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Hospital Responses to New Disproportionate Share Payment Rules
Jenny Markell1, Gerard Anderson1, Mark Meiselbach1
1Department of Health Policy and Management, Johns Hopkins Bloomberg School of Public Health, Baltimore, Maryland, USA.
Health Services Research
|August 12, 2026
Summary
Medicare
Area of Science:
- Health Economics
- Healthcare Policy
- Hospital Financial Management
Background:
- Medicare's disproportionate share payments (DSH) are designed to support hospitals serving a large number of low-income patients.
- A 2018 policy change altered the DSH payment formula to incorporate uncompensated care (UC) data.
- The impact of this policy change on hospital reporting and DSH payments requires investigation.
Purpose of the Study:
- To evaluate whether the 2018 Medicare DSH payment formula change influenced hospitals' reporting of uncompensated care.
- To assess if different hospital categories experienced differential changes in UC reporting and DSH payments post-policy change.
Main Methods:
- A difference-in-differences analysis was employed to compare changes in UC reporting and DSH payments.
- Data from 2011-2023 hospital cost reports (RAND), American Hospital Association (AHA) surveys, and KFF uninsurance rates were linked.
- The analysis categorized hospitals by system affiliation (system vs. individual) and ownership (for-profit vs. nonprofit).
Main Results:
- System-affiliated hospitals reported an 11% increase in UC and a 20% increase in UC payments compared to individual hospitals.
- For-profit hospitals reported a 41% increase in UC and a 4% increase in UC payments compared to nonprofit hospitals.
- For-profit hospital systems showed the most significant changes, with a 49% rise in UC reporting and an 18% rise in DSH payments relative to nonprofit individual hospitals, largely driven by the two largest systems.
Conclusions:
- The policy change disproportionately benefited hospitals that increased their UC reporting, particularly for-profit systems.
- The Centers for Medicare & Medicaid Services (CMS) should monitor UC reporting, including charity care and bad debt, for accuracy.
- Further research is needed to determine if reporting changes reflect actual practice, and policy adjustments may be necessary to ensure equitable DSH payment distribution.
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