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CHA Comments on Proposed Changes to Hospital and Health Care Complex Cost Report

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CHA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed changes to the Hospital and Health Care Complex Cost Report.  

In the letter, CHA raised concerns that many of the proposed changes will unnecessarily increase administrative inefficiencies while creating additional ambiguity related to how certain data elements should be submitted to CMS as part of a cost report filing. CHA believes CMS greatly underestimates the additional inefficiencies added by the expanded S-10, new data fields added to schedules and new schedules that support the disproportionate share hospital calculation and uncompensated care reported on worksheet S-10, and worksheet D-6 to compute cellular therapy acquisition costs. 

CHA provided recommended changes to the proposed worksheets to recognize hospitals’ limited resources in taking on additional reporting requirements.