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AHA opposes the Centers for Medicare & Medicaid Services’ proposal to limit patient days when calculating Medicare Disproportionate Share Hospital payments for patients eligible for Medicaid benefits under a Section 1115 demonstration project, which it said could devastate access to care for lower-income populations by curtailing resources used to finance health care in historically marginalized communities.

“This proposed rule is the agency’s third attempt in as many years to exclude the counting of days of patients associated with uncompensated care pools from the Medicaid fraction of the Medicare DSH patient percentage,” AHA said in comments submitted to the agency May 1. “In addition, the agency proposes to limit the counting of patient days to only those patients who purchase health insurance that includes inpatient services through an authorized Medicaid 1115 demonstration premium assistance program where 100% of the cost of the premium is covered. CMS bases both of these proposed changes on its interpretation of the Medicare statute as it relates to what types of 1115 demonstration project patient days count, for purposes of the Medicaid fraction. However, the agency’s interpretation is contrary to unambiguous statutory language.”