NASH Comments on Proposed Changes in S-10 Uncompensated Care Reporting

NASH has expressed support for several new federal proposals on hospital uncompensated care data reporting and conveyed its opposition to other proposed changes in federal data collection requirements in a new letter to the Centers for Medicare & Medicaid Services.

In response to changes CMS has proposed in the uncompensated care data hospitals must submit to the federal government, NASH expressed:

  • Support for CMS’s proposal to clarify aspects of how hospitals must report data on the uncompensated care they provide on the Medicare cost report’s S-10 form.
  • Expressed concern that some of the new data reporting requirements violate current HIPAA requirements.
  • Asked CMS to defer reporting on the rates hospitals negotiate with Medicare Advantage plans until after the end of the COVID-19 public health emergency.

NASH is especially interested in proposed changes in uncompensated care data reporting on the S-10 form because that form is used in the calculation of private safety-net hospitals’ Medicare disproportionate share payments (Medicare DSH).  Those Medicare DSH payments are a vital tool in helping these hospitals serve the low-income and uninsured residents of the communities in which they are located.

Learn more about NASH’s response to CMS’s proposed new information collection activities in this NASH letter to CMS.

GAO: CMS Should Pay More Attention to States’ Financing of Medicaid

The federal government does not adequately monitor how states finance their Medicaid programs.

It also lacks a sufficiently clear understanding of how they pay providers of Medicaid-covered services.

These are among the conclusions in a new study on Medicaid financing and payments by the U.S. Government Accountability Office.

According to the GAO report,

GAO estimated that states’ reliance on provider taxes and local government funds decreased states’ share of net Medicaid payments (total state and federal payments) and effectively increased the federal share of net Medicaid payments by 5 percentage points in state fiscal year 2018.  It also resulted in smaller net payments to some providers after the taxes and local government funds they contribute to their payments are taken into account. While net payments are smaller, the federal government’s contribution does not change. This effectively shifts responsibility for a larger portion of Medicaid payments to the federal government and away from states.

To address this challenge, the GAO urged CMS to collect more complete and consistent information about both state financing of their Medicaid programs and the manner in which states pay Medicaid providers.  CMS neither agreed nor disagreed with the GAO’s recommendation.

Such a study could have implications for private safety-net hospitals located in states that have increased their dependence on provider taxes to fund their Medicaid programs in recent years.

Learn more about what the GAO found and recommended in its new report “Medicaid:  CMS Needs More Information on States’ Financing and Payment Arrangements to Improve Oversight.”

NASH Asks Congress for COVID-19 Aid

NASH has written to Congress to request additional COVID-19 legislation between now and the end of the year to help private safety-net hospitals respond to the health care and financial challenges posed by the pandemic.

In its letter, NASH asked Congress for:

  • additional funding for the Provider Relief Fund for assistance to hospitals;
  • extension of the temporary moratorium on continued implementation of the 2011 Budget Control Act’s Medicare sequestration; and
  • the suspension of any other federal cuts for health care providers, such as the scheduled reduction of Medicaid disproportionate share (Medicaid DSH) allocations to the states.

Read NASH’s message to Congress.

NASH Statement on Nomination of Xavier Becerra

Statement of the National Alliance of Safety-Net Hospitals on the Nomination of  Xavier Becerra to be Secretary of the U.S. Department of Health and Human Services

The National Alliance of Safety-Net Hospitals is extremely pleased with President-elect Biden’s nomination of Xavier Becerra to serve as his Secretary of the Department of Health and Human Services.  As Attorney General of California, Mr. Becerra has been a staunch, effective defender of the role of the Affordable Care Act in helping to reduce the number of uninsured Americans.  As a member of Congress, private safety-net hospitals worked often with Mr. Becerra and came to recognize him as a leader among his colleagues in working to preserve the country’s health care safety net, of which private safety-net hospitals are an integral part.  We look forward to the opportunity to resume our relationship with this strong advocate for health care for all Americans and to work together to ensure access to care in our country.


Schumer: Block Medicaid DSH Cuts

Congress should block scheduled Medicaid DSH cuts.

That’s the message Senate minority leader Chuck Schumer sent during a recent appearance in upstate New York.

“At a time when we need to be supporting our hospitals with robust funding to help them keep their doors open and doctors available, threatening them with substantial cuts to essential funding is fundamentally wrong,” Schumer said, speaking of cuts in Medicaid disproportionate share payments (Medicaid DSH) mandated by the Affordable Care Act, delayed many times by Congress, but now scheduled to take effect when the current continuing resolution funding the federal government expires on December 11.

