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Copyright 1999 Federal Document Clearing House, Inc.  
Federal Document Clearing House Congressional Testimony

October 01, 1999

SECTION: CAPITOL HILL HEARING TESTIMONY

LENGTH: 11400 words

HEADLINE: TESTIMONY October 01, 1999 MICHAEL HASH DEPUTY ADMINISTRATION US DEPARTMENT OF HEALTH AND HUMAN SERVICES HOUSE WAYS AND MEANS HEALTH MEDICARE BALANCED BUDGET ACT REVISIONS

BODY:
Testimony of Michael Hash, Deputy Administrator Health Care Financing Administration before the Ways & Means Health Subcommittee on Balanced Budget Act Refinement October 1, 1999 Chairman Thomas, Congressman Stark, distinguished Subcommittee members, thank you for inviting us to discuss refinements to the Balanced Budget Act. The BBA includes important new preventive benefits and payment system reforms that promote access, efficiency, and prudent use of taxpayer dollars. These reforms are critical to strengthening and protecting Medicare for the future. The Medicare Trust Fund, which was projected to be insolvent by 1999 when President Clinton took office, is now projected to be solvent until 2015. The BBA made substantial changes to the way Medicare reimburses providers in the fee-for- service program by: - modifying inpatient hospital payment rules; - establishing a prospective per them payment system for skilled nursing facilities to encourage facilities to provide care that is both efficient and appropriate; - refining the physician payment system to more accurately reflect practice expenses; - initiating development of prospective payment systems for home health agencies, outpatient hospital care, and rehabilitation hospitals that will be implemented once the Year 2000 computer challenge has been addressed; and, - authorizing an important test of whether market competition can help Medicare and its beneficiaries save money on durable medical equipment and supplies. And the BBA created the Medicare+Choice program, which allows private plans to offer beneficiaries a wide range of options, similar to what is available in the private sector today. It has initiated a new beneficiary education campaign to inform beneficiaries about these options. It includes important new protections for patients and providers, as well as statutory requirements for quality assessment and improvement. And it initiates a transition to risk adjustment, which will make the payment system fairer and more accurate. We have fully implemented the majority of the BBA's more than 300 provisions affecting our programs and made substantial progress on the remainder. While the statute generally prescribes in detail the changes we are required to make, we are committed to exercising the maximum flexibility within our limited discretion in the implementation of these provisions. It is clear that the BBA is succeeding in promoting efficiency, slowing growth of Medicare expenditures, and extending the life of the Medicare Trust Fund. However, according to both the HCFA actuaries and the Congressional Budget Office (CBO), the BBA is only one factor contributing to changes in Medicare spending. We have made substantial strides in fighting fraud, waste and abuse that have significantly decreased improper payments. For the first time ever, the hospital case mix index declined last year due to efforts to stop "upcoding," or billing for more serious diagnoses than patients actually have. Low inflation from a strong economy is having an impact on total spending. And slower claims processing during the transition to new payment systems is contributing to a temporary slow-down in spending. Backlogged claims are expected to be paid by fiscal 2000. Change of this magnitude always requires adjustment. It is not surprising that some market corrections would result from such significant legislation. We are proactively monitoring the impact of the BBA to ensure that beneficiary access to covered services is not compromised. We are evaluating this information to assess the impact of BBA changes on beneficiaries and to determine what changes may need to be made to ensure continued access to quality care. It is important to note that the BBA is only one factor contributing to challenges providers face in the rapidly evolving health care market place. Efforts to pay correctly and promote efficiency may mean that Medicare no longer makes up for losses or inefficiencies elsewhere. We are concerned about reports on the financial conditions of some individual and chain providers. But it is essential that we try to delineate the BBA's impact from the effects of excess capacity, discounted rates to other payers, aggressive competition, imprudent business decisions, and other factors not caused by the BBA. And it is essential that we focus on the impact on beneficiary access to high quality patient care. Thus far, our monitoring reveals evidence of isolated but significant problems. Although our analysis is not yet complete, we are concerned, for example, that some beneficiaries are not getting necessary care because of the BBA's $1500 caps on certain outpatient rehabilitation therapies. We will continue working with beneficiaries, providers, Congress, and other interested parties to closely monitor the situation, evaluate evidence of problems in access to quality care, and develop appropriate, fiscally responsible solutions. Because of our concerns, the President's Medicare reform plan sets aside $7.5 billion from fiscal 2000 to fiscal 2009 to smooth out implementation of BBA payment reforms that may be adversely affecting beneficiary access to quality care. We want to work with the Congress to make appropriate adjustments where there is evidence that adjustments are needed. The President's reform plan also