Messages to the Administration
In a letter to the Centers for Medicare & Medicaid Services, NAUH conveys its opposition to aspects of CMS’s proposed Medicare outpatient prospective payment system regulation for 2019. NAUH opposes the plan to reduce outpatient payments to exempted off-campus provider-based departments to site-neutral rates; to reverse the regulation that would have permitted hospital-based outpatient facilities to be paid outpatient fee system rates rather than physician fee schedule rates for new services provided within clinical families of services; and to reduce payments for 340B-covered prescription drugs when provided by off-campus provider-based physician practices.
In a letter to the Centers for Medicare & Medicaid Services, NAUH offers extensive comments on why the Medicare cost report’s S-10 worksheet is not yet an appropriate tool to use when calculating Medicare DSH uncompensated care payments. NAUH also offers an alternative methodology for calculating hospitals’ FY 2019 Medicare DSH payments. In the letter, NAUH also comments on the hospital readmissions reduction program and proposed changes in quality reporting, the submission of documentation to support Medicare cost reports, and the manner in which Medicare treats multi-campus hospitals. Finally, NAUH offers its views in response to CMS’s request for comments about the Medicare area wage index system.