In this letter to U.S. Department of Health and Human Services Secretary Tom Price, MACPAC comments on the Centers for Medicare & Medicaid Services (CMS) July 28, 2017 proposed rule on disproportionate share hospital (DSH) allotment reductions. The proposed rule updates CMS’s methodology for applying pending DSH allotment reductions, which are currently scheduled to begin in fiscal year (FY) 2018.
MACPAC supports the effort by CMS to provide more clarity about how pending DSH allotment reductions will be applied. The Commission provides comments on several aspects of the proposed rule, including comments on approaches to limit the total amount of allotment reductions that states would receive and ways to improve the calculation of specific factors of the reduction methodology.