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.