[Federal Register: February 22, 2008 (Volume 73, Number 36)]
[Rules and Regulations]
[Page 9685-9699]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr22fe08-11]
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DEPARTMENT OF HEALTH AND HUMAN SERVICES
Centers for Medicare & Medicaid Services
42 CFR Part 433
[CMS 2275-F]
RIN 0938-AO80
Medicaid Program; Health Care-Related Taxes
AGENCY: Centers for Medicare & Medicaid Services (CMS), HHS.
ACTION: Final rule.
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SUMMARY: This final rule revises the collection threshold under the
regulatory indirect guarantee hold harmless arrangement test to reflect
the provisions of the Tax Relief and Health Care Act of 2006. When
determining whether there is an indirect guarantee under the 2-prong
test for portions of fiscal years beginning on or after January 1, 2008
and before October 1, 2011, the allowable amount that can be collected
from a health care-related tax is reduced from 6 to 5.5 percent of net
patient revenues received by the taxpayers. This final rule also
clarifies the standard for determining the existence of a hold harmless
arrangement under the positive correlation test, Medicaid payment test,
and the guarantee test (with conforming changes to parallel provisions
concerning hold harmless arrangements with respect to provider-related
donations); codifies changes to permissible class of health care items
or services related to managed care organizations as enacted by the
Deficit Reduction Act of 2005; and, removes obsolete transition period
regulatory language.
DATES: Effective date: This rule is effective April 22, 2008.
Compliance date: CMS will not consider a State to be out of
compliance with the revision to the definition of permissible classes
until October 1, 2009.
FOR FURTHER INFORMATION CONTACT: Charles Hines, (410) 786-0252 or
Stuart Goldstein, (410) 786-0694.
SUPPLEMENTARY INFORMATION:
I. Background
A. General
Title XIX of the Social Security Act (the Act) authorizes Federal
grants to the States for Medicaid programs to provide medical
assistance to persons with limited income and resources. While Medicaid
programs are administered by the States, they are jointly financed by
the Federal and State governments. The Federal government pays its
share of medical assistance expenditures to the State on a quarterly
basis according to a formula described in sections 1903 and 1905(b) of
the Act. The amount of the Federal share of medical assistance
expenditures is called Federal financial participation (FFP). The State
pays its share of medical expenditures in accordance with section
1902(a)(2) of the Act.
The Medicaid Voluntary Contribution and Provider Specific Tax
Amendments of 1991 (Pub. L. 102-234), enacted December 12, 1991,
amended section 1903 of the Act to specify limitations on the amount of
FFP available for medical assistance expenditures in a fiscal year when
States receive certain funds donated from providers and revenues
generated by certain health care-related taxes. We issued regulations
to implement the statutory provisions concerning provider donations and
health care-related taxes in an interim final rule (with comment
period) published on November 24, 1992 (57 FR 55118). A final rule was
issued on August 13, 1993 (58 FR 43156). The Federal statute and
implementing regulations were designed to protect Medicaid providers
from being unduly burdened by health care related tax programs. Health
care related tax programs that are compliant with the requirements set
forth by the Congress create a significant tax burden for health care
providers that do not participate in the Medicaid program or that
provide limited services to Medicaid individuals.
B. Health Care-Related Taxes
Section 1903(w) of the Act requires that State health care-related
taxes must be imposed on a permissible class of health care services;
be broad based or apply to all providers within a class; be uniform,
such that all providers within a class must be taxed at the same rate;
and avoid hold harmless arrangements in which collected taxes are
returned directly or indirectly to taxpayers. Section 1903(w)(3)(E) of
the Act specifies that the Secretary shall approve broad based (and
uniformity) waiver applications if the net impact of the health care-
related tax is generally redistributive and the amount of the tax is
not directly correlated to Medicaid payments. The broad based and
uniformity requirements are waivable through a statistical test that
measures the degree to which the Medicaid program incurs a greater tax
burden than if these requirements were met. The permissible class of
health care services and hold harmless requirements cannot be waived.
The statute and Federal regulation identify 19 permissible classes of
health care items or services that States can tax without triggering a
penalty against Medicaid expenditures.
The regulatory language at 42 CFR 433.68(f) sets forth tests for
determining the presence of a hold harmless arrangement that were
directly based on the language contained in section 1903(w)(4) of the
Act. The preamble to the 1993 regulation provided guidance and some
illustrative examples of the types of health care-related tax programs
that we believed would violate the hold harmless prohibitions. In a
June 29, 2005 decision, however, the HHS Departmental Appeals Board
(DAB), DAB No. 1981, found that these regulations did not clearly
preclude certain types of arrangements that we believe to be within the
scope of the
[[Page 9686]]
statutory hold harmless prohibition and implementing regulations. The
DAB consequently reversed disallowances issued by CMS to five States.
In each of these reversed disallowances, the States had created
programs that imposed a tax on nursing homes and simultaneously created
programs that awarded grants or tax credits to private pay residents of
those nursing homes. These grants and/or tax credits were designed by
the States to compensate private pay residents of nursing homes for the
costs of the tax passed on to them by their nursing homes through
increased charges. The DAB, however found that CMS regulations did not
clearly identify that such grants and tax payments amounted to hold
harmless arrangements that would preclude FFP.
One of the hold harmless tests, set forth in current rules at Sec.
433.68(f)(3)(i), defines arrangements that are considered to be
prohibited indirect guarantees. Taxes imposed on health care-related
providers may not exceed 6 percent of the revenue received by the
taxpayer unless the State makes a showing that, in the aggregate, 75
percent of taxpayers do not receive 75 percent or more of their total
tax costs back in enhanced Medicaid payments or other State payments.
Prior to the enactment of the Tax Relief and Health Care Act of 2006,
States could tax individual classes of health care services and
providers, including inpatient hospital services, outpatient hospital
services, and nursing facility services up to 6 percent of the net
patient revenue attributable to the assessed permissible class of
health care items or services without violating prohibitions on the
indirect hold harmless arrangements. The 6 percent limit was
established to maintain consistency with the average level of taxes
applied to other goods and services in the State, as discussed in the
November 24, 1992 preamble to the interim final rule implementing the
statute.
On December 20, 2006 the Tax Relief and Health Care Act of 2006 was
signed into law as Public Law 109-432. Section 403 of that law
incorporated the existing regulatory test for an indirect guarantee
into the Medicaid statute but provided for a temporary reduction in the
allowable tax rate under the first prong of the test. Specifically, the
indirect hold harmless threshold has been reduced from 6 percent to 5.5
percent effective January 1, 2008 and before October 1, 2011. We want
to remind States that the collection threshold test is an annual test
and while the effective date of this change does not coincide with the
beginning of any State's fiscal year the test must still be performed
on an annual basis. Therefore, if a State chooses to impose a health
care related tax at a rate in excess of 5.5 percent prior to January 1,
2008, it will have to appropriately adjust the tax rate after January
1, 2008 so that health care related tax collections will not exceed 5.5
percent on a per class basis going forward. Compliance in State fiscal
year 2008 will be evaluated from January 1, 2008 through the last day
of State fiscal year 2008. Beginning with State fiscal year 2009 the
5.5 percent tax collection will be measured on an annual State fiscal
year basis.
II. Provisions of the Proposed Rule
In the March 23, 2007 proposed regulation we proposed to:
Codify section 6051 of the Deficit Reduction Act of 2005
(Pub. L. 109-171) which amended section 1903(w)(7)(viii) of the Act to
expand the previous Medicaid managed care organization (MCO) class of
health care items and services to include all MCOs.
Clarify the provisions of the hold harmless tests found at
Sec. 433.68(f).
Modify and clarify the positive correlation test set forth
at Sec. 433.68(f)(1), to specify that a State or other unit of
government will violate this test if they impose a health care-related
tax and also provide for a direct or indirect non-Medicaid payment and
the payment amount is positively correlated to the tax amount or to the
difference between the Medicaid payment and tax amount. We proposed to
interpret the phrase ``direct and indirect non-Medicaid payment''
broadly. These payments may take many forms, such as grants or tax
credits, although there will undoubtedly be other types of payments
that we have not yet anticipated.
Clarify the definition of tax amounts and payment amounts
for purposes of hold harmless analyses. We proposed to unify these
definitions so that they would have identical meanings in all three
hold harmless tests under Sec. 433.68(f).
Clarify within Sec. 433.68(f)(2) that a Medicaid payment
would be considered to vary based on the tax amount when the payment is
conditional on the tax payment.
Clarify the guarantee test at Sec. 433.68(f)(3) to
specify that a State can provide a direct guarantee through a direct or
indirect payment. A direct guarantee would be found when a State
payment is made available to a taxpayer or a party related to the
taxpayer (for example, as a nursing home resident is related to a
nursing home), in the reasonable expectation that the payment would
result in the taxpayer being held harmless for any part of the tax. An
indirect payment to the taxpayer would also constitute a direct
guarantee. One such example of this indirect payment providing a direct
guarantee would be found where a State imposing a tax on nursing
facilities provided grants or tax credits to private pay residents of
those facilities that could be used to compensate those residents for
any portion of the tax amount that the State has allowed to be passed
down to them by their nursing homes. This represents a direct guarantee
of an indirect payment to taxpayers.
Modify under Sec. 433.68(f)(3)(i), the indirect hold
harmless threshold percentage to be consistent with the Tax Relief and
Health Care Act of 2006, which lowered the collection threshold under
the indirect hold harmless provision from 6 percent of net patient
service revenue to 5.5 percent effective for portions of fiscal years
beginning on or after January 1, 2008 through September 30, 2011, prior
to a State being required to demonstrate the second prong of the
indirect hold harmless provision.
Clarify at Sec. 433.56(a)(4) the permissible class for
purposes of health care-related taxes to only those services of ICF/MRs
by removing narrow exception for similar services of community-based
residences for the mentally retarded if certain criteria are met.
Modify parallel hold harmless provisions with respect to
provider-related donations at Sec. 433.54(c).
Remove transition periods related to provider-related
Donations and health care related taxes provided under section
1903(w)(1)(C)(ii) of the Act since the last transition period expired
in 1993.
