VA

The National Association of Children’s Hospitals (N.A.C.H.) appreciates the opportunity to submit comments to the Centers for Medicare and Medicaid Services (CMS) on its proposed rule on health care related taxes published in the May 6th Federal Register. The Association would like to thank CMS for delaying implementation of parts of the health care related tax rule to allow time for the agency to examine the impact of changes on states and providers. Although they only account for 3 percent of all hospitals, children’s hospitals provide 43 percent of the hospital care for children. Children insured by Medicaid account for, on average, 53 percent of all inpatient days of care at children’s hospitals. Since Medicaid is such a large payer for children’s hospitals and the patients they serve, any changes to Medicaid funding, such as changes in provider taxes, can have a profound impact. In several states, children’s hospitals participate in provider taxes, which help to support the states’ Medicaid programs and their ability to provide coverage to millions of children. Any change to current policy should be carefully considered and the potential effects of changes on state Medicaid programs and providers should be examined. With the serious budget pressures currently facing states, any changes that could limit state financing mechanisms already in place could negatively affect the ability of these programs to maintain coverage and payment levels. Protecting the fiscal integrity of the Medicaid program is in all of our best interests – providers, states and the federal government. As significant Medicaid providers, we look forward to working with you and states over the next year to examine provisions of the rule. Thank you for your work on this regulation. If you have any questions on our comments on this proposed rule, please contact Aimee Ossman at 703/797-6023 or aossman@nachri.org.