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America’s Essential Hospitals Comments on Medicaid DSH Proposed Rule

America’s Essential Hospitals submitted comments July 12 to the Centers for Medicare & Medicaid Services (CMS) on the proposed rule implementing the Affordable Care Act’s (ACA’s) Medicaid disproportionate share hospital (DSH) cuts. In the proposed rule, CMS provides detail on the DSH health reform methodology the agency will use to determine the amount of reduction to each state’s DSH allotment for fiscal years 2014 and 2015.

America’s Essential Hospitals has been vocal in opposing the cuts and continued to stress that opposition in its comments. In the letter, the association notes that with the U.S. Supreme Court decision rendering the ACA’s Medicaid expansion optional for states, the level of DSH cuts no longer reflects the need for DSH payments. Hospitals, especially members of America’s Essential Hospitals, will likely see continued high levels of uncompensated care. The association urges CMS to finalize a methodology that incentivizes states to target their DSH dollars to hospitals with high levels of uncompensated care and Medicaid patients, and adopt an approach that allows for reevaluation as the impact of health reform is better understood. Contact Xiaoyi Huang, assistant vice president for policy, at or 202-585-0127, with any questions about the comment letter or CMS’ proposed methodology.


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