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Baxter Morgan

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With a strong background in reimbursement and Medicaid supplemental payment programs, Baxter represents healthcare providers in regulatory, compliance, and litigation matters. Today, Baxter has a national practice with a Texas focus and divides his time between healthcare regulatory counsel, litigation, and assistance with reimbursement systems, including regulatory oversight of payments through audits, government inquiries, and administrative reviews. The opportunity to support health systems in their mission of patient care, and addressing challenges that allow providers to continue treating underserved communities, is the most rewarding part of his work.

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This post is the first in a series dedicated to Colorado’s Medicaid finance and payment systems, challenges faced by those programs, and opportunities for expansion.

The Colorado Healthcare Affordability and Sustainability Enterprise (CHASE) oversees Colorado’s hospital provider tax and the use of those taxes to support Medicaid supplemental payments. CHASE uses the largest portion of those taxes to generate payments targeting the cost shortfalls from treating Medicaid and uninsured patients. Broadly speaking, federal regulations (see 42 C.F.R. §§ 447.272, 447.321) allow each class of institutional providers to be paid for Medicaid services (on a fee-for-service basis) to a level that approximates what could have been paid under Medicare payment principles. This is known as the Upper Payment Limit (UPL). For the past several years, CHASE has limited these payments to less than the full amount permitted by federal law out of concerns about potential overpayments and statewide recoupment risks. The Colorado Hospital Association (CHA) is currently advocating for CHASE to increase payments to 100% of the UPL—i.e. “the full UPL.”