III. Analysis of and Responses to Public Comments
We received 21 items of timely public comments which contained
approximately 190 public comments that raised 47 individual issues, in
response to the March 23, 2007 proposed regulation (72 FR 13726 through
13734). The comments came from a variety of correspondents, including
health care provider associations, national and State organizations and
State Medicaid agencies. The majority of commenters urged us to
reconsider proposed changes to the hold harmless provisions. The
following is a summary of the comments received and our response to
those comments.
[[Page 9687]]
A. General Comments
Comment: One commenter expressed support for the codification of
the 6 percent maximum tax amount allowed and agreed with CMS'
implementation of section 403 of the Tax Relief and Health Care Act of
2006. The commenter indicated that while health care provider taxes are
not an optimal approach to sustainable appropriate and equitable
Medicaid funding, but stated that cutting the maximum tax rate allowed
substantially below 6 percent would have resulted in Medicaid payment
reductions and thus harmed low income populations needing care. The
commenter also suggested that such taxes create a significant tax
burden for health care providers that provide limited services to or no
services to Medicaid beneficiaries.
Response: We appreciate the support for our implementation of
section 403 of the Tax Relief and Health Care Act 2006. We understand
the concern about the burden of health care related taxes on providers
that have little or no Medicaid revenues. Medicaid limits on health
care related taxes protect those providers at the same time as ensuring
that such health care related taxes do not effectively shift a
disproportionate burden of the Medicaid program to the federal
government. We also recognize that States use revenues received from
permissible health care related taxes to support Medicaid payment
rates, but States have other sources of revenue that can support
Medicaid payments and ensure that low income populations receive needed
care. This rule balances all these concerns in clarifying the
definitions of permissible classes and hold harmless arrangements.
Comment: A couple of commenters asserted that the proposed rule
violated the Administrative Procedure Act provision codified at 5
U.S.C. 553(b). The commenters took issue with the preamble
clarifications regarding interpretations of regulatory provisions that
were included in the proposed rule. The commenters argued that CMS
should have included precise regulatory language to implement such
changes and that CMS cannot implement the proposed rule until it
publishes sufficient notice in the form of substantive regulatory
language. Other commenters stated that CMS provided no rational support
for the proposed rule.
Response: We disagree with the suggestion of any procedural
deficiency. Through publication of the proposed regulation, CMS adhered
to all requirements of the Administrative Procedure Act. Proper notice
was given of proposed changes and a public comment period was provided.
Those comments were considered, and are discussed in this final rule.
The final rule includes all necessary changes to the regulatory
framework and gives States clear guidance on how that regulatory
framework will be applied to health care related tax programs.
Comment: Numerous commenters argued that the proposed regulatory
changes directly contradict provisions of the Social Security Act and
that CMS exceeded its statutory authority. These commenters cited
section 5(c) of the Medicaid Voluntary Contribution and Provider-
Specific Tax Amendments of 1991 (Pub.L. 102-234) which mandated that
the Secretary consult with States before issuing any regulations under
this public law. The commenters asserted that significant changes were
made through this proposed regulation and that consultation with States
was required prior to the issuance of the regulatory changes. For these
reasons, the commenters indicated that CMS should not implement the new
rule and begin consultations with States.
Response: We believe the conditions of section 5(c) of the Medicaid
Voluntary Contribution and Provider-Specific Tax Amendments of 1191,
Public Law 102-234 were fully satisfied by the process the Secretary
undertook when the regulations implementing that Act were issued in
1992 and 1993. Even if these conditions were read to extend in
perpetuity, however, they have been met with respect to this final
rule. The notice and public comment procedures used to issue this final
rule have provided a full and fair opportunity for consultation with
States. This opportunity is in addition to the ongoing dialogue between
CMS and the States over proposed State financing in the review process
for Medicaid State plan amendments.
Comment: Several commenters believe that CMS' approach will harm
State Medicaid programs by decreasing the resources necessary to
support the growing and changing nature of Medicaid services. Another
commenter raised concern about the financial and administrative burden
for States of the proposed rule. One commenter argued that the changes
proposed in the regulation will compel States to dismantle already
approved financing. One commenter asserted that the negative effect of
the proposed rule could exceed approaches rejected by Congress. One
commenter was concerned that CMS did not fully consider the significant
financial issues confronting States and the continual pressure to
contain Medicaid spending in the face of State budgets. Another
commenter stated that the proposed regulation will cause a shift in
burden of health care financing from the federal government to the
States.
Response: This final regulation implements section 403 of the Tax
Relief and Health Care Act of 2006 and clarifies existing Federal law
related to permissible classes of health care services and the hold
harmless provisions. We do not agree that the statutorily-mandated
reduction in the indirect guarantee threshold will result in excessive
financial and administrative burdens or reductions in program benefits.
In any case, CMS is bound by the law to make this change. Moreover, the
clarifications provided in this regulation were not designed to target
particular existing health care related tax programs for which States
have received waiver approval from CMS of the broad based and/or
uniformity requirements. These clarifications were instead to ensure a
consistent and uniform understanding of the application of the hold
harmless provisions. We refer to them as clarifications because they
reflect CMS's understanding of how the hold harmless provisions should
be applied. These clarifications are based on the need to ensure that
the regulations effectively identify hold harmless arrangements in
which health care related taxes operate to effectively shift a
disproportionate burden of the Medicaid program to the federal
government. Although the clarifications are not targeted toward any
particular financing arrangements, CMS reserves the right to perform
financial management reviews of any tax structures to ensure compliance
with Federal statute, expressly approved by CMS or otherwise.
Comment: Several commenters requested that CMS affirm that the
proposed rule would not jeopardize already approved State plan
amendments (SPAs) and provider tax programs. The commenters also
requested that CMS confirm that it will continue to approve SPAs and
provider tax submissions with similar features as those already
approved. In the absence of such confirmations, the commenters
requested that CMS identify with written explanations which specific
approved SPAs and provider tax submissions would be problematic under
the proposed regulation. Another commenter suggested that if these
provisions are adopted in final, they should only apply to payments
contained in SPAs adopted after the effective date of the final rule.
Response: With respect to the change in the indirect guarantee
test, Congress
[[Page 9688]]
did not make any provision to exempt or grandfather existing approved
tax provider programs. Under the direction of the Congress, the final
regulation is effective January 1, 2008. With respect to the other
changes contained in this final rule, we considered and rejected a
possible exception for already approved provider tax programs. Such an
exception would not be uniform and would not achieve the objective of
ensuring that provider taxes did not shift the effectively shift a
disproportionate burden to the federal government. As part of the
routine CMS review of Medicaid State plan amendments (SPA) that affect
Medicaid payment to providers, CMS examines the sources of the non-
Federal share of Medicaid payments, including the revenues received by
States from health care-related taxes. Such SPAs are reviewed and
decided upon on a case-by-case basis under the consistent application
of Federal statute and regulations. Because these clarifications
reflect current CMS practices regarding ongoing reviews, CMS is not
aware of any approved tax programs that are not in compliance with the
final rule. However, CMS always reserves the right to ensure any State
Medicaid financing source and associated reimbursement methodologies
comply with Federal requirements.
Comment: A few commenters were concerned that the proposed rule
would ultimately decrease funding for the Medicaid program and threaten
access to important long-term care services. Another commenter was
concerned that the proposed rule will adversely affect safety net
providers by lowering Medicaid payments and as a result patients'
access to essential health care services would be disrupted.
Response: This final regulation along with the Federal Medicaid
statute governing health care related taxes was designed in part to
protect health care providers. Specifically, the reduction to the
allowable collection threshold serves to minimize the burden imposed on
health care providers by States through taxation in order to support
the State's Medicaid program. The effect of this reduction is that
health care providers can realize a greater net revenue base when they
are no longer obligated to fund a portion of their Medicaid payments
through a State imposed tax. Further, those health care providers that
do not participate in the Medicaid program would experience an overall
reduction in their tax rate. In addition, States have the option to
replace any tax revenue lost as a result of the reduction to the
allowable collection threshold with other sources of non-Federal share
payment, including additional State and local general fund dollars. If
such general fund dollars are used health care providers may experience
no reduction in the level of their Medicaid funding. States still have
many available resources to ensure that necessary services are
available to the most vulnerable populations. The purpose of this
regulation was not to reduce access to any health care services but to
strengthen the fiscal integrity of the Medicaid program.
Comment: One commenter stated that addressing perceived problems
with Medicaid financing would be better addressed through legislation.
Another commenter specified that CMS should work with the Congress to
clarify existing statutory language.
Response: The final regulation implements section 403 of the Tax
Relief and Health Care Act of 2006 and clarifies existing Federal law
related to permissible classes of health care services and the hold
harmless provisions. The clarifications are to ensure that the
regulatory framework effectively implements existing statutory
provisions setting permissible classes and prohibiting hold harmless
arrangements that shift a disproportionate share of the cost of the
Medicaid program to the federal government.
Comment: One commenter noted that, given the most recently issued
proposed regulations restricting IGTs and CPEs, CMS should not further
limit States' ability to fund the non-federal share of Medicaid
payments.
Response: This final regulation implements and clarifies statutory
provisions that permit States to fund the non-federal share of Medicaid
payments with permissible health care related taxes. The statutory
provisions, and these regulations, are a response to States that
imposed health care related taxes that had the effect of shifting
financial burdens from the States to the federal government. This shift
resulted from hold harmless arrangements under which providers were
effectively repaid some or all of the tax burden, and the federal
government was left with a disproportionate share of the tax burden.
The changes made in this final regulation should assist States in
determining the permissibility of tax programs. While the temporary
reduction in the indirect guarantee threshold test may reduce the
amount of permissible tax revenues, States have the option to replace
any tax revenue lost as a result of the reduction to the allowable
collection threshold with other sources of non-Federal share payment,
including additional State and local general fund dollars.
Comment: One commenter expressed concern that the proposed rule
unnecessarily grants CMS authority to delve into relationships between
States and local governments and does not provide sufficient clarity on
the criteria for evaluation of these relationships. The commenter
believes that open ended interpretations of tax and reimbursement
programs could result in case by case inconsistencies and confusion
while States attempt to structure a permissible provider tax program.
