Mr. William Lessard                                                                                        

Provider Reimbursement Division

DMAS

600 Broad Street, Suite 1300

Richmond, VA  23219

Mr. Lessard;

We appreciate the opportunity to comment on the Notice of Intent to Amend the Methods and Standards for Establishing Payment Rates – Inpatient Hospital Services (12 VAC 30-70).

In addressing the reimbursement changes affecting our hospitals, we would like to note that our ability to serve the communities and continue research & development to improve care is based on a fair cost reimbursement for services rendered.  Medicare and Medicaid is a large part of the payor base for our patients and unfortunately does not cover the full cost of care.  Therefore, we depend on the inflation increases to keep pace with rising costs.  We nor our patients cannot afford these continued cuts by Medicare and Medicaid. Consider at a minimum an inflation rate adjustment to keep with the trend of rising costs.  Many of our rural hospitals are struggling due to rising costs for necessary services such as Emergency Room and Obstetrician services. Please reconsider the inflation adjustment as Virginia’s families need rural community hospital services. 

Keeping pace with the increased patient population, all states need to address the rate of resident training.  In addition to our current physician shortage, American Hospital Association (AAMC) is showing a projected shortage of physicians to be between 40,800 and 104,900 over the next decade.  Creating a real risk to patient care.  We agree and “Thank you” for considering an increase in supplemental payments for existing programs with new medical residency slots.  But would also encourage supplemental reimbursement for new programs in their cap building years. 

Supplemental payments to the LCME accredited medical school located in Planning District 23 and District 5 will greatly benefit their teaching programs.   In reference to the physician shortage addressed in the above paragraph, we would suggest that the supplemental program be open to all teaching facilities in order to increase teaching programs across the state. 

Comment on the Reimbursement Changes Affecting Other Services (12VAC 30-80).  As referenced in the above paragraph, rising costs to recruit and retain physicians in the rural communities is vital for patients and their families.  A “no inflation adjustment” is injurious to rural areas and to patients that are too far from the larger urban area hospitals.  Many rural community patients are covered under Medicare/Medicaid plans, which again, pay at or below cost of care.  We ask that you reconsider an inflationary adjustment to payment rates. 

Thank you for your consideration