I sincerely hope that you, as Commissioner, will reconsider your intention to discontinue the 81⁄2 percent Nursing Differential under Medicare. Let's have Medicare pay its fair share! Sincerely, KENNETH W. AITCHISON, Administrator. COMMISSIONER, COMMUNITY MEMORIAL HOSPITAL, Social Security Administration, Department of Health, Education, and Welfare, Washington, D.C. DEAR SIR: The intention of HEW to discontinue the 82% Nursing Differential under Medicare will be some blow to Hospitals across the country. For 1974, our patient days totaled 5,759 of which 3,136 (54.5%) were Medicare. As a group, the Medicare age bracket requires considerably more Nursing Care than do younger persons. They need help getting in and out of bed; if they must remain in bed, good nursing care takes even more time; in educating those preparing to go home, the material must usually be covered 3 times before there is even comprehension. They often come to us with multiple diagnoses which require varied treatment and care. As a former Director of Nursing Service, I know these things for a fact, and have found nothing that would support any other view. For 1974, our Medicare discounts were $33,397.96 (that's 7% of our gross revenues). This, of course, must be picked up in 1975 by increasing rates. Can you see what the loss of the 82% Nursing Differential would do to us? I do believe Medicare was intended to pay its own way and not be subsidized by taxpayers 2 times-Through taxes plus higher individual hospital costs. This particular plan of HEW doesn't seem the way to improve Health Care to those over 65. And it certainly won't do much for holding Health Care costs down. Sincerely, JOAN BACHMAN, Administrator. SAINT ALEXIUS HOSPITAL, Bismarck, N. Dak., April 15, 1975. DEAR SIR: St. Alexius Hospital is in receipt of the notice that the Department of Health, Education and Welfare intends to discontinue the nursing differential for routine inpatient costs under the Medicare program. I am writing in opposition to this decision because there is no evidence that the Department of Health, Education and Welfare has completed any new studies to document its thesis that patients 65 years of age and over do not require a greater level of nursing services than other patients. This is the basis for the original decision and one with which we involved in providing care are all too well aware. In the case of St. Alexius Hospital and based on our patient day volume of Medicare beneficiaries, this will amount to a loss of approximately $20,000.00 over the ensuing fiscal year. This translates into an additional 40¢ per patient day additional cost to the remaining volurae of our patients who are not Medicare beneficiaries. It is our understanding that Title XVIII requires that the Medicare program pay for its full costs and that these costs are not to be subsidized by other users of our hospital services. Nevertheless, the end result of this decision would be that hospitals in general and St. Alexius Hospital in particular, have no other recourse but to recover these costs from non-Medicare beneficiaries. The justice of such a decision would have to be called into question. The impact across the State of North Dakota will certainly be much greater. For this reason, I would appreciate anything you can do which will result in the reconsideration of this decision. Sincerely, Sister M. JOANNE, O.S.B., President. BISMARCK HOSPITAL, COMMISSIONER, Social Security Administration, Department of Health, Education and Welfare, Bismarck, N. Dak., April 11, 1975. DEAR COMMISSIONER: Comments have been requested regarding the termination of inpatient routine nursing salary cost differential. I would like to add my comments to those you are receiving. As a 200 bed hospital in North Dakota, I am not in agreement with this proposed change. I feel that this will be shifting an unfair burden on the other patients using our facility. In reviewing our records, the number of Medicare patients between 1969 and to date have remained relatively stable and do not show as indicated. In the comments we have received there was a feeling that beneficiaries below age 65 have grown in significant number; this has not been indicated in our institution. Another rationale that had been used as to why this should be dropped is there has been a marked increase in the number of special care beds. This could well be. However, individual patients are not placed in the ICU's or CCU's unless there is medical need and that need should have been prevalent in 1969 as well as it is today. The studies accomplished in 1969, when this benefit was instituted, obviously had indicated a need at that time for such recognition. When that was recognized, the people felt strong enough to add that to our Medicare reimbursement and one of the rationale used, I'm sure, was why should the patients who are not Medicare patients, other third party payors and individual payors, carry the added expense for Medicare patients. This current decision seems to fly in the face of the original study; thus, in effect, increasing the cost of hospitalization to non-Medicare patients. Consequently, this action then adds additional fuel to the fire that hospital costs are continually rising-when in actuality, the hospital was not the controlling factor when a benefit such as this is removed; thus, HEW comes out a hero by reducing their expenses the individual hospitals scattered throughout the U.S. come out the heavy with no defense to change this course. I would appreciate your reconsiderating your action on this potential termination