Tag Archives: Disproportionate Share Hospital (DSH) Payments

CMS Clarifies Medicaid DSH Rules for Treatment of Third Party Payments in Calculating Uncompensated Care Costs

CMS has published a final rule intended to codify its existing interpretation of how third-party payments are considered in the calculation of Medicaid uncompensated care costs for the purpose of making Medicaid disproportionate share hospital (DSH) payments. Under the final rule, CMS specifies that uncompensated care costs for purposes of calculating hospital-specific DSH limits are … Continue Reading

Medicaid DSH Allotments Announced

CMS recently finalized the federal share disproportionate share hospital (DSH) allotments for federal fiscal year (FY) 2014 and announced preliminary federal share DSH allotments for FY 2016.  CMS also announced the corresponding limitations on aggregate state DSH payments to institutions for mental disease and other mental health facilities.… Continue Reading

CMS Proposes Clarification of Treatment of Third Party Payments in Calculating Uncompensated Care Costs under Medicaid DSH Payments Rules

CMS has proposed regulatory changes to specify that the hospital-specific limitation on Medicaid disproportionate share hospital (DSH) payments is based on uncompensated care costs net of third-party payments received. Under the proposed rule – which is intended to align with CMS’s existing interpretation – a hospital’s uncompensated care costs would not include care provided to … Continue Reading

Extensive Medicare & Medicaid Funding and Program Integrity Provisions in Obama’s Released FY 2017 Budget Proposal

On February 9, 2016, the Obama Administration released its proposed fiscal year (FY) 2017 budget, which contains significant Medicare and Medicaid reimbursement and program integrity legislative proposals – including $419 billion in Medicare savings over 10 years. These proposed policy changes would require action by Congress, and Republican Congressional leaders have already voiced general opposition … Continue Reading

CMS Issues Final FY 2016 Medicare IPPS/LTCH Rule

On July 31, 2015, the Centers for Medicare & Medicaid Services (CMS) released a major final rule to update the Medicare acute hospital inpatient prospective payment system (IPPS) and the long-term care hospital prospective payment system (LTCH PPS) for fiscal year (FY) 2016. The official version of the rule will be published in the Federal … Continue Reading

GAO Report Examines Hospital Financial Incentives to Prescribe 340B Drugs to Medicare Beneficiaries

The Government Accountability Office (GAO) has issued a report examining financial and other characteristics of hospitals that participate in the 340B Drug Pricing Program, focusing on disproportionate share hospitals (DSH) that account for the majority of 340B Program discount drug purchases.  Based on a review of Health Resources and Services Administration (HRSA) data for 2008 … Continue Reading

CMS Issues Proposed Rule to Update FY 2016 IPPS, LTCH PPS Rates, Policies

On April 30, 2015, the Centers for Medicare & Medicaid Services (CMS) is publishing its proposed rule to update the Medicare acute hospital inpatient prospective payment system (IPPS) and long-term care hospital (LTCH) prospective payment system (PPS) for fiscal year (FY) 2016.  CMS will accept comments on the proposed rule until June 16, 2015. The … Continue Reading

President Obama Signs MACRA: Permanently Reforms Medicare Physician Reimbursement Framework, Includes Other Health Policy Provisions

Today President Obama signed into law H.R. 2, the "Medicare Access and CHIP Reauthorization Act of 2015" (MACRA), which reforms Medicare payment policy for physician services and adopts a series of policy changes affecting a wide range of providers and suppliers. Most notably, MACRA permanently repeals the statutory Sustainable Growth Rate (SGR) formula, achieving a goal that has eluded Congress for years. Now, after a period of stable payment updates, MACRA will link physician payment updates to quality, value measurements, and participation in alternative payment models.… Continue Reading

Obama Administration Releases FY 2016 Budget Proposal with Medicare/Medicaid Provisions

On February 2, 2015, the Obama Administration released its proposed federal budget for fiscal year (FY) 2016. The budget would impact all types of health care providers, health plans, and drug manufacturers if adopted as proposed – which is unlikely given Republican control of the House and Senate. Nevertheless, Congress can be expected to consider … Continue Reading

CMS Adopts Changes to Medicaid DSH Rules

On December 3, 2014, CMS published a final rule that defines “uninsured” for purposes of calculating the Medicaid hospital-specific disproportionate share hospital (DSH) payment limit. Under the Social Security Act, DSH payments to a hospital cannot exceed the uncompensated costs of furnishing hospital services by the hospital to individuals who are Medicaid-eligible or “have no … Continue Reading

CMS Offers Guidance to Hospitals and States Ahead of DSH Compliance Audits

CMS has released guidance in preparation for State Plan Rate Year 2011 (SPRY) Medicaid disproportionate share hospital (DSH) audits and reports due at the end of 2014. By way of background, on December 19, 2008, CMS published a final rule implementing federal DSH reporting and auditing requirements. CMS provided a transition period to allow adequate time … Continue Reading

President Signs Medicare Physician Fee Schedule/SGR Patch with Numerous Health Policy Provisions

