AHA recommends changes to proposed rule for Medicaid DSH audits

A proposed rule expanding the definition of "uninsured" used to calculate Medicaid Disproportionate Share Hospital payments addresses some of the American Hospital Association's concerns with how the program defines unreimbursed costs, but the Centers for Medicare & Medicaid Services should further clarify and expand the definition, apply the proposed changes retrospectively and improve its oversight of the program, the association said in comments submitted Feb. 16. Specifically, the AHA urged CMS to consider uncompensated care provided after benefits are exhausted as "uninsured" uncompensated costs. In addition, AHA said unfunded and unreimbursed costs for contract health services provided to the Indian Health Service, and unreimbursed physician costs associated with hospital services should count toward hospital-specific DSH limits.