that the nature of teaching hospital operation must be clearly understood in order to determine the appropriateness of the hospital's cost. Teaching hospitals typically serve a broad regional area on a referral basis offering a wide range of specialized services that are typically not available in many community hospitals. This results in a higher-cost institution. Studies, however, have proved that teaching hospitals are the appropriate setting to provide many of the referral services because of the resources typically found in a University setting. In addition, the teaching hospital is the primary center for producing most of the health care personnel, particularly physicians, that are needed in the development of an effective health care system for this country. Severe financial restrictions on teaching hospitals will require them to reduce their commitment to training at a time when most studies indicate these efforts need to be accelerated. To summarize, the 25 hospitals in Pennsylvania that will be adversly affected by these regulations are simply being told that their costs are above the stated average and therefore not eligible for reimbursement. The only reason given is that they fall outside the formula that is being applied nationally, and we think this is inexcusable. We, therefore, urge the withdrawal of the new schedule of limits until a better system of evaluating efficiency is developed. CONGRESS OF THE UNITED STATES, Hon. DAN ROSTENKOWSKI, Chairman, Subcommittee on Health, HOUSE OF REPRESENTATIVES, House Ways and Means Committee, Washington, D.C. DEAR MR. CHAIRMAN: I am in receipt of the enclosed correspondence from my constitutents expressing their strong support for H.R. 7000. It is my understanding that your Subcommittee will be holding hearings on proposed and final regulations pertaining to Medicare including the one relating to H.R. 7000. I am hopeful you will consider the comments contained in the enclosed correspondence during these deliberations. With best wishes, Enclosure. Hon. WILLIAM S. MOORHEAD, Washington, D.C. WILLIAM S. MOORHEAD. CHILDREN'S HOSPITAL OF PITTSBURGH, DEAR CONGRESSMAN MOORHEAD: Representative Mark W. Hannaford has introduced in the House of Representatives Bill 7000 which would require that the Social Security Administration continue to provide for the allowance for an inpatient routine nursing salary cost differential of at least 82% as reasonable reimbursable cost of inpatient nursing care. Children's Hospital of Pittsburgh would not gain anything by this feature currently in the rules and regulations, but nonetheless recognizes the fairness of it. A fairly extensive study was done a number of years ago to show that the elderly receive nursing care in excess of the average patient, and a figure of 82% was at that time established as a fair recognition of this difference. Since the Medicare law calls for full reasonable reimbursable costs, the 82% recognition of nursing salary differential is legal. It may be contrary to the law itself to remove this differential. I therefore urge that you support HR-7000. Very truly yours, HAROLD W. LUEBS, Administrator. [Mailgram] MONTEFIORE HOSPITAL ASSOCIATION OF WESTERN PENNSYLVANIA, Representatives WILLIAM S. MOORHEAD and H. JOHN HEINZ, As a follow up to recent correspondence with your office concerning the proposed elimination by the Social Security Administration of the 81⁄2 percent nursing cost differential provided to hospitals under the Medicare Program, we would urge your support of H.R. 7000, introduced by Representative Mark W. Hannaford, which would require the Social Security Administration to continue to provide for the 81⁄2 percent nursing cost differential in recognition of the above average cost of furnishing care to aged patients. MILTON PORTER, President. IRWIN GOLDberg, Executive Director. MAGEE-WOMENS HOSPITAL, Pittsburgh, Pa., May 27, 1975. Hon. WILLIAM S. MOORHEAD, M.C., Federal Building, Pittsburgh, Pa. DEAR CONGRESSMAN: I urge your support and co-sponsorship of H.R. 7000. This bill requires the social security administration to continue to pay the inpatient routine nursing salary cost differential of at least 82% as a reimbursable cost to hospitals who provide an above average amount of nursing service to Medicare patients. SSA has arbitrarily decided to eliminate this cost which is clearly a Medicare cost. The original study which determined this differential is still valid. The original intent of Congress was that all costs applicable to Medicare patients should be paid by the Medicare program. If this cost is not reimbursed to hospitals, then patients other than Medicare patients will have to pay this cost. Sincerely, HENRY J. SMITH, Director of Fiscal Services. [Mailgram] MERCY HOSPITAL OF PITTSBURGH, Hon. WILLIAM S. MOORHEAD, Washington, D.C. We urgently count on your support of H. R. 7000 introduced by Congressman Mark Hannaford on May 14 to require the Social Security Administration to continue to provide for inpatient routine nursing salary cost differential of at least 81⁄2 percent for services to aging patients. We count on your support just as surely as the patient in a critical care bed in a full service hospital can count on a nurse when he rings for her service gratefully. [Mailgram] Sister M. FERDINAND CLARK, PRESBYTERIAN UNIVERSITY HOSPITAL, Congressman WILLIAM S. MOORHEAD, As I am sure you are aware on May 14, Representative Mark