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CHA has submitted comments on the Medicare disproportionate-share hospital (DSH) provisions in Section 3133 of the Affordable Care Act (ACA) to the Centers for Medicare & Medicaid Services (CMS). The comments were provided in response to the agency’s request for input following a Jan. 8 National Provider Call on the same topic. In its comment letter, CHA recommends CMS consider, for formal rulemaking, adopting a definition of “uninsured” that includes undocumented individuals; adopting a definition of “uncompensated care” that includes the unreimbursed costs of Medicaid, the Children’s Health Insurance Program and other state and local government indigent care programs; and including graduate medical education costs in calculating cost-to-charge ratios. In addition, CHA urges greater clarity regarding definitions for lines 17 and 18 of Worksheet S-10, and requests excluding revenue streams created in California’s most recent Section 1115 waiver from uncompensated care calculations. For more information, see attached comments. CHA expects CMS to propose policies for implementing both the Medicare and Medicaid DSH provisions in the fiscal year 2014 inpatient prospective payment system proposed rule to be released in April. CHA will convene members to discuss these important provisions during the comment period.
