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AAMC Comments on CMS’ Proposed 2013 Occupational Mix Survey

February 8, 2013—The AAMC Feb. 5 submitted comments  to the Centers for Medicare and Medicaid Services (CMS) in response to a request for input regarding the agency’s proposed 2013 Medicare Wage Index Occupational Mix Survey.  The AAMC encouraged CMS to consider modifying the occupational mix adjustment to take into account the unique occupational needs of teaching hospitals. 

CMS uses the survey to satisfy a statutory requirement to collect data every three years on the occupational mix of employees for each short-term acute care hospital participating in the Medicare program to construct an occupational mix adjustment to the wage index. AAMC’s comments highlight that teaching hospitals consistently treat more complex patients and provide specialized services such as level 1 trauma centers and burn units.  As a result, teaching hospitals are required to hire more specialized staff with higher training and wages. 

AAMC’s letter encourages CMS to consider that teaching hospitals’ staffing decisions are driven by mission and necessity.  This should be taken into account when CMS is collecting data and constructing an adjustment that is meant to control for the effect of hospitals’ employment choices on the wage index.

The AAMC’s letter also recommends adding two additional categories to the survey: “unit secretaries” and “all other nursing.” Additionally, the letter encourages CMS to alleviate the administrative burden associated with completing the survey, and suggests that one way to do this is to exempt hospitals that terminate participation in the Medicare program at any time during the data collection period. 

The 2013 Occupational Mix Survey will provide for the collection of occupational mix data for a 12-month period: from pay periods ending between Jan. 1 and Dec. 31, 2013, to be applied to the fiscal year 2016 wage index.


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806