In response to a request from the House Ways and Means Committee’s Health Subcommittee for suggestions from stakeholders on ways to improve the delivery of Medicare services and eliminate statutory and regulatory obstacles to more effective care delivery, NAUH has asked the committee to require the Centers for Medicare & Medicaid Services to continue using the low-income days proxy for 2013 in the calculation of Medicare disproportionate share payments (Medicare DSH) and not use S-10 uncompensated care data in that calculation until the S-10 form’s instructions have been improved and until the quality of the data hospitals report on an improved S-10 can be verified through audits.

After years of considering such an approach, Medicare adopted the use of the S-10 in the calculation of Medicare DSH payments in its final FY 2017 inpatient prospective payment system regulation, which was published earlier this month.

NAUH has long opposed the use of S-10 data for this purpose, maintaining that it is inaccurate, lacks uniformity, is subject to manipulation, and is not verified through auditing.  All private safety-net hospitals qualify for Medicare DSH payments and those payments help ensure access to care for the many low-income residents of the communities these hospitals serve.

See NAUH’s message to the House Ways and Means Committee here.