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MedPAC Proposal Would Disadvantage Safety Net Providers, Patients


Statement attributable to:
Beth Feldpush, DrPH
Senior Vice President of Policy and Advocacy
America’s Essential Hospitals 

 WASHINGTON — We appreciate the Medicare Payment Advisory Commission’s desire to define safety net hospitals for targeted support, but the commission’s Medicare safety net index (MSNI) could have the perverse effect of shifting resources away from hospitals that need support the most.

The MSNI methodology fails to account for all the nation’s safety net hospitals by overlooking uncompensated care and care provided to non-Medicare, low-income patients — especially Medicaid beneficiaries. Any practical definition of a safety net provider must consider the care of Medicaid and uninsured patients, yet the MSNI misses on both counts. 

These shortcomings would shift resources away from large, teaching, and urban hospitals and those serving many uninsured patients and contradict Congress’ intent to better account for uncompensated care in Medicare disproportionate share hospital (DSH) payments. The MSNI also would hinder work to improve care equity by undermining providers that care for people at greatest risk of structural inequities and health disparities, including many low-income Medicare beneficiaries. 

We urge policymakers to develop a federal designation of safety net hospitals and to reject the MSNI as a part of that process, as it would jeopardize access to care for marginalized patients and harm hospitals that operate on low margins and rely on public payers. Further, policymaking for these hospitals should supplement, rather than redistribute, existing Medicare DSH funding, which reflects a congressionally sanctioned, well-established methodology. 

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About America’s Essential Hospitals
America’s Essential Hospitals is the leading association and champion for hospitals dedicated to equitable, high-quality care for all, including those who face social and financial barriers to care. Since 1981, America’s Essential Hospitals has advanced policies and programs that promote health, health care access, and equity. We support our more than 300 members with advocacy, policy development, research, education, and leadership development. Communities depend on essential hospitals for care across the continuum, health care workforce training, research, public health and health equity, and other services. Essential hospitals innovate and adapt to lead all of health care toward better outcomes and value. Learn more at 

Carl Graziano


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