of in-patient routine nursery salary cost differential. Sincerely, QUENTIN BURDICK, JAMES P. SWENSON, Administration. GRIGGS COUNTY HOSPITAL AND NURSING HOME, Russell Senate Office Building, DEAR MR. BURDICK: I am writing in reference to the intention of HEW to discontinue the 81⁄2 percent Nursing Differential Under Medicare. We are concerned about this action because Medicare beneficiaries 65 years of age and over require and receive a greater degree of nursing care than do younger patients. Most of their needs must be anticipated and they must be very closely supervised. Many times 2 or 3 nursing personnel are required to ambulate the senior patient. HEW estimates to save $120 million through the discontinuance of the differential. This would have to be passed on to the non-Medicare patient to be recouped, who are already burdened heavily with medical costs. Also, Title XVIII requires that the Medicare program pay for its full costs and not be subsidized by other users of hospital services. There also is no evidence, to my knowledge, that HEW has completed any new studies to document its thesis that patients 65 and over do not require a greater level of nursing services than younger patients. Sincerely, GARY M. RYBA, Administrator. PEMBINA COUNTY MEMORIAL HOSPITAL, Re 82% nursing differential under medicare. U.S. Senate, Washington, D.C. DEAR SIR: We are very concerned about the elimination of the Nursing Differential under Medicare. Our deductions from revenue for 1974 from our Medicare billings totaled $66,617. It is the non-Medicare patients who have to make up the additional funds necessary to keep in operation and prepare for future care. Thirty-eight percent of our patients are Medicare and account for fifty-nine percent of our patient days. Older patients require more Nursing Care than the average adult patient below 65 years of age. Title 18 requires the Medicare program pay its full costs and should not be subsidized by the other hospital patients. How can we keep costs down when we are constantly struggling to get equal reimbursement from all our patients? We urge you to vote against the elimination of the 8%% Nursing Differential. Sincerely, RUTH HOLLIS, R.N., Administrator. TOWNER COUNTY MEMORIAL HOSPITAL, Senator QUENTIN BURDICK, Washington, D.C. DEAR SENATOR BURDICK: We are concerned about the action of the Federal Register which gave notice that H.E.W. intends to discontinue the 81⁄2 percent Nursing differential under Medicare. I am sure you will agree that Medicare beneficiaries 65 years of age and over require and receive a greater degree of nursing care than do younger patients. For this reason we would like to ask you to assist us in the care of the elderly. Title XVIII requires that the Medicare program pay for its full costs and not be subsidized by other users of the hospital services. Thank you for your consideration and your support in the past. Sister M. ARNOLDINE, Administrator. SAINT ALOISIUS HOSPITAL, Senator QUENTIN BURDICK, U.S. Senate, Senate Office Building, DEAR SENATOR BURDICK: I am enclosing a copy of the letter to the Commissioner of the Department of Health Education and Welfare regarding the administrative maneuverings in that department to unfairly limit reimbursement of hospitals for services to beneficiaries of the health care program for the aged. I think that you would agree that when congress enacts a program it should be fairly administered by those officials who are charged with that responsibility. I further believe that if program funds are inadequate the legislative branch of the government should be so notified so that proper action can be taken. It is my feeling as an administrator of a health care institution that the patients that look to us for health services are entitled to a fair and equitable treatment when it comes to paying for these services. Inflation and cost increases are of concern to me as a citizen and administrator of a health care institution. It is however beyond my control as an individual or administrator to limit cost increases mandated by law, nor is it within my power to control cost increases which come about due to the various international problems that have arisen during the past two years regarding energy and all the other price increases associated with that crisis. I apologize for the length of the letter enclosed. I would however appreciate your consideration of the points and issues raised in that letter. Sincerely yours, LEO GEIGER, Administrator. SAINT ALOISIUS HOSPITAL, Re Federal health insurance for the aged and disabled, termination of inpatient routine nursing salary cost differential, Federal Register April 3, 1975, page 14934 Regulation No. 5 (20 C.S. R. part 405). COMMISSIONER OF SOCIAL SECURITY, Department of Health Education and Welfare, DEAR SIRS: It is obvious from the news release and the statements published in the Federal Register that you are ignorant of the facts concerning the fair reimbursement of providers of health care to the recipients of this program. The elimination of this 8.5% differential merely compounds a serious inequity in the reimbursement to providers and is contrary to the intent of Congress when they enacted this program. The intent of Congress when they enacted public law 18-97 was obvious. In this law in section 1861, paragraph V, entitled "Reasonable Costs" this paragraph charges the secretary with reimbursement of providers on a reasonable cost basis. The regulation in part says, and I quote "Such regulations may provide for determination of the costs of services on a per diem, per