A report commissioned by the American Hospital Association and the Federation of American Hospitals warns that a conglomeration of health measures could result in funding losses of up to $218.2 billion for hospitals by 2028.
The report looked at multiple measures—from sequestration to cuts in Medicare payments for bad debt, hospital coding and documentation adjustment and clarifications to the three-day payment window—to project the cumulative losses between 2010 and 2028.
The single most costly changes they found? Adjustments to Medicare Severity Diagnosis Related Groups documentation and coding, which is expected to add up to $79.3 billion in cuts over that time period.
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Sequestration
Among the reductions taken into account under sequestration, the Budget Control Act of 2011 imposed across-the-board cuts in federal spending, including a 2% reduction in Medicare payments after April 1, 2013. Sequestration cuts have since been extended several times to stretch through fiscal 2027.
Estimated cost: $73.1 billion by 2028.
Changes to Medicaid Disproportionate Share Hospital payments
The group took multiple pieces of legislation into account, namely the Affordable Care Act, which required cuts to federal DSH payments beginning in 2014 to account for the decrease in uncompensated care anticipated under health insurance coverage expansion. It was delayed but will take effect in 2020 and extend through 2025.
Estimated cost: $25.9 billion between 2020 and 2025
Off-campus provider-based departments
The Bipartisan Budget Act of 2015 modified the CMS definition of provider-based off-campus hospital outpatient departments so only those off-campus PBDs that were billing under CMS' outpatient prospective payment system prior to November 2015 could continue to bill under the OPPS starting in 2017. Off-campus PBDs would otherwise be eligible under reimbursements from other payment schedules.
Estimated cost: $13.2 billion between 2017 and 2028
Post-acute care reductions
The Medicare Access and CHIP Reauthorization Act of 2015 capped Medicare reimbursements to post-acute care facilities by no more than 1% in fiscal 2018. Further, the Bipartisan Budget Act of 2018 continued restricting inflation-based payment increases for home health services starting in fiscal 2020.
Estimated cost: $6.1 billion between 2018 and 2028.
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Hospice transfer policy
The Bipartisan Budget Act of 2018 extended the definition of post-acute care providers to include hospitals, which meant patients who are discharged from an IPPS hospital to a hospital will result in a reduced payment to the hospital starting in fiscal 2019.
Estimated cost: $5.5 billion
Bad debt
Under the Middle-Class Tax Relief and Job Creation Act of 2012, bad debt reimbursement was phased down to 65%.
Estimated cost: $5 billion between 2013 and 2028.
3-day window
This refers to the American Jobs and Closing Tax Loopholes Act of 2010, which was meant to prevent unbundling of related services within three days of an inpatient admission.
Estimated cost: $4.2 billion in 2010 and 2011.
The report was compiled by Vienna, Virginia-based health consultancy Dobson DaVanzo and Associates.