Chapter 2 of the March 2019 Report to Congress on Medicaid and CHIP examines upper payment limit (UPL) payments, which exceed DSH payments and are a significant source of Medicaid funding for hospitals. Previous MACPAC analyses have noted the lack of data regarding these payments, observing that incomplete information on this important source of hospital financing affects policymakers’ ability to fully understand hospital spending in Medicaid.
New analyses in Chapter 2 raise additional concerns about UPL data accuracy and completeness. The analyses note large discrepancies between spending reported on state UPL demonstrations and actual spending reported on CMS expenditure reports, as well as missing hospital and payment data for many states. To improve oversight and transparency of hospital-specific UPL demonstration data, Chapter 2 contains recommendations directing the Secretary of the U.S. Department of Health and Human Services to:
- establish process controls to ensure that UPL demonstration data are accurate and complete, and that HHS uses them to review claimed expenditures, and
- make UPL data available to the public in a standard format that permits analysis.
