Medicare Compliance & Reimbursement

Reward: your share of $1 billion MMA fund. The Centers for Medicare & Medicaid Services is dangling a new carrot in front of providers -- but will it be worth going through an awkward situation with their uninsured patients? The new proposal issued July 22 would make $250 million a year -- $1 billion total over four years -- available to hospitals and providers to "help recoup the costs of providing uninsured care" according to CMS. Nestled in the proposal is a requirement that hospitals and others collect and maintain additional information on the immigration status of patients in order to receive the additional federal payments. One-third of the funding, which was earmarked by the Medicare Modernization Act, would go to those states with the largest number of apprehensions of undocumented aliens. Currently, aliens who are eligible for "emergency only" Medicaid coverage are not required to provide proof of immigration status. Participants at an Open Door Listening Session in March 2004 raised concerns that inquiries about patients'citizenship would deter many from coming through emergency room doors, CMS said. But the agency cites a May 2004 General Accountability Office report (GAO-04-472) which found that a lack of reliable data on undocumented aliens has made it difficult to determine the costs of their care. CMS says the proposed program would answer the GAO's call to "develop reporting criteria". With a "patient-based" documentation approach, providers would collect citizenship information after a patient is identified as a self-pay and not Medicaid eligible. An "information collection instrument" released by the agency pinpoints what providers need to document to be eligible for the "section 1011" federal assistance.

A single CMS contractor would be designated to process the claims. Payments would be made retrospectively and sent directly to hospitals, physicians and ambulance providers, including Indian Health Service facilities and Indian tribes and tribal organizations "as long as they did not receive payment from any other source such as the person treated or an insurance company," the proposal reads.

"We encourage everyone involved in providing emergency care to review our proposal and help us craft the best plan to help hospitals and other providers remain vital providers of health care to their communities," said CMS Administrator Mark McClellan. Public comment will be accepted through August 16 with an implementation set for September 1. To read the proposal, go to http://www.cms.hhs.gov/providers/mma1011.pdf.