Submitted Online (www.townhall.com) and Sent Via Email (Emily.McClellan@dmas.virginia.gov)
September 10, 2020
Emily McClellan
Virginia Department of Medical Assistance Services
600 E. Broad St., Suite 1300
Richmond, VA 23219
Re: Virginia Hospital & Healthcare Association
Public Comment on Hospital Manual Chapter V
Virginia Hospital & Healthcare Association (“VHHA”) appreciates the opportunity to submit comments to the Virginia Department of Medical Assistance Services (“DMAS”) in response to its General Notice regarding draft Hospital Manual Chapter V posted on August 11, 2020. The draft changes to Chapter V relate to implementation of reimbursement changes directed by Item 313.AAAAA of HB30 (the “Budget Bill”), which alters Medicaid reimbursements for certain emergency department (“ED”) claims, and Item 313.BBBBB of the Budget Bill, which implements a readmission reimbursement reduction (the “Reimbursement Changes”).
On June 19, 2020, VHHA submitted public comments in response to the DMAS Notices of Intent to Amend the Virginia State Plan for Medical Assistance posted on May 20, 2020, for the purpose of implementing the Reimbursement Changes. In its public comments in response to that notice, VHHA expressed its opposition to the Reimbursement Changes and related State Plan Amendment. Because this General Notice relates to the same subject matter as the proposed State Plan Amendments, VHHA is opposed to the draft changes to Hospital Manual Chapter V for the same reasons stated in our public comments on June 19, 2020.
For your reference, please find enclosed copies of the public comments submitted on June 19, 2020, expressing our opposition to the Reimbursement Changes.
https://townhall.virginia.gov/l/viewcomments.cfm?commentid=80911
https://townhall.virginia.gov/l/viewcomments.cfm?commentid=80915
To summarize the reasons for our opposition as it relates to the Reimbursement Changes and the draft Hospital Manual Chapter V:
For all of the reasons stated in our June 19, 2020, public comments and restated herein, VHHA is opposed to the draft Hospital Manual Chapter V. Furthermore, to our knowledge the State Plan Amendments for the Reimbursement Changes have not yet been approved by the Centers for Medicare & Medicaid Services. Accordingly, it may be premature to amend the Hospital Manual at this time.
Thank you again for this opportunity to comment. If you have any questions or require clarifications of our comments, please feel free to contact me at brawlings@vhha.com.
Sincerely,
R. Brent Rawlings
Senior Vice President & General Counsel
Enclosures