Hannaford introduced H. R. 7000, a bill which will require the Social Security Administration to continue to provide for the allowance for inpatients routine nursing salary cost differential of at least 81⁄2 percent, as the reimbursable cost of inpatient nursing care, in recognition of the above average cost of furnishing such care to aged patients, I am urgenly requesting your support and cosponsorhip of this bill. EDWARD H. NOROIAN, President. WILLIAM S. MOORHEAD, [Mailgram] PITTSBURGH EYE AND EAR HOSPITAL, Urge support and co-sponsorship of H. R. 7000 requiring Social Security Administration to continue providing the allowance for an inpatient routine nursing salary costs differential of 81⁄2 percent, as reimbursable costs of inpatient nursing care, elimination of allowance would not reduce hospital costs but would result in transfer of costs to other patients, as previously demonstrated. Differential necessary to reimburse hospitals for higher than average routine service costs incurred in caring for aged patients. LYLE W. BYERS, Executive Director. Hon. JOHN M. MARTIN, Jr., REDLANDS COMMUNITY HOSPITAL, Chief Counsel, Committee on Ways and Means, DEAR MR. MARTIN: I am writing this with a deep concern over the impending serious economic consequences that would result from the elimination of the 82% nursing salary cost differential. It has been recognized by legitimate studies conducted by the Social Security Administration that aged Medicare patients require a greater-than-average amount of routine nursing care. Since this was recognized in 1971 by the SSA, the situation has not lessened, but has, in fact, magnified due to the advances that have been made in the last four years in the care of the elderly. At Redlands Čommunity Hospital, a 195-bed community hospital, we found that today we have a census of 114 patients and the age distribution is as follows (this random tally is typical of our usual age distribution): Age 1 to 64.. 65 to 69. 70 to 79. Number 80 to 89 90 and over.... Total... 114 It is apparent from a "typical" day at Redlands Community Hospital, that over 50% of our patients are 65 years of age and over. It is further observed that 41% of our patients were 70 years and over. From staffing patterns within our hospital, the record indicates that these patients do require more than the average number of nursing hours as prescribed by the Commission for Administrative Services in Hospitals (CASH), for our area. Further, in analyzing our records, we have had a negligible number of patients who qualified for Medicare that were less than 65 years of age. It is quite apparent to us at Redlands Community Hospital that a shifting of the responsibility of payment for hospital care in our community is carefully being accomplished by the federal government if this differential were to be eliminated. I would like to further register a protest to changing the rules amid stream without abiding by the 1971 regulations that originally authorized the nursing care differential. At that time, it was provided that the SSA would conduct further studies with respect to nursing care prior to any revision of this 82% formula. I am not aware of any studies that have been conducted by SSA that document legitimatizing a reduction of this cost reimbursement. I am certain it is no news to you that there are many community hospitals in our nation that are endeavoring to serve their communities, which are going to be unduly restricted and come to a point of financial insolvency if this and other unrealistic controls are placed upon us. Therefore, I would appreciate your consideration of the needs of our nation's hospitals by your action to maintain the nursing salary cost differential, at least at the level it now exists. Sincerely, GEORGE A. DELANGE, Administrator. CONGRESS OF THE UNITED STATES, Hon. AL ULLMAN, Chairman, House Ways and Means Committee, DEAR MR. CHAIRMAN: I have just received the enclosed correspondence concerning the Social Security Administration's proposal to terminate the 8%% inpatient routine nursing salary cost differential. It is my understanding that H. R. 7000 will help to discourage the Social Security Administration from removing this cost differential. It is my sincere wish that Sister Mary Brooks' views be given every consideration when the Ways and Means Committee acts upon this legislation. With warm regards, I remain DEAR REPRESENTATIVE HILLIS: The recent proposal by the Social Security Administration to terminate the 82% inpatient routine nursing salary cost differential is of great concern to the hospital staff as well as to the hospital Board of Trustees. The proposed changes are the result of misinformation and apparent arbitrary action on the part of the Social Security Administration. The transfer of costs generated by patients served by the Medicare program should not be the responsibility of the non-Medicare patients. This very principle is in violation of the intent of Public Law 89-97 and its subsequent regulations. We have recognized, as has the Social Security Administration, that the over age 65 Medicare patients do require greater-than-average amounts of routine nursing care. This care is not necessarily in the form of intensified nursing care but more in the areas of general medicine and surgery. The response to medical care of the elderly patients is not as rapid as the non-Medicare patients; therefore requires more