Rich Umbdenstock

President and CEO


April 19, 2010


America's hospitals are deeply disappointed with today's proposal. Plain and simple:  this policy will undermine hospitals' ability to care for patients and communities across the country.   

Should this rule take effect, billions of dollars would be taken out of the system just as hospitals are grappling with sweeping changes and payment reductions contained in the new health reform legislation.  Not only do we believe CMS' analysis is incomplete, we disagree with any further reductions to a system in which, according to independent analyses conducted by MedPAC, hospitals already are being paid less than the cost of providing vital services. 

We take issue with the coding offset that assumes inpatient payments have increased solely due to changes in coding - ignoring that hospital patients are getting sicker. Hospitals supported the move toward a more refined payment system that would better characterize patient severity, yet CMS' coding offset distorts any improvements to payment accuracy. 

We strongly urge CMS to rethink their analysis regarding the coding offset and hope to work with the agency to eliminate these cuts and protect health care that patients and communities need and deserve.