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Association Comments on New Supplemental Payment Reporting System

America’s Essential Hospitals on Aug. 19 sent a letter to the Centers for Medicare & Medicaid Services (CMS) with recommendations for implementing the new Medicaid supplemental payment reporting system outlined in the Consolidated Appropriations Act of 2020 (CAA). Section 202 of the CAA requires the agency to develop a data reporting system no later than Oct. 1, 2021.

Supplemental payments are critical for essential hospitals in the absence of adequate Medicaid base rates and states use them to target funds to essential hospitals and similar providers to fulfill certain policy goals. It is important this reporting system be accurate while avoid duplicating data collection.

The association made several recommendations for implementing Section 202, including:

  • states and providers should be involved in the development of this reporting system;
  • CMS should clarify that the scope of the reporting is limited to fee-for-service, non–disproportionate share hospital payments;
  • how to interpret the definitions of base payment and supplemental payment;
  • that reporting should be a part of the state plan amendment submission process;
  • the agency should clarify this system will use state data, not provider data; and
  • reporting should preserve state flexibility and avoid duplication of effort.

In June, the association and 11 other stakeholder groups sent a letter to CMS asking for stakeholder engagement in the development of this system.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Julie Kozminski is a senior policy analyst at America's Essential Hospitals.

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