Yesterday, FAH submitted comments to CMS on its proposal to collect information through a form that would be provided to state Medicaid programs, requiring providers to attest that they are not being held harmless to a provider tax. 

FAH reiterated concerns with CMS’s interpretation that the hold harmless provision applies to private arrangements and goes beyond a state guaranteeing that a provider will be held harmless. FAH also raised concerns about CMS’s reporting burden estimate, indicating that hospitals will incur much higher costs than CMS’s estimate of six minutes per hospital to complete the form.

Read the letter.