The FY 2018 IPPS proposed rule was published in the Federal Register on April 28, 2017. All comments to the rule were to be submitted to CMS by Tuesday, June 13, 2017. Like in past years, Southwest Consulting Associates (SCA) performed extensive analysis of the proposed rule and submitted comments in response to CMS’ FY 2018 IPPS Notice of Proposed Rulemaking (NPRM). SCA’s comments primarily related to the proposed changes in the payment adjustment for Medicare Disproportionate Share Hospitals (DSH) including the Uncompensated Care (UC) payment component.
Highlights of SCA’s comment letter include:
Lack of transparency and values for the many components that make up the "Other" category trending factor used to compute the estimated Medicare DSH for FY 2018
Lack of detailed explanation and data to support the Medicaid expansion component of the "Other" category trending factor
Lack of correlation between the estimated DSH for years subsequent to the enactment of Medicaid expansion and the increase in additional Medicaid enrollees since pre-ACA levels
Factor 3
- Reference to extensive comments made in the past where no meaningful changes have been made to the underlying systems, processes and instructions used to compile the data for Worksheet S-10
Data anomalies still exist which inappropriately distribute UC reimbursement
Data used to distribute the UC pool (in this case, S-10) should be subject to review prior to use
- Definitional issues remain that need to be resolved, specifically the definition of uncompensated care, charity care costs and charity care criteria
- Hospitals should be afforded another opportunity to revise their FY 2014 Worksheet S-10 data
- If CMS continues forward with the use of S-10 data for FY 2018 and future years, hospitals should also be allowed the opportunity to revise FY 2015 S-10 data for the FY 2019 proposed rule Factor 3 compilation similar to Transmittal 1681
SCA’s comment letter can be viewed in its entirety HERE. Read our summary of the FY 2018 IPPS proposed rule HERE.
We expect the final rule to be issued this August and we plan to post an update in addition to a summary soon after it is released. In the meantime, we will continue to post about Medicare DSH, the uncompensated care payment and Worksheet S-10 as they relate to this proposed rule. Rumor has it, we have some recommendations we'll be writing about soon. Want to discuss the proposed rule some more? If so, we'd love to hear from you. Please leave a comment below...
