CMS-1533-FC-87
  

  
 Medicare Program; Proposed Changes to the Hospital Inpatient Prospective Payment Systems and Fiscal Year 2008 Rates

  


  

  

  


  

  


  

  



  

  
Submitter : 
  

  
Mr. Gary Husband
  

  
Date & Time: 
  

  
11/20/2007
  


  

  

  

  

  



  

  
 Organization : 

  

  
Mary Hitchcock Memorial Hospital
  


  

  

  


  

  


  

  



  

  
Category : 
  

  
Hospital
  


  

  

  



  

  
Issue Areas/Comments 
  


  

  



  

  
Capital IPPS Payment Adjustments
  


  

  



  

  
 RE: Capital IPPS



The purpose of the letter is to comment on the CMS Final Rule concerning the Hospital Inpatient Prospective Payment System as published in the Federal Register of Wednesday, August 22, 2007. We would like to take this opportunity to express our concerns with the proposed change to the Medicare Capital Payment System.



By way of background, the Dartmouth-Hitchcock Medical Center (DHMC) is comprised of Mary Hitchcock Memorial Hospital, a 337 bed teaching hospital, the Dartmouth-Hitchcock Clinic, a large academic group practice, Dartmouth Medical School, and the Veterans Administration Hospital.  Mary Hitchcock is the only academic tertiary care hospital in the state of New Hampshire, and is one of only a few major rural teaching hospitals in the country.



As part of the final rule, CMS is proposing to eliminate the Capital Indirect Medical Education adjustment factor.  CMS has based its proposed reduction on a margin analysis that was limited only to Inpatient Capital.  We recommend that CMS refrain from using margin analysis as the basis for reductions, unless there is also a discussion on overall hospital margins.  We strongly urge CMS to include hospital outpatient costs (operating and capital costs) in any future margin analysis related to Indirect Medical Education payments.   The indirect costs related to Medical Education are spread across the organization, and thus the margin analysis should not be isolated to the Inpatient setting. 



In MedPACs testimony to Congress on May 15, 2007 indicated that overall hospital margins have become even more negative in recent years.  MedPAC is projecting a -5.4% (negative) Medicare margin for FY07, compared to a -3.3% (negative) Medicare margin in FY05.  Based on MedPACs testimony to Congress, we are very concerned about the adequacy of the current payment system and its potential impact on Medicare beneficiaries.



Thank you for consideration of these comments.