Every year, the Centers for Medicare & Medicare Services (CMS) publishes in the Federal Register a draft regulation describing how it proposes paying hospitals for the inpatient care they provide to their Medicare patients in the coming fiscal year. The proposed inpatient prospective payment system regulation for FY 2015 was published on May 15, and as always, CMS invited interested parties to submit written comments.
The National Association of Urban Hospitals has always found CMS to be receptive and even responsive to its comments and therefore takes the opportunity to submit detailed comments and suggestions about the agency’s annual proposal.
Beginning today and for the next six business days, NAUH will present excerpts from its comment letter to CMS. The subjects and the dates they will be published are:
Today – the size of the Medicare DSH pool
June 27 – the manner in which CMS uses CBO estimates of changes in insurance status
June 30 – the methodology for distributing Medicare DSH funds
July 1 – the need for appropriate risk adjustment in the hospital readmissions reduction program
July 2 – a much-needed adjustment to the methodology employed by the hospital readmissions reduction program
July 3 – hospital inpatient rates
July 7 – short hospital stays (two-midnight rule)
NAUH’s complete comment letter to CMS can be found here.
The Size of the Medicare DSH Pool
NAUH appreciates the work that went into CMS’s decision regarding the size of the factor 1 portion proposed Medicare DSH pool for FY 2015. The work was thoughtful and well-researched, and we thank you for this.
For future reference, and so we can understand the underlying rationale for the decisions that were made, NAUH would like to know more about the underlying calculations that led to those decisions. To begin, NAUH would like to know more about CMS’s decisions and calculations in light of the proposed rule’s assertion that
The Office of the Actuary uses the most recently submitted Medicare cost report data to identify current Medicare DSH payments, supplemental cost report data provided by IHS hospitals to CMS, and the most recent DSH payment adjustments provided in the IPPS Impact File, and applies inflation updates and assumptions for future changes in utilization and case-mix to estimate Medicare DSH payments for the upcoming fiscal year.
NAUH asks CMS to provide more information about the inflation updates and assumptions the Office of the Actuary used to estimate what Medicare DSH payments would have been absent section 1886(r) of the Affordable Care Act. Although we do not know what those assumptions were, the FY 2014 final IPPS rule stated that the Office of the Actuary accounted for additional Medicare DSH expenditures associated with Medicaid expansion. NAUH recommends that this estimate, too, should account for that impact. Specifically, NAUH recommends that the estimate of Medicare DSH payments for the upcoming fiscal year take into account increases in Medicare DSH payment percentages that can be expected among hospitals currently projected to receive DSH as well as increased DSH expenditures attributable to hospitals that are likely to become eligible for Medicare DSH as their DSH patient percentages increase. This calculation, NAUH believes, also should reflect the significant numbers of individuals whose applications for Medicaid are still pending – 1.7 million such people, according to published reports in early June. NAUH would like to know whether the calculation includes these individuals and how much Medicare DSH would otherwise have been paid had they been qualified in a more timely manner.
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Tomorrow: the manner in which CMS uses CBO estimates of changes in insurance status
NAUH’s complete comment letter to CMS can be found here.