dedicates a portion of the budget surplus to Medicare. This will help prevent excessive cuts in provider payment that otherwise would be necessary in the future as Medicare enrollment doubles over the next 30 years, since increased efficiencies alone will not be able to cover the increased costs. The President's plan also includes administrative actions to assure a smooth implementation process, and we are continuing to explore other actions. Those already underway address several key areas of concern: Inpatient hospital transfers. The BBA requires the Secretary to reduce payments to hospitals when they transfer patients to another hospital or unit, skilled nursing facility or home health agency for care that is supposed to be included in acute care payment rates for ten diagnoses. It also authorizes HCFA to extend this "transfer policy" to additional diagnoses after October 1,2000. To minimize the impact on hospitals, we are delaying extension of the transfer policy to additional diagnoses for two years. Hospital outpatient payments. The BBA requires Medicare to begin paying for hospital outpatient care under a prospective payment system (PPS), similar to what is used to pay for hospital inpatient care. This new system is schedule to go into effect in July 2000. To help all hospitals with the transition to outpatient prospective payment, we are considering delaying a "volume control mechanism" for the first few years of the new payment system. The law requires Medicare to develop such a mechanism because prospective payment includes incentives that can lead to unnecessary increases in the volume of covered services. The proposed prospective payment rule presented a variety of options for controlling volume and solicited comments on these options. Delaying their implementation would provide an adjustment period for providers as they become accustomed to the new system. We also are considering implementing a three-year transition to this new PPS by making budget-neutral adjustments to increase payments to hospitals that would otherwise receive large payment reductions such as low-volume rural and urban hospitals, teaching hospitals, and cancer hospitals. Without these budget-neutral adjustments, these hospitals could experience large reductions in payment under the outpatient prospective payment system. And, to help hospitals under the outpatient prospective payment system, we included a provision in the proposed rule to use the same wage index for calculating rates that is used to calculate inpatient prospective payment rates. This index would take into account the effect of hospital reclassifications and redesignations. For all of these outpatient department reform options, the rulemaking process precludes any definitive statement on administrative actions until after the implementing rule is published. Rural hospital reclassification. Hospital payments are based in part on average wages where the hospital is located. We are making it easier for rural hospitals whose payments now are based on lower, rural area average wages to be reclassified and receive payments based on higher average wages in nearby urban areas and thus get higher reimbursement. Right now, facilities can get such reclassifications if the wages they pay their employees are at least 108 percent of average wages in their rural area, and at least 84 percent of average wages in a nearby urban area. We are changing those average wage threshold percentages so more hospitals can be reclassified. Home health agencies. The BBA significantly reformed payment and other rules for home health agencies. We are taking several new steps to help agencies adapt to these changes. We are increasing the time for repayment of overpayments related to the interim payment system from one year to three years, with one year interest free. Currently, home health agencies are provided one year of interest free extended repayment schedules. We are postponing the requirement for surety bonds until October 1, 2000, when we will implement the new home health prospective payment system. This will help ensure that overpayments related to the interim payment system will not be an obstacle to agencies obtaining surety bonds. We also are following the recommendation of the General Accounting Office (GAO) by requiring all agencies to obtain bonds of only $50,000, not 15 percent of annual agency Medicare revenues as was proposed earlier. We also have eliminated the sequential billing rule that some agencies said was adversely affecting cash flow. And we are phasing-in our instructions implementing the requirement that home health agencies report their services in 15-minute increments. Monitoring Access We are proactively monitoring the impact of the BBA to ensure that beneficiary access to covered services is not compromised. We are systematically gathering data from several sources to look for objective information and evidence of the impact of BBA changes on access to quality care. These data sources include: - beneficiary advocacy groups; - health plans and providers; - Area Agencies on Aging; - State Health Insurance Assistance Programs; - claims processing contractors; - State health officials; and - media reports. We also are examining information from the Securities and Exchange Commission and Wall Street analysts on leading publicly traded health care corporations. This can help us understand trends and Medicare's role in net income, revenues and expenses, as well as provide indicators of liquidity and leverage, occupancy rates, states-of-operation, continuing lines of business as well as those exited or sold by the company, and other costs which may be related to discontinued operations. We are examining Census Bureau data, which allow us to