NASH has submitted formal comments to the Centers for Medicare & Medicaid Services in response to CMS’s proposed FY 2021 Medicare inpatient prospective payment system regulation.
In its letter, NASH addressed six specific aspects of the proposed rule:
- Medicare disproportionate share (Medicare DSH) proposals
- The Medicare area wage index
- Negotiated rate reporting
- Medicare bad debt policy
- Medicare graduate medical education policy
- CAR-T cell therapy payments
Of particular note, NASH maintained that instead of decreasing the size of the pool of money for Medicare DSH uncompensated care payments, CMS should actually increase that pool in anticipation of increased hospital inpatient volume in FY 2021 – and increased hospital uncompensated care – as people return to hospitals for non-emergency procedures delayed by the COVID-19 emergency.
NASH also conveyed its opposition to the methodology CMS proposes using to calculate Medicare DSH uncompensated care payments, suggesting an alternative approach that makes better use of more current, more accurate data in that calculation.
Medicare DSH and Medicare DSH uncompensated care payments are especially important to private safety-net hospitals because those hospitals care for so many low-income, low-income elderly, and uninsured patients.
Read NASH’s comment letter to CMS here.