The AHA supports a number of provisions in the inpatient prospective payment system proposed rule for fiscal year 2018, but has concerns about certain proposed changes related to disproportionate share hospital payments, the documentation and coding reduction, and quality programs, AHA Executive Vice President Tom Nickels told the Centers for Medicare & Medicaid Services in comments submitted today. With respect to DSH payments, AHA urged CMS to delay by one year only the use of Worksheet S-10 to calculate DSH payments, and continue to use Medicaid and Medicare Supplemental Security Income days from FY 2011-2013 to calculate uncompensated care payments in FY 2018. AHA also urged the agency to phase in the transition to Worksheet S-10 data over at least three years, and implement a stop-loss policy to help hospitals adjust to new payment levels. The association commented separately on proposed changes to the long-term care hospital PPS.

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