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Thank you for this excellent analysis. We’ve found similar disparities in our analyses of hospital cost report data, as described here: https://ruralhospitals.chqpr.org/Problems.html#private_pay_losses

However, our analyses show that the key factor is not how rural the location is, but how small the hospital is. The best measure of hospital size is its total expenses, not the number of beds (since most hospital care is outpatient not inpatient). Small rural hospitals (those below the median total expenses for rural hospitals, which is about $45 million) are paid much less relative to their costs by private payers (which includes Medicare Advantage plans) than by Medicare. The smallest rural hospitals (those under $20-25 million in annual expenses) are paid the least. It doesn’t matter that the hospital is the only hospital for miles around because network adequacy rules do not require a health plan to contract with the only hospital in a small rural community.

The differences between small rural hospitals and larger hospitals (both rural and urban) are described here: https://ruralhospitals.chqpr.org/downloads/Two_Types_of_Hospitals_in_US.pdf. You can find information on the sizes of both urban and rural hospitals here: https://ruralhospitals.chqpr.org/Data0.html and you can see the disparity in profit margins for Medicare vs. Private/Other payers by hospital here: https://ruralhospitals.chqpr.org/Data3.html

Your caveat about not using the actual Medicare payment amounts at Critical Access Hospitals is very important and it may not be understood or appreciated by many readers. The CAH program was created in 1997 because standard Medicare rates were not sufficient to cover the cost of care at small rural hospitals, and many of those hospitals were closing as a result. So Medicare pays CAHs significantly more than other hospitals for many key services, such as emergency department visits and inpatient care, because the cost per patient for those services is much higher in a small rural community. If a commercial insurance plan is paying the CAH less than the standard Medicare rates paid to larger hospitals, then it is paying the CAH a lot less than the actual amount Medicare is paying the CAH, so the actual percentage of Medicare will be much lower than shown in your charts. Medicare Advantage plans are not required to pay a CAH the same amount that Original Medicare does, and they often pay less, so the growth in Medicare Advantage plans nationally has been one of the reasons more and more rural hospitals are losing money. It sounds as though you also didn’t make adjustments for the higher payments received by Sole Community Hospitals, Medicare Dependent Hospitals, and Low Volume Hospitals, which is how many small rural hospitals that are not Critical Access Hospitals are paid, and if so, the actual rural/urban disparity is also greater as a result.

Lower payment amounts from commercial insurance plans are only part of the reason that small rural hospitals lose more money on those patients – the other reason is the excessive use of prior authorization and high rates of claims denials. Even if a commercial insurance plan or Medicare Advantage plan contracts to pay the hospital the same amount as Medicare would pay, they often don’t pay at all, so the actual net revenue the hospital receives is lower than the payment amounts would suggest. For example, if a health plan says it will only pay for a hospitalized patient as an observation stay rather than an inpatient stay, the hospital’s payment is much less than it would have been paid by Medicare as an inpatient stay, even if the health plan paid the same amount for an observation stay as Medicare would have paid. And if the health plan simply rejects the claim and the small rural hospital doesn't resubmit it in time, the hospital won't be paid at all. Small rural hospitals don't have the resources that larger hospitals do to appeal and resubmit claims denials, so their net revenues are lower as a result.

Thank you again for this excellent work!! I appreciate all of the time and effort that were required to do this.

Harold Miller

President & CEO

Center for Healthcare Quality and Payment Reform

miller.harold@chqpr.org

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