unit, per capita, or other basis, may provide for using different methods in different circumstances, may provide for the use of estimates of costs of particular items of services and may provide for the use of charges or a percentage of charges when this method reasonably reflects costs. Such regulations shall (A) take into account methods of determining costs, the costs with respect to individuals covered by the insurance programs, established by this title would not be borne by individuals not so covered, and the costs with respect to individuals not so covered will not be borne by such insurance programs, and (B) provide for a making of suitable retroactive corrective adjustments where, for a provider of services for any fiscal period, the aggregate reimbursement produced by the methods of determining costs proves to be inadequate or excessive." At St. Aloisius Hospital in Harvey I will give you the figures which indicate that Medicare has never reimbursed in this manner and in fact reimbursement has deteriorated over the years to something bordering on the ridiculous. This was accomplished by the Department of Health Education and Welfare by administrative rulings particularly the changing of reporting forms which tend to unfairly allocate costs to the private patients, to the benefit of the Medicare program. To cite what occurred in St. Aloisius Hospital since the inception of this program I will give you costs per patient day for the years in question and costs for all Medicare and Non-Medicare patients per patient day. These are cost figures taken directly from the Medicare cost statement. Since St. Aloysius Hospital is a non-profit hospital, all money required to operate this facility must come from patients, it is apparent that a private pay patient who in fiscal year 1974 paid $20.40 more per patient day than the Medicare patient was discriminated against. It is obvious that that portion of the law which says that cost of program beneficiary will not be borne by private pay patients is not being met. It is further obvious that the Medicare Cost Formula has been modified by administrative rulings so that cost reimbursement for Fiscal year 1974 is literally the same as 1970 and 1971. This is unbelievable when you look at the inflation in the general economy during this period. In summary it is obvious that reimbursement to health care providers is totally inadequate and that if the new regulation is put into effect it would compound this problem. It is further obvious that through a series of administrative maneuvers the Department of Health Education and Welfare has circumvented the intent of Congress and therefore has illegally applied these reimbursement restraints to health care providers and in so doing have been able to subject the general public to the double taxation of not only supporting the Medicare program but also having higher costs for their own health care to offset the inadequate reimbursement of that program. Sincerely yours, LEO GEIGER, Administrator. Senator QUENtin Burdick, COMMUNITY HOSPITAL IN NELSON COUNTY, Russell Senate Office Building, Washington, D.C. DEAR SENATOR BURDICK: I am very distraught at the news that H.E. W. intends to discontinue the 82% Nursing Differential under Medicare. I believe it is noteworthy when H.E.W. says it can save an estimated $120 million. However, it is also noteworthy when another part or the story is the devastating financial effect this would have on particularly those institutions under 50 beds-several hundred hospitals across the country. They, versus larger institutions, have a smaller revenue base to recoup such a financial set-back. I am opposed to the discontinuance of the 82% Nursing Differential. COMMISSIONER, C. GARY KOPP, Administrator. STANLEY COMMUNITY HOSPITAL, Stanley, N. Dak., April 11, 1975. Social Security Administration, Department of Health, Education, and Welfare, Washington, D.C. DEAR COMMISSIONER: We have been informed that HEW intends to stop paying the 81⁄2 percent Inpatient Routine Nursing Salary Cost Differential under Medicare. As the Administrator of a small, rural hospital, I am opposed to any action of this type. HEW would have us believe that discontinuance of the differential would save millions of dollars. It may save HEW some money, but the cost would then have to be passed on by the hospital to the non-Medicare patient. It is not fair to expect non-Medicare patients to pay for the care of Medicare patients or to expect the hospitals to absorb this extra cost. Medicare beneficiaries require and receive a greater degree of nursing care than do other patients. The Medicare program should pay for full costs and should not expect to be subsidized by charges to other patients. Payment in full for hospital care should be expected of Medicare patients, just as it is expected of private pay patients or patients covered by any type of health insurance. Please reconsider the proposed amendments to the regulations. Sincerely, CHARLES KRAMER, DAKOTA HOSPITAL, Fargo, N. Dak., April 11, 1975. Hon. QUENTIN N. BURDICK, Washington, D.C. DEAR SENATOR BURDICK: The March 5, Federal Register carried a most devasting proposed change in the Medicare reimbursement formulae. In an attempt to show unjustifiable savings, the SSA has proposed the elimination of the 8w% Nursing Differential. Health Education & Welfare have projected a savings of $120 million. In order to accomplish this, our hospitals will have to reduce the available care to Medicare recipients or spread the cost to all other patients. Neither alternative is acceptable. |