News: AHA calls for steady CMS uninsured rates for DSHs

The American Hospital Association (AHA) recently submitted commentary on CMS’ fiscal year 2025 Inpatient Prospective Payment System (IPPS) proposed rule, urging it to maintain an uninsured rate of 8.7%, according to an AHA press release.

The AHA, in submitting its comment, is primarily concerned with the state of disproportionate share hospitals (DSH). According to the AHA, in years past, uninsured rates between the IPPS’ initial proposed rule and the resulting final rule have fluctuated, leaving DSHs with financial “uncertainty and instability.”

“[I]n the agency’s upcoming fiscal year (FY) 2025 IPPS final rule,” the AHA wrote, “we urge CMS to maintain the uninsured rate at its proposed level of 8.7%. Doing so would provide critical stability for DSH hospitals that serve low-income, uninsured and historically marginalized populations.”

The CMS and the Office of the Actuary (OACT) are jointly responsible for setting the uninsured rates for the final rule via population health modeling and projections gathered from the National Health Expenditure Accounts. According to the AHA, however, the data, methods, and analysis required for certain model estimates (e.g., uninsured rates) have been concealed from public scrutiny.

"The agency continues to withhold relevant information from the public, thereby depriving the AHA and others of the ability to comment on the basis for the agency’s decision," AHA wrote. "Without additional information regarding the OACT analysis, stakeholders can neither validate nor evaluate the complex calculations CMS has made in estimating the percent of uninsured and other factors used to determine DSH payments."

Editor’s note: To read the AHA press release, click here. To read the AHA’s full letter to CMS, click here.