gauge the importance of Medicare in each health service industry, looking at financial trends in revenue sources by major service sectors, and tracking margin trends for tax-exempt providers. We are monitoring the Bureau of Labor Statistics monthly employment statistics for employment trends in different parts of the health care industry. Such data show, for example, that the total number of hours worked by employees of independent home health agencies is at about the same level as in 1996. That provides a more useful indicator of actual home health care usage after the BBA than statistics on the number of agency closures and mergers. The data also show that nursing homes may be slightly reducing the number of employees and the hours that they work. The HHS Inspector General's (IG) office has interviewed hospital discharge planners and nursing home administrators about the BBA's impact on patient care. The IG also has agreed to interview discharge planners about access to home health care following BBA payment reforms and the impact of the $1500 caps on outpatient therapy. Specific BBA Provisions Outpatient Rehabilitation Therapy: The BBA imposed $1500 caps on the amount of outpatient rehabilitation therapy services that can be reimbursed, except in hospital outpatient clinics. However, these caps are not based on severity of illness or care needs, and they appear to be insufficient to cover necessary care for many beneficiaries. We have several industry-sponsored analyses from different sources of 1996 claims data indicated that approximately 12 to 13 percent of therapy patients will exceed the caps. Beneficiary groups are reporting many instances of problems with this cap, and we are very concerned about their adverse impact, particularly on individuals in nursing homes. As mentioned above, our IG colleagues have agreed to study this problem. We are providing data to the Medicare Payment Advisory Commission so it can analyze patterns of therapy service usage. And we will continue to work with Congress and others to determine what adjustments to the cap should be made. Skilled Nursing Facilities: We implemented the new prospective payment system (PPS) called for in the BBA on July 1, 1998. The old payment system was based on actual costs, subject to certain limits, and included no incentives to provide care efficiently. The new system uses average prices adjusted for each patient's clinical condition and care needs, as well as geographic variation in wages. It creates incentives to provide care more efficiently by relating payments to patient need, and enables Medicare to be a more prudent purchaser of these services. The BBA mandated a per them PPS covering all routine, ancillary, and capital costs related to covered services provided to beneficiaries under Medicare Part A. The law requires use of 1995 costs as the base year, and implementation by July 1, 1998 with a three-year transition blending facility-specific costs and prospective rates. It did not allow for exceptions to the transition, carving out of any service, or creation of an outlier policy. We are carefully reviewing the possibility of making budget neutral administrative changes to the PPS. We held a town hall meeting earlier this year to hear a broad range of skilled nursing facility concerns, and we continue to meet with provider and beneficiary representatives. There are concerns that the prospective payment system does not adequately reflect the costs of non- therapy ancillaries such as drugs for high acuity patients. The Inspector General found in its interviews of hospital discharge planners and nursing home administrators that less than I percent of nursing home administrators say the prospective payment system is causing access to care problems. The proportion of beneficiaries discharged to skilled nursing facilities is unchanged from 1998, and hospital lengths of stay have not increased. However, about one in five discharge planners say it takes more time to place Medicare patients in nursing homes. The IG also found that both nursing home administrators and hospital discharge planners say nursing facilities are requesting more information before accepting patients. About half of the nursing home administrators say they are less likely to accept patients requiring expensive supplies or services such as ventilators or expensive medications, about half also say they are more likely to admit patients who require special rehabilitation services such as physical therapy following joint replacement surgery. We are therefore conducting research that will serve as the basis for refinements to the resource utilization groups that we expect to implement next year. We expect to have the research completed by the end of the year and to then develop refinements that we will be able to implement next October. Under the statute, we have the authority to refine these groups and redistribute money across categories in a budget neutral manner. We do not have discretion under the law to increase the overall level of payments to skilled nursing facilities. We fully expect that we will need to periodically evaluate the system to ensure that it appropriately reflects changes in both care practice and the Medicare population. Home Health Agencies: The BBA closed loopholes that had invited fraud, waste and abuse. For example, it stopped the practice of billing for care delivered in low cost, rural areas from urban offices at high urban-area rates. It tightened eligibility rules so patients who only need blood drawn no longer qualify for the entire range of home health services. And it created an interim payment system to be used while we develop a prospective payment system. We expect to publish a proposed regulation this fall and