Response: This final regulation implements section 403 of the Tax
Relief and Health Care Act of 2006 and clarifies existing Federal law
related to permissible classes of health care services and the hold
harmless provisions. This rule does not specifically require review of
relationships between States and local governments. Under existing
statutory law, however, CMS must ensure that State claims for federal
funding are supported by non-federal expenditures and comply with all
provisions of the law. This includes review of health care related
taxes and associated payment or grant arrangements, whether on a State
or local level. In other words, our review is limited to tracing the
flow of funds to verify the non-federal share of Medicaid expenditures.
This final rule makes changes to the regulatory framework to ensure
that this review is consistent, uniform, and effectively implements the
statutory requirements.
Comment: A couple of commenters specified that CMS did not have the
statutory authority to go beyond the explicit direction provided in the
Tax Relief and Health Care Act of 2006 to only temporarily reduce the
maximum allowable tax rate.
Response: CMS' responsibility is to ensure that the Federal
statutory requirements governing health care related taxes are met. In
addition to codifying in regulation section 403 of the Tax Relief and
Health Care Act of 2006, the new regulation clarifies some issues that
have arisen since the issuance of the 1993 rule. Therefore, we believe
it is necessary and appropriate for the Secretary to issue new
regulatory provisions to address these issues so that States will have
clear guidance on which health care related tax programs will be
entitled to FFP. Furthermore, this final rule fully complies with the
requirements of the Administrative Procedure Act.
Comment: One commenter noted that changes to tax programs will
further exacerbate health care challenges in
[[Page 9689]]
areas impacted by major natural disasters.
Response: We do not agree that either the statutorily mandated
reduction in the indirect guarantee test, or the clarification of
permissible classes or hold harmless tests, will exacerbate health care
challenges in areas impacted by major natural disaster. The reduction
to the allowable collection limit serves in part to minimize the burden
imposed on health care providers through health care related taxation.
This result should help to minimize the cost structure of providers in
areas impacted by major natural disasters.
Comment: One commenter stated that the proposed regulations reflect
a fundamental suspicion of States' Medicaid financing practices. The
commenter encouraged CMS to address any inappropriate financing
arrangements through enforcement of current regulatory standards on a
case by case basis rather than regulatory changes.
Response: Our responsibility is to ensure that the Federal
statutory requirements governing health care related taxes are met in a
consistent and uniform manner. Revision to the regulatory framework
ensures consistent and effective implementation of the statute.
B. Implementation
Comment: Several commenters recommended that CMS delay the
implementation of the new rule until State legislatures can adequately
assess its implications and take the necessary action to ensure proper
funding of their Medicaid programs. A few commenters recommended that
the proposed rule be delayed until CMS works closely with States to
establish some optional funding solutions for Medicaid services.
Another commenter suggested that, at a minimum, States should be
provided an adequate transition period to implement the new rule.
Another commenter recommended that the effective date of the rule be
delayed by at least 6 to 12 months.
Response: As required by section 403 of the Tax Relief and Health
Care Act of 2006, the final regulation with respect to the reduction in
the indirect guarantee threshold percentage is effective January 1,
2008. We have provided for a transition period until October 1, 2009
for States to come into compliance with the statutory revision to the
permissible class of health care services identified as ``services of a
managed care organizations.'' Since the other provisions of the
regulation are clarifications that reflect CMS's existing understanding
of the law, further transition is not warranted.
C. Permissible Classes of Health Care Items and Services--ICF/MR (Sec.
433.56(a)(4))
Comment: Several commenters, including a commenter from a State
that the commenter believes was the intended beneficiary of the
provision, expressed concern that CMS did not explain why community
based residences included in the ICF/MR class in 1993 would be excluded
from the class. One commenter stated that CMS violated the APA by not
providing a reasoned analysis for the proposed change. Another
commenter stated that this proposed change would adversely affect the
provision of home and community based services.
Response: We proposed to delete this exception because we believed
it was no longer applicable to any State. In response to these
comments, we have determined that there is one State to which the
exception applies. Therefore, we are no longer deleting the exception.
In the 1993 interim final rule implementing Medicaid Voluntary
Contribution and Provider Specific Tax Amendments of 1991, the
statutory class of health care items and services at section
1903(w)(7)(iv) of the Act for services of intermediate care facilities
for the mentally retarded (ICF/MR) was defined to include similar
services furnished by community-based residences for the mentally
retarded, under a waiver under section 1915(c) of the Act, in a State
in which, as of December 24, 1992, at least 85 percent of such
facilities were classified as ICF/MRs prior to the grant of the waiver.
This exception was very narrow and was only intended to capture those
States that were granted section 1915(c) waivers that converted most of
their ICF/MRs to community-based residences prior to the effective date
of the interim final rule.
Over the past several years, a few States have requested CMS
approval to expand their ICF/MR services tax programs to include
certain home and community-based services. None of those States were
able to demonstrate compliance with the parameters of this permissible
class of health care items or services. Therefore, when CMS proposed
deleting the exception, CMS did not believe there were any States that
did or could meet these specific requirements.
In response to public comments, CMS was able to identify one State
that meets the requirements for this class of health care services.
Rhode Island has a long-standing tax program that meets these
requirements and as a result, the final regulation retains the original
regulatory language.
Comment: Several commenters asked for CMS to expand the inclusion
of home and community-based service providers in the ICF/MR class for
all States, arguing that it is not equitable to accord different
treatment to States that converted ICF/MRs into waiver facilities
before 1992 than to other States. These commenters noted that this
policy would generally benefit home and community-based service
providers. These commenters argued that, in order for the class to be
truly broad-based, all types of home and community-based residences for
persons with mental retardation and developmental disabilities should
be included. One commenter specifically asserted that this policy would
allow States to impose health care-related taxes to help fund home and
community-based services, and would increase access and availability of
such services. Many commenters cited the benefits of home and
community-based waiver services, and mentioned Federal policies
supporting the expansion of such services.
Response: The statutory provision at section 1903(w)(7)(iv) of the
Act refers only to ICF/MR facilities as the permissible class. As
discussed above, in 1993, we provided for a limited exception to
address the unique situation of States with existing waivers that
converted most of their ICF/MRs to community-based residences prior to
the effective date of the interim final rule. We do not believe a
broader exception would be consistent with the statutory language.
Moreover, we were not persuaded by the arguments that higher taxes on
home and community-based services would actually encourage and
stimulate the provision of such services. It appears counterintuitive
that taxes that make such services more costly would stimulate broader
use and availability.
Comment: One commenter requested that CMS more precisely define
intermediate care facilities for the mentally retarded (ICF/MR) to
include all facilities licensed as ICFs/MR, no matter the size of the
facility.
Response: The regulation was not intended to redefine ICF/MRs or
any other provider type. Instead, in part, the rule proposed to clarify
a permissible class of health care services for purposes of health
care-related tax requirements. For purposes of health care-related
taxes, if a State were to impose a tax on ICF/MR services, in order to
be considered broad-based, all licensed
[[Page 9690]]
ICF/MR providers within the State would need to be subject to the tax.
Comment: One commenter suggested that CMS exercise its statutory
authority to update the historical listing of permissible classes by
adopting additional provider classes through regulation. The commenter
noted that CMS has reminded States of this opportunity. The commenter
specified that inviting proposals to add classes helps update the
Medicaid program by recognizing change in providers, acknowledging
State environments are different, supporting Congressional intent and
recognizing that individual States and providers should be free to
collaborate and choose the best means suited to address financing
relationships to meet their State's needs.
Response: The preamble to the 1993 final rule stated that the
Secretary would consider adding additional classes if States can
demonstrate the need for additional designation and that any proposed
class meet the following criteria: (1) The revenue of the class is not
predominantly from Medicaid and Medicare (not more than 50 percent from
Medicaid and not more than 80 percent from Medicaid, Medicare, and
other Federal programs combined; (2) the class is clearly identifiable,
for example, by designation through State licensing programs,
recognition for Federal statutory purposes, or inclusion as a provider
in State plans; and (3) the class is nationally recognized rather than
unique to a State. At this time, we do not see a reason to alter this
policy or to add new permissible classes of health care items or
services.
D. Permissible Classes of Health Care Items and Services--Managed Care
(Sec. 433.56(a)(8))
Comment: One commenter recommended that CMS consider a definition
for the term ``preferred provider organizations'' so that States will
know what entities must be included in a tax program on this class of
providers for it to comply with the broad-based requirement of the
statute and associated regulations.
Response: Inclusion of the term preferred provider organization
(PPO) as a type of managed care organization that would be in the
permissible class of services for health care-related taxation purposes
mirrored the statutory language enacted under section 6051 of the
Deficit Reduction Act which amended section 1903(w)(7)(A)(viii) of the
Social Security Act. The statutory language was designed to more
broadly encompass services provide by all managed care organizations
without regard to their status as Medicaid or commercial health plan or
the form of such plans. The statutory language included examples to
clearly establish that all types of managed care businesses must be
included in order for a health care-related tax to be truly broad
based. For Medicare accreditation purposes it is established that MCOs
are licensed as both HMOs or PPOs. The intent is to fully encompass the
types of managed care products available to individuals in commercial
markets for coordinated care plans. This is a generally accepted term
and type of entity in the managed health care market and we do not feel
that a definition is necessary for Medicaid regulation purposes.
E. Hold Harmless Sec. 433.68(f)--General
Comment: Some commenters expressed concern that the new rule
appears to replace a purely objective test for hold harmless
arrangements with one that is subjective. They argued that the
Secretary had rejected the introduction of a subjective analysis when
he published the original hold harmless prohibitions in 1993 and that
the new rule should continue along this same course.
