The Alliance of Safety-Net Hospitals has submitted written comments to the Centers for Medicare & Medicaid Services in response to that agency’s proposed rule governing Medicaid state directed payments.

In its letter, ASH notes its support for responsible guardrails for state directed payments.  At the same time, though, ASH explains that those payments have become a vital tool for states to help community safety-net hospitals fulfill their missions of service to their communities – and to the very hospitals that play the greatest role in caring for Medicaid and other low-income and uninsured patients.

The proposed rule, in ASH’s view, would weaken that vital tool at precisely the time when states and providers face historic Medicaid policy changes, rising costs, increased uncompensated care pressures, and continued instability in coverage.

With these concerns in mind, ASH urges CMS in its letter to:

  • Limit Medicare-based caps to the four service categories Congress identified: inpatient hospital services, outpatient hospital services, nursing facility services, and qualified practitioner services at an academic medical center.
  • Preserve state flexibility to implement uniform Medicaid rate increases.
  • Reconsider its proposed hospital-specific Medicare payment limit methodology.
  • Maintain grandfathered status for statutorily grandfathered payments even when they reach the Medicare cap.

Learn more from ASH’s letter to CMS about that agency’s proposed rule governing Medicaid state directed payments.