to have the prospective payment system in place by the October 1, 2000 statutory deadline. The interim payment system is a first step toward giving home health agencies incentives to provide care efficiently. Before the BBA, reimbursement was based on the costs they incurred in providing care, subject to a per visit limit, and this encouraged agencies to provide more visits and to increase costs up to the limits. The interim system includes a new, aggregate per beneficiary limit designed to provide incentives for efficiency that will be continued under the episode-based prospective payment system. Last year Congress increased the cost limits in an effort to help agencies during the transition to prospective payment. We are also taking the steps discussed above to help agencies adjust to these changes, and in March we held a town hall meeting to hear directly from home health providers about their concerns. To date, evaluations by the GAO and HHS have not found that BBA changes are causing significant quality or access problems. Our monitoring of employment data shows that freestanding home health agencies have made small reductions in their workforce, back to the level seen in 1996. However, we have heard reports from beneficiary groups, our regional offices, and others regarding home health agencies that have inappropriately denied or curtailed care, and incorrectly told beneficiaries that they are not eligible for services. We are also hearing reports from beneficiary advocates and others that some high cost patients are having trouble finding home health agencies to provide the care they need. This may result from a misunderstanding of the new incentives to provide care efficiently, or from efforts to "cherry pick" low cost patients and game the system. The CBO attributes some of the lower health spending to the fact that agencies are incorrectly treating the new aggregate per beneficiary limit as though it applies to each individual patient. We have therefore provided home health agencies with guidance on the new incentives and their obligation to serve all beneficiaries equitably. We have instructed our claims processing contractors to work with agencies to further help them understand how the limits work. And, because home health beneficiaries are among the most vulnerable, we are continuing ongoing detailed monitoring of beneficiary access and agency closures. Hospitals: We have implemented the bulk of the inpatient hospital- related changes included in the BBA in updated regulations. We have implemented substantial refinements to hospital Graduate Medical Education payments and policy to encourage training of primary care physicians, promote training in ambulatory and managed care settings where beneficiaries are receiving more and more services, curtail increases in the number of residents, and slow the rate of increase in spending. We have implemented provisions designed to strengthen rural health care systems. We have carved out graduate medical education payments from payments to managed care plans and instead are paying them directly to teaching hospitals (and are proposing in the President's Medicare reform plan to similarly carve out disproportionate share hospital payments). We expect to implement the prospective payment system for outpatient care next year. The outpatient prospective payment system will include a gradual correction to the old payment system in which beneficiaries were paying their 20 percent copayment based on hospital charges, rather than on Medicare payment rates. Regrettably, implementation of the prospective payment system as originally scheduled would have required numerous complex systems changes that would have substantially jeopardized our Year 2000 efforts. We are working to implement this system as quickly as the Year 2000 challenge allows. We issued a Notice of Proposed Rule Making in September 1998 outlining plans for the new system so that hospitals and others can begin providing comments and suggestions. We are actively reviewing all of the comments from the industry and other interested parties that we received during the comment period, which we extended until July 30. We are focusing most of our continuing work on rural, inner city, cancer, and teaching hospitals because our analysis suggests that the outpatient prospective payment system will have a disproportionate impact on these facilities. And we are continuing to develop modifications to the system for inclusion in the final rule. The hospital industry has submitted data projecting significant decreases in total Medicare margins. Our actuaries believe the methodology used to develop these projections understates base year total margins by approximately 7 percent. And, according to the Medicare Payment Advisory Commission (MedPAC), Medicare costs per case have declined for an unprecedented fifth year in a row. However, MedPAC also notes that while rural hospitals have generally posted healthy margins, many small rural hospitals appear to be in especially poor financial condition. We continue to hear reports of financial distress, and we understand the challenge hospitals are facing in today's changing health care marketplace. We are reviewing the data as it comes in, and we will continue to monitor this situation closely. Physicians: As directed by the BBA, we are on track in implementing the resource-based system for practice expenses under the physician fee schedule, with a transition to full implementation by 2002 in a budget-neutral fashion that will raise payment for some physicians and lower it for others. The methodology we used addresses many concerns raised by physicians and meets the BBA requirements. We fully expect to update and refine the practice expense