Response: We believe that the new regulation continues to apply a
largely objective analysis in determining whether state tax programs
contain hold harmless arrangements. This regulation is intended to
carry out the purposes originally outlined in the Medicaid Voluntary
Contribution and Provider Specific Tax Amendments of 1991 (Pub. L. 102-
234) and the implementing regulations, by prohibiting FFP for health
care-related taxes where the state has implemented a hold harmless
provision. One lesson we have learned in the years since we first
endeavored to implement Congress's prohibitions on taxes with hold
harmless arrangements is that it is simply impossible to anticipate
every hold harmless arrangement that may be implemented by States. As a
result, it would not be true to Congressional intent to implement a
mathematical model to be applied in detecting hold harmless
arrangements that violate the statutory prohibitions. We do not believe
the Medicaid statute contemplates such a formula, but anticipates that
the Secretary will carefully analyze all circumstances relevant to the
creation and operation of a state health care-related tax and attendant
tax relief programs in carrying out his mandate to prohibit FFP where
hold harmless arrangements exist. The analysis of state provider taxes
remains an overwhelmingly objective process, but the unique and
individual nature of State tax programs means that the analysis is
always on a case-by-case basis. The individualized analysis outlined in
this rule is not the type of subjective analysis that the Secretary
expressly rejected in the 1993 final rule. In that rule, the Secretary
rejected a suggestion that CMS should assess the egregiousness of a
hold harmless violation in determining whether to take a disallowance.
Comment: One commenter opined that Congress did not authorize the
Secretary to expand the tests for determining when an impermissible
hold harmless arrangement exists, arguing that the regulations should
mimic the statutory language. Other commenters suggested that the
existing rules were appropriate and the new rules could place existing
tax programs at risk.
Response: It is not our intent to expand the test for determining
when an impermissible hold harmless arrangement exists beyond the
original purposes authorized by Congress and underlying the 1993 rules.
As noted above, we are not aware of any state tax programs that would
have been permissible under the Secretary's prior interpretation of the
rules, but are no longer permissible under the new rules. The new rule
endeavors to address issues that have arisen since the issuance of the
1993 rule, which effectively repeated the statutory language but did
little to elucidate that language. That rule proved largely successful
in stopping impermissible hold harmless arrangements, with the
overwhelming majority of States ending such programs. A recent decision
issued by the HHS Departmental Appeals Board, however, has indicated
confusion concerning the degree of flexibility in the application of
the Secretary's longstanding interpretation of that rule in addressing
new issues that have arisen. (DAB No. 1981, June 29, 2005.) Therefore,
we believe it is necessary and appropriate for the Secretary to issue
new regulations so that States will have clear guidance on which health
care-related tax programs will be entitled to FFP.
Comment: Several commenters requested that they be able to retain
the ability to use rates that are based on receipt of provider taxes
rather than overall provider costs.
Response: The Social Security Act clearly allows States to collect
permissible health care-related taxes to be used as a source of non-
federal share funding for Medicaid payments to health care providers.
Further, States can consider Medicaid's portion of a permissible health
care-related tax as an
[[Page 9691]]
allowable cost for purposes of developing Medicaid reimbursement rates.
However, basing Medicaid payment rates solely on the receipt of health
care-related taxes is a clear hold harmless violation.
Comment: Several commenters noted that broadening the definition of
hold harmless will penalize States that have other non-Medicaid funding
initiatives for health care organizations. Under the proposed rule,
payments made to health care providers as part of regular business
could become entangled in the enforcement of the new rule.
Response: The hold harmless clarifications in this regulation are
necessary to ensure compliance with the statutory limitations on hold
harmless arrangements. In reviewing a health care related tax program,
CMS needs to review the tax and associated financial arrangements as a
whole, including any non-Medicaid payments. Taxes or fees that are
imposed in the ordinary course of business and are not health care
related would not trigger such a review, nor would non-Medicaid
governmental payments that occur in the regular course of business, for
example through procurements.
Comment: One commenter stated that the changes to the hold harmless
provisions could make their current provider tax program non-approvable
because the fees for the most part are used to pay back the cost to the
fee payer.
Response: We are not aware of any State tax programs that would
have been permissible under the Secretary's prior interpretation of the
rules, but are no longer permissible under the new rules. If, however a
State increases Medicaid reimbursement rates based solely on the
receipt of a health care related tax, rather than on the costs incurred
for providing Medicaid services, such an arrangement would be
considered a hold harmless violation. We believe this result is
consistent with the requirements of the statute and existing regulation
and is unchanged by this final rule.
Comment: One commenter requested that CMS include in the rule
itself the language in the preamble to the proposed rule indicating
that States using cost-based payment systems may include provider tax
costs as one of many provider costs that are considered in setting
individualized provider rates. The commenter argued that including this
language in the rule would prevent any changes in CMS interpretation.
Response: We are not including this language in the rule itself
because the rule is limited to the basic framework and cannot address
every specific circumstance and nuance. And this is an example of a
very complex issue. The clarification to the Medicaid payment hold
harmless test states that a Medicaid payment will be considered to vary
based on the tax amount when the payment is conditional on the tax
payment. This provision does not prevent States that use cost-based
reimbursement methodologies from including Medicaid's share of health
care related tax costs as one of many health care provider costs that
are considered in setting individualized Medicaid reimbursement rates.
However, where a Medicaid payment is conditional on receipt of health
care related taxes, we would view the Medicaid payment to be, in part
or in full, the repayment of the health care related tax to repay the
taxes in a hold harmless arrangement rather than as a protected
reimbursement for cost of Medicaid services.
Comment: A few commenters addressed the DAB decision that CMS
acknowledged it was attempting to respond to with this regulation,
suggesting that a more appropriate response to that decision would have
been to simply clarify that the hold harmless standard applies to
situations where the benefits accrue to private pay patients rather
than to the taxpaying facilities directly.
Response: We do not believe that the commenter's suggestion would
address all of the confusion created by the Board's decision. We agree
that clarifying the rules to explain that the hold harmless standard
applies to situations where the state payments are made to third
parties would help to clarify the questions raised by the Board's
decision and we have attempted to do that in this rule. However, we do
not believe such a clarification alone would be sufficient.
F. Hold Harmless--Sec. 433.68(f)(1)--Positive Correlation
Comment: Several commenters stated that by including any positive
correlation over any amount of time, the proposed rule destroys any
standard by which a State may assess whether or not a tax based
Medicaid funding arrangement will be determined by CMS to be a hold
harmless violation. Other commenters disagreed with CMS' statement that
the current regulations related to positive correlation led to
confusion. The commenters believe that the subjective analysis proposed
will only lead to additional confusion.
Response: Our experience is that States and providers are typically
very aware of the overall character of a tax based Medicaid funding
arrangement. Moreover, it is clear that to achieve the statutory
purpose of ending hold harmless arrangements that result in shifting a
disproportionate burden to the federal government, the test must be
applied flexibly. Otherwise, financing arrangements will be structured
to meet the letter but not the underlying purpose of the statutory
limitations. This regulation is intended to further clarify the
existing hold harmless provisions and not to lead to additional
confusion.
Comment: Several commenters asserted that the test for a ``positive
correlation'' under Sec. 433.68(f)(1) is too subjective, and should
instead remain a statistical test. They expressed concern that under
the proposed test, CMS could find a positive correlation in almost any
situation.
Response: The 1993 rule does confine the statutory term ``positive
correlation'' to a test requiring mathematical certainty. The insertion
of the statistical concept suggests that a positive correlation
contemplates a positive relationship between two variables. Such a
correlation would exist, for example, where a state passes a tax on
nursing home beds that a facility is permitted to pass on to its
residents in the form of rate increases. If at or about the same time,
the state passes a grant program that pays private pay residents of the
nursing home an amount similar to the bed tax, the grant money would be
available for use to compensate the nursing facility for the tax and a
positive correlation would be found to exist between the tax and the
grant. The correlation would not be destroyed by altering one variable
over time and would not necessarily need to be measured in a
statistical sense. This has always been CMS's position with respect to
the 1993 regulations, but unfortunately the description of positive
correlation as a statistical concept in the 1993 rule created some
confusion. In retrospect, we now believe that characterizing positive
correlation as having ``the same meaning as the statistical term'' in
the 1993 rule was imprecise. The use of this language caused some
readers to view the test as requiring a mathematical certainty with
specifically measurable statistical significance over the life of the
grant and tax programs, or measured with respect to specific amounts
collected and paid out under the specific programs. Where we did impose
a mathematical test in evaluating a tax program it was clearly spelled
out in the 1993 rule, as it was with respect to the ``indirect
guarantee test'' described at page 43182 of the 1993 rule. The rule
was, however, never meant to bring
[[Page 9692]]
mathematical certainty into the positive correlation examination. We do
not consider the current rule to signal a significant change in our
analysis; rather, it clarifies our interpretation of the statutory term
``positive correlation.'' We will continue to evaluate health care
related tax programs to determine whether there is a positive
correlation with a state payment program.
G. Hold Harmless Sec. 433.68(f)(2)--Medicaid Payment Test
Comment: Many commenters argued that, by prohibiting States from
conditioning Medicaid payment on receipt of the tax, the proposed rule
would prevent the State from using the tax to reimburse providers.
These commenters stated that Congress clearly intended provider taxes
to be used for purposes of Medicaid reimbursement purposes. The
commenters noted that section 1903(w)(4) of the Social Security Act
specifies that the hold harmless provisions ``shall not prevent use of
the tax to reimburse health care providers in a class for expenditures
under this title nor preclude States from relying on such reimbursement
to justify or explain the tax in the legislative process.''
Response: We agree States can use permissible health care related
tax revenues to increase Medicaid reimbursement rates. However, section
1903(w)(4) of the Act specifies three conditions under which a State or
local government is determined to hold taxpayers harmless for their tax
costs. If any of these conditions are met the tax program would be
determined to have a hold harmless provision and the tax would be
impermissible. The final rule does not change the conditions of the
hold harmless provisions under Federal law. Consistent with these
provisions, where a Medicaid payment is conditional on receipt of
health care related taxes, we would view the Medicaid payment to be, in
part or in full, the repayment of the health care related tax to repay
the taxes in a hold harmless arrangement rather than as a protected
reimbursement for cost of Medicaid services.
Comment: Several commenters stated that by expressly 37
conditioning Medicaid payments on the tax amount, States are explicitly
explaining how the tax is being used for Medicaid reimbursement as part
of the legislative process. The commenters believe that it is
reasonable to condition payment on the approval and receipt of the tax
and to not do so would be fiscally irresponsible. The State would be
obligated to make payments without having a funding source to finance
them and without conditioning States would not be able to adopt tax
programs. Other commenters noted that health care providers are
reluctant to support taxes unless there is an explicit assurance that
the revenues from the taxes will be dedicated to increasing Medicaid
payments and that State legislatures are reluctant to increase Medicaid
liabilities with the ability to make them contingent on the funding
source.
