Medicare & Medicaid Services (CMS), NAUH conveys its opposition to the manner in which the agency proposes implementing the Affordable Care Act-mandated reduction of Medicaid disproportionate share (Medicaid DSH) payments to hospitals. In particular, NAUH objects to CMS’s proposed division of the cuts between so-called “low-DSH states” and “non-low-DSH states,” maintaining that non-low-DSH states would, under the CMS proposal, bear too great a share of the overall reductions of state Medicaid DSH allotments.
In a letter to the Centers for Medicare & Medicaid Services (CMS), NAUH offers extensive comments on why the Medicare cost report’s S-10 worksheet is not an appropriate tool to use when calculating hospital Medicare DSH uncompensated care payments. In support of this view, NAUH offers detailed documentation on the shortcomings of the S-10. In the letter, NAUH also comments on proposed changes in Medicare’s hospital readmission reduction program, proposed changes in hospital inpatient rates, the area wage index system, and quality reporting, and advocates the preservation of states’ ability to make supplemental payments to hospitals through Medicaid managed care providers.