The American Hospital Association says the CMS' proposed changes on how officials define “uninsured” when computing Medicaid disproportionate share hospital payments still need tweaking in respect to uncompensated care and unreimbursed physician costs.

The AHA's comments on the proposed rule (PDF) make suggestions regarding the rule revision published on Jan. 18. DSH helps safety net hospitals, which care for a high number of low-income patients.

The association wants the CMS to clarify the rule to include the cost of uncompensated care given when health insurance benefits run out during an extended hospital stay. There's also concern over costs from the Indian Health Service, as AHA officials said the rule excludes unreimbursed costs from IHS or tribal health programs. The AHA also wants the cost of unreimbursed hospital services administered by doctors included in the DSH calculation.

There are also worries in regard to high-deductible plan costs, as the AHA suggested that CMS included unreimbursed costs from non-payment of copayments and deductibles. The AHA argues hospitals take the brunt of those costs from high-deductible and catastrophic health plans where patients can't pay the deductibles.

The AHA is asking for these changes to be applied retroactively to calculations made for fiscal 2009.