Response: There is a distinction between using health care related
tax revenues to support Medicaid payments and specifically guaranteeing
repayment of some or all of the tax amount or otherwise ensuring a
direct correlation between payments to taxpayers and the amount of
their taxes. States have and continue to maintain the ability to
justify the imposition of a health care related tax by indicating
through the State legislative process that proceeds from the health
care related tax will be used to increase Medicaid reimbursement and
that such funding must be approved by CMS. However, the statute is very
clear that health care related taxes cannot contain hold harmless
arrangements and any failure to comply with any of the three hold
harmless ``tests'' would render a health care related tax
impermissible. There is a distinct difference between explaining a
health care related tax and its purposes through the legislative
process and extending conditional guarantees to provider taxpayers.
States must ensure that no payment is conditioned upon receipt of a
health care related tax payment.
Comment: A few commenters requested that CMS clarify preamble
language related to State use of tax proceeds and federal match to
increase Medicaid rates in the form of Medicaid supplemental payments.
The commenters believe that this should not prohibit States from using
tax proceeds and federal match to increase Medicaid rates in the form
of Medicaid per diem add-ons or rate supplements.
Response: Section 1903(w)(4) expressly provides that States may use
permissible tax revenues to fund provider payments for covered services
furnished to eligible individuals. This provision does not authorize
States to use tax revenues for a hold harmless arrangement that
effectively repays provider taxpayers. In other words, the payment
methodology related to such increases to Medicaid reimbursement rates
must be designed in a manner that recognizes the volume or nature of
the covered services provided to Medicaid individuals, and cannot be
related simply to the amount of tax proceeds.
Comment: Several commenters disagreed with any suggestion that a
Medicaid payment increase funded by tax revenue is necessarily
uneconomical, because the funding source of the payment is irrelevant
to rate development. The commenters stated that Congress rejected the
position that, because provider taxes reduced actual expenditures made
by the State, the amount of the provider tax should be deducted from
total State spending so that only ``real'' or ``net'' State
expenditures would be matched. One commenter stated that the proposed
rule would interfere with permissible taxation by presupposing that
rates explicitly supported by tax revenue are too high and therefore
not economical.
Response: These commenters appear to have misread the preamble of
the proposed rule. We agree that States may collect permissible health
care related taxes, and may use those tax revenues as a source of non-
federal share funding for Medicaid payments to health care providers.
Our specific concern is when the Medicaid payments are conditional on
payment of the taxes. In that instance, the Medicaid payment is not
linked to any rate-setting determination based on the cost or volume of
services. Instead, the Medicaid payment is in the nature of a hold
harmless arrangement to return all or part of the tax liability to the
taxpayer. We are clarifying the Medicaid payment test to provide that a
Medicaid payment will be considered to vary based on the tax amount
when the payment is conditional on the tax payment. This clarification
would only affect States that seek to use rates that are based on the
receipt of provider taxes rather than on overall provider cost. In
other words, the final regulation rule would limit the ability of
States to expressly condition payment rates on tax receipts rather than
on a process that determines rates that are consistent with efficiency,
economy and quality of care in compliance with section 1902(a)(30)(A)
of the Act.
Comment: A few commenters disagreed with the definition of enhanced
Medicaid payment as a payment for which any branch of government has
indicated that the payment can be reduced or eliminated if the provider
tax is discontinued. The commenters were concerned that CMS is
asserting that this would represent a structural repayment of the tax
and violates hold harmless provisions. The commenters disagreed with
this position.
Response: The phrase ``enhanced Medicaid payments'' relates to the
second prong of the indirect hold harmless test (``75/75 test''). This
test
[[Page 9693]]
stipulates that if a health care related tax exceeds the regulatory
percentage threshold, CMS would consider a hold harmless to exist if 75
percent or more of the taxpayers in the class receive 75 percent or
more of their total tax back in enhanced Medicaid payments or other
State payments. We clarified that if a State ever had to provide a
demonstration for purposes of the ``75/75 test'' we may consider any
amount that any branch of the State, including legislative and
executive branch, has indicated could be subject to reduction in the
absence of provider tax revenues as an enhanced Medicaid payment. This
comparison is between Medicaid payments and tax costs and we were not
asserting in this instance that this would be a structural repayment.
We were clarifying that, for purposes of the ``75/75 test'', payments
which would no longer be provided if the tax funding source were
eliminated, would be considered enhanced Medicaid payments, even if the
State did not characterize them as such.
Comment: Several commenters stated that eliminating conditional
Medicaid payments would undermine provider support for health care
related taxes. The commenters asserted that assurances that provider
tax revenue will be used for a specific category of Medicaid
expenditures is not equivalent to holding taxpayers harmless for the
cost of the tax.
Response: States have and continue to maintain the ability to
justify the imposition of a health care related tax by indicating
through the State legislative process that proceeds from the health
care related tax will be used to increase Medicaid reimbursement and
that such funding must be approved by CMS. However, the statute is very
clear that health care related taxes cannot contain hold harmless
arrangements and any failure to comply with any of the three hold
harmless ``tests'' would render a health care related tax
impermissible. There is a distinct difference between explaining a
health care related tax and its purposes through the legislative
process and extending conditional guarantees to repay provider
taxpayers. We recognize that high volume Medicaid providers could
benefit from a health care related tax that funds a Medicaid rate
increase, however, States must ensure that no payment is conditioned
upon receipt of a health care related tax payment.
Comment: Several commenters stated that the definitions of ``tax
amount'' and ``payment amount'' in the proposed rule are too broad. One
commenter argued that the shift in terminology in Sec. 433.68(f)(2)
from ``amount of the total tax payment'' to ``tax amount'' represents a
significant departure from the statutory and prior regulatory language.
Response: As explained in the preamble to the proposed rule, the
change in terminology is not a substantive change from what was
intended in the original 1993 rule. We are using the terms ``tax
amount'' and ``payment amount'' throughout the new rule in an effort to
be consistent. We have found that the use of differing terms in the
various sections of the 1993 rule has led to some confusion.
Accordingly, we consolidated the terms ``total tax cost,'' ``total tax
payment,'' ``amount of the payment,'' ``amount of such tax'' into the
terms ``tax amount'' and ``payment amount'' to be used in each section
of the hold harmless rule. We explained our reasoning at more length in
the proposed rule and believe that reasoning remains valid (72 FR
13729, 13730). This does not represent a significant departure from
prior statutory or regulatory language. It clarifies that we are not
looking at the total amount of the tax payment received by the state,
but we will be looking at the tax program as a whole, including whether
taxpayers are being held harmless for increments of the tax. With
respect to subsection (f)(2) this means that we will look at whether
any portion of the Medicaid payments made by the state to providers,
varies based upon the health care related tax levied upon the
providers. The ``tax amount'' is the amount of the tax levied upon the
provider (either directly, or indirectly).
Comment: Several commenters stated that the phrase ``including
where Medicaid payment is conditional on receipt of the tax amount'' is
problematic. Some commenters noted that the proposed language would
appear to have the effect of prohibiting States from enforcing tax
obligations on delinquent providers through intercept of Medicaid
payments. Another commenter expressed concern that this would prohibit
States from requiring overdue taxes as a condition for payments due to
a taxpayer. Other commenters stated that it may result in situations
where health provider taxes that are statutorily established in a
manner that complies with the broad based and uniformity requirements
of the statue cannot be enforced.
Response: This regulation does not prevent State enforcement of the
collection of health care related taxes. It is the State's obligation
to ensure that any health care related tax program is collected in a
manner consistent with legislation enacting the health care related tax
program and any approved waiver of the broad-based and/or uniformity
requirements. To suggest that the phrase ``including where Medicaid
payment is conditional on receipt of the tax amount'' would prohibit
States from enforcing tax obligations on delinquent health care
providers is erroneous. If States do not enforce the proper collection
of the health care related tax, the State is at risk of violating
statutory broad-based and/or uniformity requirements which could render
the entire tax program and its collections impermissible.
Comment: A few commenters specified that the word ``total'' is
critical within the Medicaid payment test because a Medicaid payment
that varies based on the Medicaid portion of the tax is permissible.
The commenters stipulated that only a Medicaid payment that varies
based on the total provider tax amounts constitutes a hold harmless.
Other commenters stated that the portion of a provider's health care-
related tax payment attributable to Medicaid services is an allowable
cost, and Medicaid reimbursement may be furnished for it. The
commenters recommended that the word ``total'' be restored.
Response: The regulation specifies that a hold harmless arrangement
exists if all or any portion of the Medicaid payment varies based only
on the amount of the tax payment. The removal of the word total does
not represent a significant departure from prior statutory or
regulatory language. As explained in the preamble to the proposed rule,
the change in terminology is not a substantive change from what was
intended in the original 1993 rule. We are using the terms ``tax
amount'' and ``payment amount'' throughout the new rule in an effort to
be consistent. We have found that the use of differing terms in the
various sections of the 1993 rule has led to some confusion.
Accordingly, we consolidated the terms ``total tax cost,'' ``total tax
payment,'' ``amount of the payment,'' ``amount of such tax'' into the
terms ``tax amount'' and ``payment amount'' to be used in each section
of the hold harmless rule. We explained our reasoning at more length in
the proposed rule and believe that reasoning remains valid (72 FR
13729, 13730). This was intended to clarify that we are not looking
simply at the total amount of the tax payment received by the state,
but will be looking at the tax program as a whole, including whether
tax payers are being held harmless for increments of the tax.
Comment: One commenter suggested that supplemental payments should
be permitted to be paid to those providers
[[Page 9694]]
who are providing Medicaid services based on receipt of provider taxes.
Response: Generally, States can collect permissible taxes and use
such tax receipts as the non-federal share to make supplemental
payments for the provision of Medicaid services. However, a hold
harmless arrangement exists when States seek to use reimbursement rates
that are based solely on the receipt of health care related taxes and
effectively repay the taxpayer (such as supplemental Medicaid payments
conditioned on receipt of a health care related tax payment), rather
than on overall health care provider costs. The clarifications in this
rule are necessary to ensure that Medicaid payments are not made simply
to repay providers for the cost of the health care related tax beyond
Medicaid's allowable share, but also to ensure the integrity of the
development of sound Medicaid payment rates in compliance with the
requirements of section 1902(a)(30) of the Act.