extensive attention but the nursing personnel and the other para-medical personnel who are available to serve the patients. The justification for terminating the differential because of extending Medicare coverage to persons under age 65 is not a significant factor at our hospital. The staff at Saint John's Hospital has provided care to 120 patients who were considered having insurance under the Medicare program and under the age of 65 during a period from June 1974 to April 1, 1975. These patients constitute 1% of our total patients and 5% of our total Medicare patient complement. As you can see, this is not a significant number of patients at our particular hospital and therefore the justification submitted by the Social Security Administration is not valid as applied to Saint John's Hospital. The second justification submitted by SSA to support termination of this program because of the high utilization of intensive care nursing service is not supported by our hospital statistics. The Medicare beneficiaries constitute approximately 18% of the admissions to our intensive care nursing units; however, the same patients represent only 10% of the total Medicare patients treated in the hospital. The average cost per hospitalization for Medicare patients is $1,106 as compared to the average cost per hospitalization of all patients being $890. These figures reflect a longer length of stay but, more significantly, the increased costs reflect concentrated nursing care on the routine medical-surgical units. The other primary concern expressed by our staff is that there have been no definitive studies conducted by the Social Security Administration verifying any of the facts which have been stated in their comments submitted in the April 3, 1975 Federal Register. The Social Security Administration has indicated in the past that they would support any change in this specific regulation through extensive study and appropriate consultation with those who are managing the nation's hospitals. We share our concerns with you, not in a defensive manner, but as a result of a sincere concern that regulations which dramatically affect the operations of the hospitals should certainly be properly supported by studies and consultations with those who are providing the health services. This consideration of the hospitals is certainly fair and would display a sincere attempt by the Social Security Administration to work effectively with the nation's hospitals. We hope that your office will be in a position to co-sponsor HR 7000. This bill would provide "for the allowance of an inpatient routine nursing salary cost differential of at least 8.5 per cent, as a reimbursable cost of inpatient nursing care, in recognition of the above average cost of furnishing such care to aged patients". It is hoped that a large number of Congressional co-sponsors on this legislation would discourage HEW from removing the 8.5 percent cost differential. We look for your support with this regulation and other anticipated arbitrary decisions by the Social Security Administration and the Department of Health, Education and Welfare. The decisions made by these government agencies do have a dramatic impact on the hospitals and certainly are cause for alarm by those of us who are managing the hospitals as well as the people whom we serve. Sincerely, JOHN M. MARTIN, Jr., Chief Counsel, Sister MARY BROOKS, C.S.C., ST. JOSEPH'S HOSPITAL INC., Committee on Ways and Means, Washington, D.C. DEAR MR. MARTIN: I vigorously protest the termination of the inpatient routine nursing salary cost differential as a reimbursable cost of a provider. Analysis by age group revealed that care received by patients of older age groups exceeded that by patients under 65 by 21-31 minutes per shift for the age group 65-74, and 55 to 79 minutes per shift for the age 75 and over group. I strongly object to the limits of reduction from the 90th to 80th percentile on inpatient routine service costs. It is discriminatory. Third party payors (private insurance) and self-pay patients will have to pick up the differential. Operational costs keep rising. There is no rescission apparent. Too long have hospitals had to bear criticism for increases when other agencies impose this. Cutbacks in these-Medicare and Medicaid-programs, coupled with reimbursement problems in various sectors of the country, may have a tendency to increase bad debts in many hospitals. The hospital is forced to go to the same marketplace as anyone else. We are paying more for equipment, social security, utilities, supplies and salaries. No relief for the patient paying the increased costs appear to be in sight. Furthermore, the State of Idaho is placed in the $80.00 not to exceed routine daily care. Why should small hospitals or those of intermediate size be equated with larger hospitals of 400 beds? What is becoming glaringly evident is the proliferation of controls and safeguards in the hospital area that threatens the very possibility of even conducting hospital care as we have known it. Quality care that the human dignity of man is entitled to is becoming strangled. Lastly, another increased problem is the boosting of taxes on fuel for private institutions. This could have a severe impact on costs. Recession for hospitals will depend on how well hospitals, especially in Idaho, are able to cope with the multitude of problems we now face. Sincerely, Sister HELEN FRANCES, |