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We ask CMS to withdraw the proposed rule because:
* CMS has not conducted the required analysis of how the rule would impact access to care and quality.
* CMS has overstepped its authority by proposing broad discretion with no clear criteria for decision making.
* It puts pressure on our local community to increase taxes to fill the gap created by funding shortages.
We believe these policies will dramatically cut Medicaid funding (
PVHMC provides more than 83% of its care to patients who are uninsured or rely on government programs, and for over a century, we have played an essential role as a safety-net provider and tertiary referral facility for the region. Our nationally recognized and specialized services include Cancer Care, Cardiac and Vascular Care, Women's Services, Perinatology, Neonatal ICU, Physical Therapy and Sports Medicine, Robotic Surgery, 3D Mammography, Joint Replacement and a Family Medicine Residency Program affiliated with
State flexibility in funding the non-federal share of Medicaid is essential in making the
The current proposals far exceed the agency's statutory authority. Additionally, we are extremely concerned with the adverse impact the proposed rules administrative requirements will have on CMS and Medicaid agencies. The provisions outlined in the proposed rule are excessive and will cost the state of
Further, CMS proposal to limit intergovernmental transfers to state or focal taxes will create additional pressure on counties and states that rely on these arrangements. In
PVHMC disagrees with CMS' premise that, in order to improve the program's fiscal accountability, states should force local communities to raise additional or create new health care-related taxes to support the existing programs. If finalized, these policies will be devastating to our most vulnerable patients. We urge the agency to withdraw the proposed rule and work with stakeholders on policy solutions that will ensure access to care for all who need it.
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The proposed rule can be viewed at: https://www.regulations.gov/document?D=CMS-2019-0169-0001
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