H. Hold Harmless 433.68(f)(3)--Guarantee Test
Comment: Numerous commenters asked for clarification of the
proposed interpretation of the phrase ``direct and indirect'' in the
guarantee test, and should confirm that use of provider tax receipts to
increase Medicaid rates for or to enhance the Medicaid rate methodology
applicable to the taxed provider class is not prohibited.
Response: The clarification of the guarantee test is meant to
specify that a State can provide a direct or indirect guarantee through
a direct or indirect payment. A direct guarantee will be found when a
State payment is made available to a taxpayer or a party related to the
taxpayer with the reasonable expectation that the payment would result
in the taxpayer being held harmless for any part of the tax (through
direct or indirect payments). A direct guarantee does not need to be an
explicit promise or assurance of payment. Instead, the element
necessary to constitute a direct guarantee is the provision for payment
by State statute, regulation, or policy. An indirect guarantee is
distinct from a direct guarantee in that such guarantee is initially
measured by a percentage threshold that limits tax collections to 5.5
percent of net patient revenue attributable to the assessed service.
States collecting a tax in excess of 5.5 percent of assessed patient
service revenue must perform the second prong of the hold harmless test
to demonstrate permissibility.
Comment: A few commenters expressed concern that CMS has taken too
broad a view in stating that monies ``controlled or influenced by the
state'' will be considered in applying the guarantee test in Sec.
433.68(f)(1).
Response: The language of concern to these commenters appears in
the preamble to the proposed rule. In the preamble we provided an
illustration of how a health care related tax and grant program could
be found to violate both the positive correlation test and the
guarantee test. We believe that discussion accurately reflects existing
statutory provisions governing health care related taxes. The specific
language of concern to the commenters appears in a discussion of
problematic indirect payments that States may make to taxpayers. The
preamble notes that ``money is fungible and, as long as the payment is
from a source controlled or influenced by the State, it will be
considered in determining whether it has been made available for the
tax.'' In evaluating whether the state has made monies available to
hold providers harmless for any portion of a health care related tax,
it makes little difference which part of the state treasury makes the
funds available to the taxpayer, or if the state monies are funneled
through some other third party, because all State monies are fungible.
For example, it would be impermissible for the state to impose a
nursing home bed tax to be paid to the state Medicaid agency and have
the Governor's office control a separate grant payment designed to
reimburse private pay residents for the amount of the tax passed on to
them by the nursing homes. Even though the state may argue these are
separate funding sources, CMS would consider all of the money state
money and would consider the positive correlation between the two
programs a violation of the hold harmless provisions. Similarly, States
will not be permitted to recycle monies through third parties, by
making payments to such third parties and requiring that the money be
used to reimburse taxpayers for any portion of their health care
related tax. This is the point the preamble was trying to address when
it embraced payments ``influenced by the state.'' However, we agree
with the commenters that ``influenced by the state'' is too broad a
term. We believe ``controlled or directed by the state'' is a more
accurate description of the types of payments that will be considered
in evaluating whether an impermissible hold harmless arrangement
exists.
Comment: Several commenters stated that the term ``reasonable
expectation'' under the guarantee test in Sec. 433.68(f)(3) is too
broad and/or subjective.
Response: In the preamble to the proposed rule we stated that ``A
direct guarantee will be found when a state payment is made available
to a taxpayer or a party related to a taxpayer (for example as a
nursing home resident is related to a nursing home), in the reasonable
expectation that the payment would result in the taxpayer being held
harmless for any part of the tax'' (72 FR 13730). We chose to use the
term reasonable expectation because we recognized that state laws were
rarely overt in requiring that state payments be used to hold taxpayers
harmless. For example, state laws providing grants to nursing home
residents who incur increased rates as a result of bed taxes on nursing
homes, rarely required the residents receiving the grants to actually
use the money to pay the increased nursing home fees. Accordingly,
arguments have been made that such grants do not actually guarantee to
hold the nursing homes harmless for the tax. We disagree. Because the
residents must pay the increased rates passed on to them as a result of
the tax and because the state has made money available to those
residents to pay those increased rates, it is reasonable to expect that
the payments going to the nursing home residents will promptly be sent
to the nursing home as resident fee payments. This would result in a
hold harmless for the nursing home. The only way to avoid this
conclusion would be for the resident to leave the facility and/or not
pay the rate increase. Therefore, we do not believe the use of the term
reasonable expectation is overly broad or vague.
Comment: Several commenters stated that collection of unpaid
provider taxes by withholding amounts of Medicaid payments due under
the new rule would constitute a hold harmless because it would cause
the Medicaid payment to be contingent on the payment of the tax.
Response: Withholding Medicaid payments to health care providers
who have not paid their taxes would not constitute a hold harmless
arrangement. This is a matter of State enforcement. States are, by
themselves, obligated to ensure that any health care related tax is
collected in a manner consistent with Federal law, authorizing State
legislation and if applicable any CMS approved waiver of the broad-
based and/or uniformity requirements. Typically, such enforcement
provisions are authorized through the health care related tax's
enacting legislation and are identified as enforcement collection
provisions and/or penalties.
Comment: A few commenters disagreed with CMS' assertion in the
[[Page 9695]]
proposed rule that the direct and indirect tests differ on the kind of
payment involved. The commenters stated that there is no basis for this
distinction.
Response: A direct guarantee will be found when a State payment is
made available to a taxpayer or a party related to the taxpayer in the
reasonable expectation that the payment would result in the taxpayer
being held harmless for any part of the tax. An indirect guarantee is
distinct from a direct guarantee in that such guarantee is initially
measured by a percentage threshold that limits tax collection to 5.5
percent of patient revenue attributable to the assessed service. States
collecting a tax in excess of 5.5 percent of assessed patient service
revenue must perform the second prong of the hold harmless test to
demonstrate permissibility.
Comment: A few commenters indicated that they do not object to CMS'
proposal to the direct guarantee test to clarify that payment to a
taxpayer may be indirect. Nor do they disagree with CMS that, under the
amended language, a grant or benefit to private pay patients or
residents could be considered an indirect payment to the taxpayer for
purposes of the ``direct guarantee.''
Response: We appreciate the support to ensure the fiscal integrity
of the Medicaid program. Clarifying our current regulations helps us
achieve this goal.
I. Hold Harmless 433.68(f)(3)(i)--Indirect Guarantee
Comment: One commenter stated that, in implementing the indirect
percentage threshold changes as mandated by Congress, CMS went beyond
the legislative directive by further amending the regulatory text to
specify that the percentage threshold applied to net operating
revenues. The commenter argued CMS' position that the safe harbor
percentages are restricted to net revenue is not supported in the
legislative history. The commenter believes that States should be
permitted to interpret the phrase ``revenue received by providers'' as
either gross or net revenue.
Response: The phrase ``revenues received by the taxpayer,'' has
been interpreted by CMS to be, the net patient service revenue,
received by the health care provider. This would include all revenues
received from all payers for providing the particular service that is
assessed by the State and would not include revenues unrelated to the
service being assessed. In addition, the safe harbor percentage
originally created by the 1992 interim rule was never addressed in the
statutory language and therefore would not be addressed in any
legislative history. However, the legislative history clearly
demonstrates that Congress requires CMS to evaluate the permissibility
of a health care related tax on a per service basis, as the 1991 law
separately identified permissible classes of health care items or
services. Finally, we believe that the phrase ``net operating revenue''
used in the regulatory text may have caused confusion. We have altered
the final regulation to refer to net patient service revenue.
Comment: One commenter specified that under the proposed broad
interpretation of the Medicaid payment hold harmless provision, CMS can
find a violation in any situation where provider tax revenues are used
to make Medicaid payments to taxed providers. The commenter argued that
the impact of this results in the omission of the ``indirect guarantee
test'', whose importance was affirmed by Congress in the Tax Relief and
Health Care Act of 2006.
Response: As we have mentioned earlier, this regulation carries out
the purposes originally outlined in the Medicaid Voluntary Contribution
and Provider Specific Tax Amendments of 1991 (Pub. L. 102-234) and the
implementing regulations, by prohibiting FFP for health care related
taxes where the State has implemented a hold harmless provision. It has
not been our intent to expand the test for determining when an
impermissible hold harmless arrangement exists beyond the original
purposes underlying the 1993 rules. We are not aware of any State
health care related tax programs that would have been permissible under
the Secretary's prior interpretation of the rules but are no longer
permissible under this regulation. Therefore, we do not agree that we
have nullified the indirect guarantee test that the commenter argues
was reaffirmed by Congress.
IV. Provisions of the Final Regulations
As a result of our review of the comments we received during the
public comment period, as discussed in section III of this preamble, we
are making the following revisions to the proposed regulation published
on January 18, 2007.
Section 433.56 Classes of Health Care Services and Providers Defined
We have modified the regulation at Sec. 433.56(a)(4) to return to
the original regulatory language. The regulation has been revised to
re-incorporate that similar services furnished by community-based
residences for the mentally retarded, under a waiver under section
1915(c) of the Act, in a State in which, as of December 24, 1992, at
least 85 percent of such facilities were classified as ICF/MRs prior to
the grant of the waiver can be included in the permissible class of
health care items or services. CMS has modified the regulation to
recognize that one State qualifies under this narrow exception.
Section 433.68 Permissible Health Care-Related Taxes
We have modified the phrase ``net operating revenues'' in Sec.
433.68(f)(3)(i) to more accurately reflect that the base to which tax
collections are applied for purposes of the indirect hold harmless
threshold (i.e., net patient service revenue). Further, in response to
comments we have clarified that revenues received by the taxpayer
refers to the net patient revenue attributable to the assessed
permissible class of health care items or services.
To increase clarity and ensure implementation of the governing
statutory provision, we are also removing Sec. 433.68(f)(3)(ii) as a
technical conforming action. This section is outdated and no longer has
any applicability.
