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June 27, 2007
Ms. Leslie Norwalk, Esq.
Acting Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Room 445-G, Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, D.C. 20201
ATTN.: CMS-1545-P
Re: Medicare Program; Prospective Payment System and Consolidated Billing for
Skilled Nursing Facilities for FY 2008; Proposed Rule, Federal Register, Volume
72, No. 86, Friday, May 4, 2007
Dear Ms. Norwalk:
On behalf of our approximately 200 member hospitals and health care systems,
the Illinois Hospital Association (IHA) is taking this opportunity to formally
comment on the proposed rule establishing new policies and payment rates for
hospital inpatient skilled nursing facility services for fiscal year 2008.
Therefore, in accordance with instructions in the rule, the Illinois Hospital
Association presents the following comments for your consideration:
BACKGROUND:
Forecast error adjustment: A forecast error percentage (measuring
the difference between estimates of the market basket increase and the
actual market basket increase) of 0.25% is currently used to determine
whether an adjustment to the overall skilled nursing market basket increase
is required. CMS proposes to increase that percentage difference to 0.50%,
primarily to eliminate "minimal imprecision" in the data. CMS’ own analysis
indicates that the percentage difference in FY 2006 is 0.3%, high enough to
justify an adjustment under the current rules, but too low to justify it
under the proposed rule. Whether the percentage adjustment is 0.25%, 0.50%
or an amount in between, payments to skilled nursing providers are
significantly impacted. Therefore, the Illinois Hospital Association
recommends that CMS defer any revisions to the market basket forecast error
adjustment to at least FY 2009, but also, because the data is currently
available, adjust for the 0.3% "underpayment" in the FY 2008 final rule SNF
base per diem rates.
Ms. Norwalk, thank you again for the opportunity to comment. The Illinois
Hospital Association also welcomes the opportunity to work with your agency in
the continued development and refinement of the Medicare payment system for all
providers.
Sincerely,
Thomas A. Jendro
Senior Director, Finance
Illinois Hospital Association
(630) 276-5516
tjendro@ihastaff.org
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