CMS did not include in the final rule an estimate or example calculation of the FY 2020 DSH allotments and related reductions. In the final rule, CMS noted that they are still gathering the final data elements needed to calculate the FY 2020 DSH allotments and reductions, but anticipate they will have all necessary data by October 1, 2019. Once all the data is gathered, they will begin the process of calculating the FY 2020 DSH allotments and reductions, and these allotments and reductions will be provided to states as soon as they are completed.
While CMS did not include any estimates or projections in the final rule, they indicated their intent to publish a separate “DHRM technical guide that provides information regarding the DHRM calculation and associated data sources in order to be fully transparent with states and stakeholders.” No timeline was given for the publication of this technical guide, nor was it indicated whether a tentative FY 2020 calculation or schedule would be included in this document.
At this time, our best source of data for the FY 2020 DSH allotment reductions is Table 3A-1 on page 85 of the March 2019 Report to Congress on Medicaid and CHIP published by the Medicaid and CHIP Payment and Access Commission (MACPAC). In the table, the MACPAC provides estimated FY 2020 DSH allotments and reductions using more recent data (SPRY 2014) than was used in CMS’s July 2017 proposed rule (SPRY 2013). Myers and Stauffer is available to assist with DSH allotment reduction projections for years after FY 2020, if needed.