On April 1, 2014, President Obama signed into law H.R. 4302, the "Protecting Access to Medicare Act of 2014" ("the Act"). The Act includes a one-year Medicare physician fee schedule fix that averts a nearly 24 percent payment cut set for April 1, 2014, but which falls far short of earlier hopes for full repeal of the current sustainable growth rate (SGR) formula. The Act also includes numerous other Medicare payment and policy changes, including skilled nursing facility value-based purchasing provisions, reforms to the physician fee schedule relative valuation process, a new framework for clinical laboratory payments, a variety of changes impacting imaging services, changes in the exceptions for long term care hospitals, and extension of certain expiring provisions. In other areas, the bill includes a one-year delay in the transition to ICD-10, changes to the timetable for Medicaid disproportionate share hospital cuts, and "front-loading" of the 2024 Medicare sequestration reduction.… Continue Reading

Obama Administration Proposes FY 2015 Budget with Medicare, Medicaid Savings Provisions

On March 4, 2014, the Obama Administration released its proposed federal budget for fiscal year (FY) 2015. Virtually all types of health care providers, health plans, and drug manufacturers would be impacted by the budget provisions if adopted as proposed – an unlikely scenario given the Republican House leadership’s reaction to the document. Nevertheless, the … Continue Reading

Preliminary FY 2014 DSH Allotments Announced

CMS has published a notice announcing the preliminary federal share disproportionate share hospital (DSH) allotments for fiscal year (FY) 2014, along with the preliminary federal share FY 2014 limits on aggregate DSH payments that states may make to institutions for mental diseases (IMD) and other mental health facilities. The CMS notice also includes additional information regarding … Continue Reading

President Signs 2-Year Funding Bill with Medicare SGR Patch, Sequestration Extension for Medicare Providers

On December 26, 2013, President Obama signed into law H.J. Res. 59, the Bipartisan Budget Act of 2013, which includes the Pathway for SGR Reform Act of 2013 ("the Act"). In addition to establishing federal budget targets for fiscal years (FYs) 2014 and 2015, the Act includes a number of provisions impacting the Medicare and Medicaid programs. Most notably, the Act provides a short-term reprieve from a looming Medicare physician fee schedule cut while lawmakers work to finalize a longer-term solution. It also extends Medicare provider payment cuts under existing sequestration authority for two years and makes a variety of other policy changes. The Act's major Medicare and Medicaid provisions are summarized in our full post.… Continue Reading

CMS Final Rule Refines FY 2014 DSH Payment Calculations

On October 3, 2013, CMS published an interim final rule with comment period revising disproportionate share hospital (DSH) payment calculations. By way of background, in the FY 2014 inpatient prospective payment system (IPPS) and long-term care hospital (LTCH) prospective payment (PPS) final rule, CMS established a methodology for determining the amount of uncompensated care payments … Continue Reading

CMS Releases ACA Medicaid DSH Funding Final Rule

CMS has put on display a final rule that implements reductions to state Medicaid Disproportionate Share Hospital (DSH) allotments mandated by the ACA. The final rule sets forth the methodology to implement the annual reductions for fiscal years (FYs) 2014 and 2015, and it establishes additional DSH reporting requirements for use in implementing the DSH … Continue Reading

Medicaid Disproportionate Share Hospital Allotments

On July 26, 2013, CMS published a notice announcing the final federal share disproportionate share hospital (DSH) allotments for federal fiscal year (FY) 2012 and the preliminary federal share DSH allotments for FY 2013. CMS also announces the final FY 2012 and the preliminary FY 2013 limits on aggregate DSH payments that states may make … Continue Reading

State DSH Allotments Methodology

CMS has published a proposed rule setting forth a methodology to implement aggregate reductions to state Medicaid Disproportionate Share Hospital (DSH) allotments for FY 2014 and 2015, as required by the ACA. The rule also proposes to add additional DSH reporting requirements for use in implementing the DSH health reform methodology. Comments on the proposed … Continue Reading

CMS Proposes Medicare IPPS and LTCH PPS Rates/Policies for FY 2014

On May 10, 2013, the Centers for Medicare & Medicaid Services (CMS) published its proposed rule updating Medicare inpatient prospective payment system (IPPS) and long-term acute care hospital prospective payment system (LTCH PPS) rates and policies for fiscal year (FY) 2014, which begins October 1, 2013. Comments on the proposed rule will be accepted until … Continue Reading

Obama Administration’s Proposed FY 2014 Budget Includes $401 Billion in Health Program Savings

Today, the Obama Administration released its proposed federal budget for fiscal year 2014. As widely reported, the budget incorporates an offer the President made to Congress in December 2012 to achieve nearly $1.8 trillion in additional deficit reduction over the next 10 years, including $401 billion in health savings (the Administration observes that this level of … Continue Reading

Fiscal Cliff Deal Includes Medicare Cuts and Other Health Policy Changes

On January 2, 2013, President Obama signed into law (via autopen) the "fiscal cliff" deal, H.R. 8, the American Taxpayer Relief Act of 2012 (ATRA). In addition to making well-publicized changes to the tax code, the new law includes numerous Medicare payment provisions. Most notably, the law includes a one-year Medicare physician fee schedule (MPFS) fix that is paid for by approximately $30 billion in other health care (mainly Medicare) spending reductions over 10 years. ATRA also delays until March 2013 the automatic, across-the-board "sequestration" cuts in federal spending imposed by the Budget Control Act of 2011, which are expected to reduce Medicare provider payments by more than $11 billion in fiscal year (FY) 2013 and $123 billion over the period of FY 2013 to 2021. The delay in sequestration, coupled with the government again reaching its debt ceiling, sets up another near-term battle on federal spending, during which Medicare, Medicaid, and other health care programs could be targeted for even more significant cuts. The health provisions of ATRA are summarized in our client alert.… Continue Reading
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