At their December meeting, members of the Medicare Payment Advisory Commission discussed the possibility of recommending to the Centers for Medicare & Medicaid Services that Medicare calculate a portion of eligible hospitals’ Medicare disproportionate share hospital payments (Medicare DSH) using the Medicare cost report’s S-10 form. That form seeks to capture how much uncompensated care hospitals provide.

NAUH has long opposed the use of the S-10 to calculate the uncompensated care portion of Medicare DSH payments and wrote to MedPAC asking the commissioners not to make such a recommendation to CMS. In making this argument, NAUH cited the lack of consensus on what constitutes uncompensated care; the S-10’s imprecise instructions, which are invariably interpreted by different hospitals in different ways; and the questionable uncompensated care data that has been submitted to CMS in recent years. NAUH has written to CMS about this on numerous occasions in recent years.

NAUH also urged MedPAC to reject another proposal the commissioners discussed at their December meeting: to reduce Medicare 340B prescription drug discount program payments to qualified hospitals.