The American Hospital Association (AHA) this week submitted comments to the U.S. House Committee on Ways and Means, Subcommittee on Health about the Protecting the Integrity of Medicare Act (PIMA), a bill that seeks to save the government money by making it harder to successfully defraud the system.

Among the changes in the bill the AHA either questioned or requested more careful attention to were:

1. Removing Social Security account numbers from Medicare cards to make it harder for these numbers to be gathered and possibly used for purposes other than billing for medical services. While the AHA supported better identity protections for Medicare beneficiaries, the number of Medicare cards out there already makes re-issuing cards for the fix a roughly $320 million proposition – money the Medicare system could ill afford to lose, the AHA felt.
2. Giving Recovery Audit Contractors (RACs) the authority to audit and deny payments for claims based on the eligibility status of a Medicare beneficiary. The AHA “strongly” opposed this because of the current problems with the RACs’ audits of hospitals just on improper diagnosis and because the government data that hospitals use to verify eligibility is not always reliable. As a result, a hospital might through no fault of its own judge a patient as Medicare eligible even though it later turns out he or she was not because the data was wrong.
3. Stopping more Medicare improper payments before they are ever issued to providers. The AHA supported this if tied to more RAC program reforms.
4. Studying what legal changes to Stark (anti-self referral) law, Civil Monetary Penalty law and anti-kickback law are needed to facilitate programs that reward providers for better quality and reduced healthcare costs was supported by the AHA.
5. Incorporation of the H.R. 3776 “Stark Administrative Simplification Act” text into the PIMA bill. The AHA thought some of the language that made the resolution of technical violations of the Stark law more predictable was lost and wanted the language restored.
6. Renewal of Medicare Administrative Contractor (MAC) only every 10 years. The AHA thought this was too long a contract period and might discourage MACs from addressing performance issues.
7. Making the prior authorization demonstration for repetitive scheduled non-emergent ambulance transport a national program. The AHA opposed this because it worried that without further clarification of its scope, it might hurt healthcare access for Medicare beneficiaries living in institutions who require an ambulance for safe transport.