V. Collection of Information Requirements
This document does not impose information collection and
recordkeeping requirements. Consequently, it need not be reviewed by
the Office of Management and Budget under the authority of the
Paperwork Reduction Act of 1995 (44 U.S.C. 35.)
VI. Regulatory Impact Analysis
A. Overall Impact
We have examined the impact of this regulation as required by
Executive Order 12866 (September 1993, Regulatory Planning and Review),
the Regulatory Flexibility Act (RFA) (September 19, 1980, Pub. L. 96-
354), section 1102(b) of the Social Security Act, the Unfunded Mandates
Reform Act of 1995 (Pub. L. 104-4), Executive Order 13132 on
Federalism, and the Congressional Review Act (5 U.S.C. 804(2)).
Executive Order 12866 (as amended by Executive Order 13258, which
merely reassigns responsibility of duties) directs agencies to assess
all costs and benefits of available regulatory alternatives and, if
regulation is necessary, to select regulatory
[[Page 9696]]
approaches that maximize net benefits (including potential economic,
environmental, public health and safety effects, distributive impacts,
and equity). A regulatory impact analysis (RIA) must be prepared for
major rules with economically significant effects ($100 million or more
in any 1 year). This regulation will surpass the economic threshold and
is considered a major rule. This rule is estimated to reduce Federal
Medicaid outlays by $85 million in FY 2008 and by $115 million per year
in FY 2009 through FY 2011.
The RFA requires agencies to analyze options for regulatory relief
of small businesses. For purposes of the RFA, small entities include
small businesses, nonprofit organizations, and small governmental
jurisdictions. Most hospitals and most other providers and suppliers
are small entities, either by nonprofit status or by having revenues of
$6 million to $29 million in any 1 year. Individuals and States are not
included in the definition of a small entity. We are not preparing an
analysis for the RFA because the regulation will not have a direct
impact on small entities. In this case the regulation directly affects
payments the States receive from the Federal government and the impact
on health care facilities is categorized as secondary impact.
While the impact on health care facilities is secondary, we proceed
to discuss the potential impact on small entities. First, the reduced
health care related tax collection threshold under this regulation will
help alleviate tax burdens on small health care facilities, to the
extent they were subject to a health care-related tax. If States choose
to maintain reimbursement rates, small health care facilities may
receive higher net Medicaid reimbursement in light of the reduced tax
burden. However, States may be unwilling to maintain reimbursement
rates without the full revenue from the health care-related tax to
contribute to the non-Federal share. If States choose to reduce
Medicaid reimbursement rates to small health care facilities, this
could result in lower net Medicaid reimbursement even after accounting
for a reduction in the tax burden.
Since we are uncertain how States will alter their Medicaid
reimbursements in response to the reduced health care related tax
collection threshold, we cannot provide an exact and quantifiable
impact on such small entities. We did not receive any quantifiable
information during the public comment process to determine any further
detailed impact. Commenters did not raise issue with the collection
threshold reduction. Nor did the commenters indicate how States will
act in response to such reduction in available health care related tax
revenue. It is important to note that not all health care related tax
programs will be impacted. Only those health care related taxes that
are currently being imposed at a rate in excess of 5.5 percent of net
patient service revenue will be directly impacted.
In addition, section 1102(b) of the Act requires us to prepare a
regulatory impact analysis if a regulation may have a direct impact on
the operations of a substantial number of small rural hospitals. This
analysis must conform to the provisions of section 604 of the RFA. For
purposes of section 1102(b) of the Act, we define a small rural
hospital as a hospital that is located outside of a Metropolitan
Statistical Area and has fewer than 100 beds. We are not preparing an
analysis for section 1102(b) of the Act because we have determined that
this regulation will not have a direct impact on the operations of a
substantial number of small rural hospitals.
Section 202 of the Unfunded Mandates Reform Act of 1995 also
requires that agencies assess anticipated costs and benefits before
issuing any regulation whose mandates require spending in any 1 year of
$100 million in 1995 dollars, updated annually for inflation. That
threshold level is currently approximately $120 million. This
regulation will not result in expenditure in any 1 year by State,
local, or tribal governments, in the aggregate, or by the private
sector, of $120 million.
Executive Order 13132 establishes certain requirements that an
agency must meet when it promulgates a final regulation that imposes
substantial direct requirement costs on State and local governments,
preempts State law, or otherwise has Federalism implications. While
this regulation would reduce the collection threshold for permissible
health care related taxes from 6 percent of the net patient service
revenue attributable to the assessed permissible class of health care
items or services to 5.5 percent of the net patient service revenue,
this change is required by section 403 of the Tax Relief and Health
Care Act of 2006. This section of the statute was self-implementing on
December 20, 2006; however, this rulemaking is necessary to include the
reduction in the regulatory text, therefore ensuring consistency with
applicable law and thus minimizing any confusion. Furthermore, we do
not believe the discretionary requirements put in place by this
rulemaking will impose substantial direct requirements or costs on
State and local governments.
B. Anticipated Effects
Provider Tax Reform
1. Effects on State Medicaid Programs
Estimates of the impact of lowering the maximum collection
threshold for permissible health care related taxes, fees, and
assessments were derived from Medicaid financial management reports on
State receipts from these programs (form CMS-64.11). Since we do not
believe that all States report completely their tax receipts from
health care-related taxes on the form CMS-64.11, we bolstered our
estimates by also analyzing information reported by some States as part
of their request for waiver of the broad-based and/or uniformity
requirements. These requests include estimated total tax collections
and total net revenues received by taxpayers applicable to a
permissible class of health care services. From this available
information, we identified 15 States whose receipts as of the date of
the reports are believed to equal the maximum threshold of 6 percent of
net patient service revenue. In accordance with the new statutory
language to reduce the maximum threshold from 6 to 5.5 percent, FFP
corresponding to these receipts would be reduced by 8.33 percent [(1-
5.5/6.0) x 100]. As described below, there are a number of avenues
available for States to address these reductions. Accordingly, in
estimating the potential Federal savings, we applied a behavioral
offset of 50 percent to the savings calculated from reported data as
described above. In accordance with the statute, savings were estimated
only for portions of fiscal years beginning January 1, 2008 and ending
September 30, 2011.
States have a number of options open to them for addressing the
reduction in FFP. In order to maintain existing reimbursement rates
funded by a health care related tax in excess of the 5.5 percent
threshold, they can restructure State spending and shift funds between
programs. This could result in loss of State funding for other
programs. States may also be able to raise funds through increases in
other forms of generally applicable tax revenue increases. This could
raise tax costs for other taxpaying entities within States. Finally,
States, as a last resort, can reduce reimbursement to the taxpaying
health care providers.
We are uncertain which options States may employ to address this
change. We did not receive any further quantifiable information through
the public comment process that would indicate which option States are
likely
[[Page 9697]]
to choose in response to such reduction in available health care
related tax revenue.
2. Effects on Other Providers
The reduced tax limit in this rule will help alleviate health care
related tax burdens on health care providers for obligations to the
Medicaid program that are otherwise the responsibility of the States.
However, if States choose to reduce reimbursement rates to health care
providers, this could result in lower net Medicaid reimbursement for
the health care provider even after accounting for reduction in the
health care related tax burden. On the other hand, if States choose to
maintain reimbursement rates by finding other non-Federal share sources
to support the Medicaid reimbursement rates, health care providers may
receive higher net Medicaid reimbursement in light of the reduced
health care related tax burden.
The new statutory language reducing the maximum threshold from 6 to
5.5 percent for the period of January 1, 2008 through September 30,
2011 is estimated to reduce Federal Medicaid outlays by $85 million in
FY 2008 and by $115 million per year in FY 2009 through FY 2011. These
savings will not be realized in 2012 because the threshold reverts back
to 6 percent after September 30, 2011.
Table A.--Estimated Reduction in Federal Medicaid Outlays Resulting From the Provider Tax Reform Proposal Being Implemented by CMS-2275-F
--------------------------------------------------------------------------------------------------------------------------------------------------------
Reduction in Federal Medicaid Outlays for fiscal years 2008-2012 (In $ million)
-----------------------------------------------------------------------------------------------
2008 2009 2010 2011 2012 Total
--------------------------------------------------------------------------------------------------------------------------------------------------------
Provider Tax Reform..................................... 85 115 115 115 0 430
3% discount rate........................................ 83 108 105 102 0 398
7% discount rate........................................ 79 100 94 88 0 361
--------------------------------------------------------------------------------------------------------------------------------------------------------
C. Alternatives Considered
In developing this regulation the following alternatives were
considered. We considered reducing the regulatory collection threshold
to 3 percent because we have noticed a recent trend in States' efforts
to maximize non-Federal share funding opportunities under current
Medicaid law through taxation of health care providers.
The result has been that the Federal government is providing
matching funds on Medicaid rate increases that are funded without
additional State dollars but instead, with revenues collected from
taxes on health care providers. This shift in fiscal responsibilities
is typically accompanied by creative payment mechanisms that
effectively place a disproportionate burden on the Medicaid program
relative to other payers. In this way, some States are avoiding their
payment responsibilities to the Medicaid program by shifting their
share of the increased Medicaid payment rate obligations to the same
health care providers serving Medicaid beneficiaries.
The current trend in States' approach to taxing health care
providers appears to start with a determination of the maximum amount
of health care-related tax revenue that can be collected from health
care providers. We have seen this particularly in State health care-
related tax programs targeting high Medicaid utilized services solely
as the basis for increasing Medicaid rates to those same providers.
States appear to be exercising their ability under the law to request
waivers of the broad based and/or uniformity requirements of the health
care-related tax law in an effort to minimize the tax burden on
facilities that furnish little to no services to Medicaid patients.
Although we would only approve such a waiver request within the
allowable regulatory standards, States requesting the waivers continue
to propose taxes that collect the maximum 6 percent limit and vary the
rate of tax to minimize the tax burden on non-Medicaid facilities
within the slightest margin allowable under current regulations. Most
waiver requests are initially submitted applicable to a tax structure
that is inconsistent with the Federal statute and regulations. This
requires CMS to provide ongoing feedback and assistance to States.
