WHA Submits Comment Letter to CMS Opposing CAH Reimbursement Changes

July 01, 2016

On June 29, the Wisconsin Hospital Association submitted comments to the Centers for Medicare and Medicaid Services (CMS) in opposition to reducing reimbursement for Critical Access Hospitals from 101 percent to 100 percent of allowable costs. While the policy has been proposed by the Administration previously, it would require an act of Congress to be enacted. CMS solicited comments in order to determine the impact of such a policy on CAHs nationally. 

“WHA is opposed to the continued focus on reducing CAH reimbursement, especially when we see no connection to improving access or value to the Medicare program,” WHA President/CEO Eric Borgerding said in WHA’s letter. “We are not certain what outcome CMS seeks to achieve with continued proposals to reduce CAH reimbursement because data support the fact that CAHs already provide access to care across rural communities in our state and in the nation in an affordable manner.” 

“These are the two main concerns CMS should have with any changes in Medicare reimbursement policy—does it help maintain or increase access to care and does it do so in an affordable, value-based manner. WHA believes the recent CAH reimbursement reduction proposal from 101 percent to 100 percent of allowable costs fails on both accounts.”

WHA’s comment letter provided background on the creation of the CAH designation as a necessary, alternative reimbursement model and that CAHs in Wisconsin are part of the rural health care infrastructure which help the state maintain one of the top rankings for health care quality nationally. 

“Wisconsin hospitals and health systems are nationally known as innovators and deliverers of high ‘value’ care—high-quality, cost efficient care. In fact, Wisconsin was ranked the second most highly-rated state in the country based on the quality of its health care according to the federal Agency for Healthcare Research and Quality (AHRQ),” read the WHA letter. “Results like these have been confirmed by others including the Dartmouth Atlas, Kaiser Family Foundation and The Commonwealth Fund and equate to benefits for both the Medicare program and Medicare beneficiaries. Wisconsin’s Critical Access Hospitals are an integral part of Wisconsin’s accessible health care delivery system and key contributors to our continued recognition as a high-value health care state.” 

In describing the negative impacts a reduction in CAH reimbursement would have, WHA’s letter highlighted the millions of dollars in cuts statewide this would mean to CAHs and what that could mean to access to care, including potentially reducing or eliminating services such as: obstetrics, hospitalists, behavioral health, urgent care, wound care, pathology, radiology, respiratory therapy or outpatient therapeutic services and more. Cuts would also make it that much more difficult to ensure necessary technology, diagnostics and other capital improvements. 

“Wisconsin hospitals have a strong and long-standing commitment to collaboration and the pursuit of the very type of value CMS desires—high-quality, cost efficient care. This pursuit is shared by all of Wisconsin’s facilities, regardless of size. WHA and our CAHs stand at the ready to assist CMS in developing approaches that continue moving Medicare further along the health care value continuum while still recognizing the unique roles Critical Access Hospitals play throughout our state and much of the country,” WHA stated in the letter. 

Read WHA’s letter here.

This story originally appeared in the July 01, 2016 edition of WHA Newsletter