relative value units in our annual regulations revising the Medicare fee schedule. We included the BBA-mandated resource-based system for malpractice relative value units in this year's proposed rule. We welcome and encourage the ongoing contributions of the medical community to this process, and we will continue to monitor beneficiary access to care and utilization of services as the new system is fully implemented. The President's fiscal 2000 budget contains a legislative proposal for a budget-neutral technical fix to ensure the BBA's sustainable growth rate (SGR) for physician payment is stable. Medicare payments for physician services are annually updated for inflation and adjusted by comparing actual physician spending to a national target for physician spending. The BBA replaced the former physician spending target rate of growth, the Medicare Volume Performance Standard, with the SGR. The SGR takes into account price changes, fee-for-service enrollment changes, real gross domestic product per capita, and changes in law or regulation affecting the baseline. After BBA was enacted, HCFA actuaries discovered that the SGR system would result in unreasonable year-to-year fluctuations. Also, the SGR target cannot be revised to account for new data. The President's budget proposal addresses both of these concerns. Medicare+Choice: Successfully implementing this program is a high priority for us. Medicare managed care enrollment has tripled under the Clinton Administration, and there are now 6.48 million beneficiaries enrolled in Medicare+Choice plans. We meet regularly with beneficiary advocates, industry representatives, and others to discuss ways to improve the program. We launched a national education campaign and participated in more than 1,000 events around the country to help beneficiaries understand it. And we are establishing a federal advisory committee to help us better inform beneficiaries. We have taken steps to assist plans and encourage plan participation in Medicare+Choice. We worked with Congress to give plans two more months to file the information used to approve benefit and premium structures so plans were able to use more current experience when designing benefit packages and setting cost sharing levels. We also published refinements to Medicare+Choice regulation that improve beneficiary protections and access to information while making it easier for health plans to offer more options. The new rule: - clarifies that beneficiaries in a plan that leaves the program are entitled to enroll in remaining locally available plans; - specifies that changes in plan rules must be made by October 15 so beneficiaries have information they need to make an informed choice during the November open enrollment; - allows plans to choose how to conduct the initial health assessment; - waives the mandatory health assessment within 90 days of enrollment for commercial enrollees who choose the same insurer's Medicare+Choice plan when they turn 65, and for enrollees who keep the same primary care provider when switching plans; - stipulates that the coordination of care function can be performed by a range of qualified health care professionals, and is not limited to primary care providers; - limits the applicability of provider participation requirements to physicians; and, - allows plans to terminate specialists with the same process for terminating other providers. We intend to publish a comprehensive final rule with further refinements this fall. We have also undertaken a comprehensive beneficiary education program. We launched the National Medicare Education Program to make sure beneficiaries receive accurate, unbiased information about their benefits, rights, and options. The campaign includes: M mailing a Medicare & You handbook to explain health plan options; M a toll-free "I-800-MEDICARE" 1-800-633-4227 call center with live operators to answer questions, and provide detailed plan-level information; - a consumer-friendly Internet site, www.medicare.gov, which includes comparisons of benefits, costs, quality, and satisfaction ratings for plans available in each zip code; - working with more than 120 national aging, consumer, provider, employer, union, and other organizations who help disseminate information to their constituencies; - beneficiary counseling from State Health Insurance Assistance Programs; - a national publicity campaign; - a Regional Education About Choices in Healthcare (REACH) campaign that will conduct State and local outreach activities nationwide; and, - a comprehensive assessment of these efforts. We tested the system in five States in 1998 and learned how to improve efforts for this November's open enrollment period. For example, we have made the Medicare & You handbook easier to use and improve the accuracy of information about plans that are withdrawing. We have added new links on our Medicare Compare website at www.medicaregov to help users find information faster. We are standardizing plan marketing materials that summarize benefits so beneficiaries can more easily make apples-to-apples comparisons among plans in this November's open enrollment period. And we have added information on managed care plan withdrawals to the Important Notes section of the 1999 plan information on our Medicare Compare website. To help us continually improve our education efforts, we are establishing the Citizens' Advisory Panel on Medicare Education, under the Federal Advisory Committee Act. The panel will help enhance our effectiveness in informing beneficiaries through use of public-private partnerships, expand outreach to vulnerable and underserved communities, and assemble an information base of "best practices" for helping beneficiaries evaluate plan options and strengthening