States ultimately deviate from their initial tax structure until they
are able to reach an optimal tax structure that enables them to gain
approval while minimizing the non-Medicaid tax burden.
Through our review of these practices, we have also noticed that
many States are applying the current statutory and regulatory authority
that permits the exclusion of Medicare revenue from a health care-
related tax, which effectively raises the rate of tax on only the
Medicaid revenues and commercial/private pay revenues above the
aggregate 6 percent limit (measured on all payers' revenues). We have
also seen an increase in the tax revenues collected through our
examination of the revenues reported by States on the CMS 64.11A. Based
on a review of quarterly expenditures, States reported the collection
of over $2.2 billion in tax revenues from health care providers.
However, since the Tax Relief and Health Care Act of 2006 reduced
the regulatory threshold to 5.5 percent, none of the above mentioned
alternatives were taken.
With respect to the other changes contained in this final rule, we
considered and rejected a possible exception for already approved
health care-related tax programs. Such an exception would not be
uniform and would not achieve the objective of ensuring that health
care-related taxes did not effectively shift a disproportionate burden
to the Federal government. Because these clarifications reflect the
understanding of permissible classes and how the hold harmless
provisions should apply that CMS has been applying in ongoing reviews,
CMS is not aware of any approved tax programs that is not in compliance
with the final rule.
D. Accounting Statement and Table
As required by OMB Circular A-4 (available at http://
www.whitehouse.gov/omb/circulars/a004/a-4.pdf), in the table below, we
have prepared an accounting statement showing the classification of the
expenditures associated with the provisions of this final regulation.
This table provides our best estimate of the reduction in Federal
Medicaid outlays for the years 2008 through 2012 as a result of the
changes presented in this final regulation. This regulation only
affects transfer payments between the Federal government and State
governments.
[[Page 9698]]
Table Number B.--Accounting Statement: Classification of Estimated Reduction in Medicaid Outlays From FY 2008 to
FY 2012
[In millions]
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
Category Transfers
----------------------------------------------------------------------------------------------------------------
Annualized monetized transfers.......................... 3% Units discount rate 7% Units discount rate
$87.0 $88.0
----------------------------------------------------------------------------------------------------------------
From whom to whom?...................................... States to Federal Government
----------------------------------------------------------------------------------------------------------------
E. Conclusion
Due to the reduction in the statutory language lowering the maximum
threshold from 6 to 5.5 percent this rule is estimated to reduce
Federal Medicaid outlays by $85 million in FY 2008 and by $115 million
per year in FY 2009 through FY 2011.
For these reasons, we are not preparing analysis for either the RFA
or section 1102(b) of the Act because we have determined that this
regulation will not have a direct significant economic impact on a
substantial number of small entities or a direct significant impact on
the operations of a substantial number of small rural hospitals.
In accordance with the provisions of Executive Order 12866, this
regulation was reviewed by the Office of Management and Budget.
List of Subjects in 42 CFR Part 433
Administrative practice and procedure, Child support, Claims, Grant
programs-health, Medicaid, Reporting and recordkeeping requirements.
0
For the reasons set forth in the preamble, the Centers for Medicare &
Medicaid Services amends 42 CFR chapter IV as follows:
PART 433--STATE FISCAL ADMINISTRATION
0
1. The authority citation for part 433 continues to read as follows:
Authority: Sections 1902(a)(2), 1903(a) and 1903(w) of the
Social Security Act (42 U.S.C. 1302).
Subpart B--General Administrative Requirements State Financial
Participation
0
2. Section 433.54 is amended by revising paragraph (c) to read as
follows:
Sec. 433.54 Bona fide donations.
* * * * *
(c) A hold harmless practice exists if any of the following
applies:
(1) The State (or other unit of government) provides for a direct
or indirect non-Medicaid payment to those providers or others making,
or responsible for, the donation, and the payment amount is positively
correlated to the donation. A positive correlation includes any
positive relationship between these variables, even if not consistent
over time.
(2) All or any portion of the Medicaid payment to the donor,
provider class, or related entity, varies based only on the amount of
the donation, including where Medicaid payment is conditional on
receipt of the donation.
(3) The State (or other unit of government) receiving the donation
provides for any direct or indirect payment, offset, or waiver such
that the provision of that payment, offset, or waiver directly or
indirectly guarantees to return any portion of the donation to the
provider (or other parties responsible for the donation).
* * * * *
0
3. Section 433.56 is amended by--
A. Republishing the introductory text to paragraph (a).
0
B. Revising paragraph (a)(4).
0
C. Revising paragraph (a)(8).
The revisions read as follow:
Sec. 433.56 Classes of health care services and providers defined.
(a) For purposes of this subpart, each of the following will be
considered as a separate class of health care items or services:
* * * * *
(4) Intermediate care facility services for the mentally retarded,
and similar services furnished by community-based residences for the
mentally retarded, under a waiver under section 1915(c) of the Act, in
a State in which, as of December 24, 1992, at least 85 percent of such
facilities were classified as ICF/MRs prior to the grant of the waiver;
* * * * *
(8) Services of managed care organizations (including health
maintenance organizations, preferred provider organizations);
* * * * *
Sec. 433.57 [Amended]
0
4. Section Sec. 433.57 is amended by--
0
A. Removing paragraph (a).
0
B. Redesignating existing paragraphs (b) and (c) as paragraphs (a) and
(b), respectively.
Sec. 433.58 [Removed and reserved]
0
5. Section 433.58 is removed and reserved.
Sec. 433.60 [Removed and reserved]
0
6. Section 433.60 is removed and reserved.
0
7. Section 433.66 is amended by--
0
A. Revising the section heading.
0
B. Revising paragraph (a).
The revisions read as follows:
Sec. 433.66 Permissible provider-related donations.
(a) General rule. (1) Except as specified in paragraph (a)(2) of
this section, a State may receive revenues from provider-related
donations without a reduction in FFP, only in accordance with the
requirements of this section.
(2) The provisions of this section relating to provider-related
donations for outstationed eligibility workers are effective on October
1, 1992.
* * * * *
0
8. Section 433.67 is amended by revising paragraph (a)(2) to read as
follows:
Sec. 433.67 Limitations on level of FFP for permissible provider-
related donations.
(a) * * *
(2) Limitations on donations for outstationed eligibility workers.
Effective October 1, 1992, the maximum amount of provider-related
donations for outstationed eligibility workers, as described in Sec.
433.66(b)(2), that a State may receive without a reduction in FFP may
not exceed 10 percent of a State's medical assistance administrative
costs (both the Federal and State share), excluding the costs of family
planning activities. The 10 percent limit for provider-related
donations for outstationed eligibility workers is not included in the
limit in effect through September 30, 1995, for health care-related
taxes as described in Sec. 433.70.
* * * * *
0
9. Section 433.68 is amended by--
0
A. Revising the section heading.
0
B. Revising paragraph (a).
[[Page 9699]]
0
C. Republishing paragraph (f) introductory text.
0
D. Revising paragraphs (f)(1), (f)(2), (f)(3) introductory text, and
(f)(3)(i).
0
E. Removing and reserving paragraph (f)(3)(ii).
0
The revisions read as follows:
Sec. 433.68 Permissible health care-related taxes.
(a) General rule. A State may receive health care-related taxes,
without a reduction in FFP, only in accordance with the requirements of
this section.
* * * * *
(f) Hold harmless. A taxpayer will be considered to be held
harmless under a tax program if any of the following conditions
applies:
(1) The State (or other unit of government) imposing the tax
provides for a direct or indirect non-Medicaid payment to those
providers or others paying the tax and the payment amount is positively
correlated to either the tax amount or to the difference between the
Medicaid payment and the tax amount. A positive correlation includes
any positive relationship between these variables, even if not
consistent over time.
(2) All or any portion of the Medicaid payment to the taxpayer
varies based only on the tax amount, including where Medicaid payment
is conditional on receipt of the tax amount.
(3) The State (or other unit of government) imposing the tax
provides for any direct or indirect payment, offset, or waiver such
that the provision of that payment, offset, or waiver directly or
indirectly guarantees to hold taxpayers harmless for all or any portion
of the tax amount.
(i)(A) An indirect guarantee will be determined to exist under a
two prong ``guarantee'' test. If the health care-related tax or taxes
on each health care class are applied at a rate that produces revenues
less than or equal to 6 percent of the revenues received by the
taxpayer, the tax or taxes are permissible under this test. The phrase
``revenues received by the taxpayer'' refers to the net patient revenue
attributable to the assessed permissible class of health care items or
services. However, for the period of January 1, 2008 through September
30, 2011, the applicable percentage of net patient service revenue is
5.5 percent. Compliance in State fiscal year 2008 will be evaluated
from January 1, 2008 through the last day of State fiscal year 2008.
Beginning with State fiscal year 2009 the 5.5 percent tax collection
will be measured on an annual State fiscal year basis.
(B) When the tax or taxes produce revenues in excess of the
applicable percentage of the revenue received by the taxpayer, CMS will
consider an indirect hold harmless provision to exist if 75 percent or
more of the taxpayers in the class receive 75 percent or more of their
total tax costs back in enhanced Medicaid payments or other State
payments. The second prong of the indirect hold harmless test is
applied in the aggregate to all health care taxes applied to each
class. If this standard is violated, the amount of tax revenue to be
offset from medical assistance expenditures is the total amount of the
taxpayers' revenues received by the State.
(ii) [Reserved]
Sec. 433.70 [Amended]
0
10. Section 433.70 is amended by--
0
A. Revising the section heading.
0
B. Removing paragraph (a)(1).
0
C. Removing the paragraph designation for existing paragraph (a)(2).
0
The revised heading reads as follows:
Sec. 433.70 Limitation on level of FFP for revenues from health care-
related taxes.
* * * * *
(Catalog of Federal Domestic Assistance Program No. 93.778, Medical
Assistance Program)
Dated: October 23, 2007.
Kerry Weems,
Acting Administrator, Centers for Medicare & Medicaid Services.
Approved: December 3, 2007.
Michael O. Leavitt,
Secretary.
Editorial Note: This document was received at the Office of the
Federal Register on February 15, 2008.
[FR Doc. E8-3207 Filed 2-21-08; 8:45 am]
BILLING CODE 4120-01-P