The Medicaid DSH program was created to help hospitals that care for especially large numbers of low-income and uninsured patients – like America’s private safety-net hospitals.  The National Alliance of Safety-Net Hospitals has long called for delaying Medicaid DSH cuts and most recently urged Congress to eliminate the Medicaid DSH cut entirely, writing in a letter to members of Congress that

Private safety-net hospitals and others like them, serving communities with large numbers of low-income and uninsured residents, have never needed the resources afforded by Medicaid DSH more than they do today.  Congress has long questioned the wisdom of this cut and has never permitted it to take effect. The most recent delay expires December 11, and NASH urges you to repeal permanently the Medicaid DSH cut in any spending or COVID-19 legislation you pass this year.

To learn more about Senator Schumer’s perspective on Medicaid DSH, see the Troy Record article “Schumer calls for reversal of devastating hospital cuts.”


Number of Uninsured Children Rising

The number of uninsured children in the U.S. is rising.

Since 2016, the number of uninsured children has risen by approximately 726,000 as the uninsured rate among children rose from 4.7 percent to 5.7 percent in 2019.

An increase of 320,000 children between 2018 and 2019 was the largest such increase in more than a decade.  Texas accounts for one-third of the four-year increase, or about 243,000 newly uninsured children, with Florida second with 55,000 newly uninsured children.

Any increase in the number of uninsured children poses a special challenge for private safety-net hospitals because those hospitals are generally located in communities with larger numbers of low-income and uninsured residents than areas served by the typical community hospital.

Learn more about the increase in the number of uninsured children in recent years and why it occurred in the report “Children’s Uninsured Rate Rises by Largest Annual Jump in More Than a Decade” from the Georgetown University Health Policy Institute’s Center for Children and Families.

NASH Asks Congress to Help Preserve Federal COVID-19 Aid for Hospitals

Protect the COVID-19 aid the federal government has given to private safety-net hospitals, NASH has asked in a letter to Congress.

The letter refers to changes in how the Department of Health and Human Services wants hospitals to calculate the revenue they lost as a result of COVID-19 – the justification in part for the Provider Relief Fund payments hospitals have received through the CARES Act.  In June, HHS told hospitals how to make that calculation but late last month it changed those directions in ways that could force many private safety-net hospitals and others to return some or even much of the federal aid they received.

In the letter, NASH asks members of Congress to sign a bipartisan letter asking HHS Secretary Alex Azar to restore the June instructions for calculating COVID-19-related lost hospital revenue.

Go here to read NASH’s message to Congress.


MedPAC Meets

Last week the Medicare Payment Advisory Commission met in Washington, D.C. to discuss a number of Medicare payment issues.

Among the issues on MedPAC’s October agenda were:

  • Medicare Advantage benchmark policy
  • indirect medical education:  current Medicare policy, concerns, and principles for revising
  • the evolution of Medicare’s advanced alternative payment models
  • vertical integration and Medicare payment policy

MedPAC is an independent congressional agency that advises Congress on issues involving the Medicare program.  While its recommendations are not binding on either Congress or the administration, MedPAC is highly influential in governing circles and its recommendations often find their way into legislation, regulations, and new public policy.  Because so many patients of private safety-net hospitals are insured by Medicare, MedPAC’s deliberations are especially important to those hospitals.

Go here for links to the policy briefs and presentations that supported MedPAC’s discussion of these issues and here for a transcript of the proceedings.

Congress Gives Hospitals Medicaid DSH Relief

Medicaid DSH allocations to states will not be reduced right away thanks to a new continuing resolution to fund the federal government through December 11.

The Medicare disproportionate share allocation cuts to the states, mandated by the Affordable Care Act but delayed by Congress several times, were delayed again earlier this year but scheduled to take effect on November 11.  With the latest continuing resolution, the cuts will be delayed yet another month.

Learn more about the delay of Medicaid DSH cuts and other aspects of the continuing resolution that affect hospitals in the Healthcare Dive article “Providers win Medicare loan extension, DSH relief but lose other asks in stop-gap spending law.”

Payer Mix to Change, Providers Anticipate

Health care providers expect to serve higher proportions of Medicaid and uninsured patients in the coming year, according to a new survey.

The shift will be driven by the COVID-19 pandemic, which as unemployment remains high is leading to fewer patients with commercial insurance and more with Medicaid or no insurance all, according to provider financial executives.

Such a shift would be especially challenging for private safety-net hospitals because they already serve higher proportions of Medicaid and uninsured patients than the typical community hospital.

Learn more about the reimbursement changes health care providers expect to see over the next twelve months in the Healthcare Dive article “Provider finance execs bracing for unfavorable shift in payer mix, survey finds.”