community assistance infrastructure. Panel members will include representatives from the general public, older Americans, specific disease and disability groups, minority communities, health communicators, researchers, plans, providers, and other groups. The BBA also initiated important payment reforms that begin to correct for historical overpayment. It established a competitive pricing demonstration in which plan payment rates will be set through a bidding process, similar to what most employers and unions use to decide how much to pay plans. And, starting in January, the BBA mandates that we "risk adjust" payments to account for the health status of each enrollee. Studies by the Congressional Budget Office, Physician Payment 9eview Commission, and many others have shown that we overpay plans in part because Medicare fails to adjust payments for the health of enrollees. That is why risk adjustment cannot be budget neutral. The vast majority of beneficiaries enrolled in Medicare+Choice cost far less than what Medicare pays plans for each enrollee. Budget neutral risk adjustment would mean Medicare and the taxpayers who fund it would continue to lose billions of dollars each year on Medicare+Choice. Budget neutral risk adjustment would cost taxpayers an estimated $11.2 billion over the five years that we are phasing it in if health plans maintain their current, mostly healthy beneficiary mix. We are concerned about disruptions to beneficiaries caused by plan decisions to trim participation in Medicare+Choice. The GAO reported in April that many factors contribute to such decisions. For instance, plans may have trouble establishing adequate provider networks, enrolling enough beneficiaries to support fixed costs, or otherwise competing in a given market. However, inadequate reimbursement to plans does not fully explain these plan decisions. Payment is rising in all counties this coming year by an average of 5 percent. In fact, despite BBA reforms, aggregate payment to plans continues to be excessive, according to another GAO report released in June, because of a forecasting error that the BBA locked into the statutory payment formula. The result is that plans are being paid an additional excess amount that totaled $1.3 billion in 1998 and will increase each year. BBA reforms may, however, mean that payments in some counties no longer include enough excess to cover losses in other areas or to subsidize extra benefits that fee-for- service Medicare does not currently cover, such as prescription drugs. Clearly all beneficiaries need a more stable and reliable source of prescription drug coverage. And, if plans' primary problem is paying for benefits beyond the Medicare benefit package, the best solution is to improve the benefit package by providing all beneficiaries with access to an affordable prescription drug benefit, and paying plans explicitly for providing it. The President's Medicare reform plan gives all beneficiaries the option to pay a modest premium for a prescription drug benefit that will cover half of all prescription drug costs up to $5,000 when fully phased in, with no deductible. Medicare+Choice plans would be explicitly paid for providing a drug benefit, and would no longer have to depend on what the rate is in a given area to determine whether they can afford to do so. The President's plan also will modernize the way Medicare pays managed care plans. Rates would be set through competition among plans rather than through a complicated statutory formula. All plans would be paid their full price through a combination of government and beneficiary payments. The lower the price, the less beneficiaries pay. And the President's plan also includes several provisions to preserve beneficiary options and strengthen protections when plans withdraw from Medicare. CONCLUSION The BBA made important changes to the Medicare program to strengthen and protect it for the future. These changes, along with a strong economy and our increased efforts to combat fraud, waste, and abuse, have extended the life of the Trust Fund until 2015. With changes of the magnitude encompassed in the BBA, some issues have arisen that may require adjustment and fine tuning. The President's Medicare reform plan sets aside $7.5 billion to smooth out implementation of BBA reforms. The President's plan also includes administrative adjustments to help in the transition to new payment systems. It dedicates a portion of the budget surplus to Medicare, which will help protect against excessive provider payment reductions in the future as Medicare enrollment doubles over the next 30 years, and increased efficiencies alone will not be able to cover the increased costs. It is not surprising that necessary market corrections would result from such significant legislation. As always, we remain concerned about the effect of policy changes on beneficiaries' access to affordable, quality health care. We are proactively monitoring the impact of the BBA to ensure that beneficiary access to covered services is not compromised. We welcome the opportunity to look at any new information regarding beneficiary access to quality care. We are committed to continuing to look at refinements to the BBA that are within our administrative authority. We also are committed to working with Congress to enact bipartisan Medicare reform this year that makes a prescription drug benefit available and affordable for all beneficiaries, dedicates, it significant portion of the budget surplus to Medicare, and sets aside funding specifically for smoothing out BBA payment reforms. I thank you for holding this hearing, and I am happy to answer your questions.

LOAD-DATE: October 5, 1999




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