AHA to CMS: Protect DSH payments, make future bundled payment models voluntary

The American Hospital Association urged CMS to shield Medicaid Disproportionate Share Hospital payments and refrain from making bundled payment programs mandatory.

Here are four things to know.

1. CMS released a final rule March 30 addressing how third-party payments are treated when calculating hospitals' Medicaid DSH payments. Under the final rule, uncompensated care costs — which are used to establish a hospital-specific federal limit on DSH payments — include only those costs for Medicaid-eligible individuals that remain after accounting for payments made to hospitals by or on behalf of Medicaid-eligible individuals, including Medicare and other third-party payments.

2. In its June 13 letter to CMS Administrator Seema Verma, AHA urged the agency to withdraw the final rule, stating the change could significantly limit or eliminate some hospitals' access to DSH funds. AHA added if CMS moves forward with the rule, "any change in policy with regard to the calculation of the hospital-specific DSH limitation only should apply prospectively, which will give states and hospitals sufficient time to make needed adjustments to ensure compliance."

3. AHA also asked CMS to make future cardiac care bundled payment initiatives and Comprehensive Care for Joint Replacement expansions voluntary. AHA said mandating the bundled payment models represent "regulatory overreach" and hospitals "should not be forced to bear the expense of participation in these complicated programs if they do not believe they will benefit patients."

4. CMS issued a final rule May 18 delaying the start of the cardiac rehabilitation payment model and mandatory bundled payment programs for heart attacks and bypass surgeries and the expansion date of the CJR model from Oct. 1, 2017, until Jan. 1, 2018. 

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