Why are some rural Medicare patients paying more than patients at bigger
hospitals?
[March 12, 2026]
By OLIVIA GIEGER/VTDigger
In November, a public comment sent a Green Mountain Care Board analyst
on a curious quest: Why were some Medicare recipients paying more out of
pocket for outpatient services at rural, “critical access hospitals”
than they’d have paid for the same service at the state’s bigger, “acute
care hospitals” — even if the hospitals’ costs for the procedure were
exactly the same?
It has brought into stark relief what one official calls a “bizarre”
quirk of unequal Medicare cost-sharing policies. Now the care board is
pushing for a swift change to the payment system.
Addressing the problem is not so simple, though. Hospitals say that
local fixes could bankrupt them or run afoul of the federal law that
governs these pay structures.
“We don’t have a lot of margin for error when it comes to addressing
this issue, and we want to move quickly,” said Devon Green, spokesperson
for the Vermont Association of Hospitals and Health Systems.
What could the hospitals or the state do? “That’s what we’re grappling
with now,” Green said.

Cost, charge and payments
To understand the differences in what patients end up paying, it helps
to know how three different numbers come into play.
First, there is the cost of the service the hospital provides — how much
money it takes to administer an MRI or replace a hip, say.
Then, there is the charge the hospital posts, which is essentially the
price they ask insurers to base their payments on. Often this number is
double the cost but sometimes can be higher, even five or six times the
hospital’s cost of the service. Each hospital sets these lists of
charges for billable services, which then serve as the basis for each
insurer to negotiate their individual rates. It’s unusual for an insurer
to pay exactly what’s listed.
What Medicare actually pays the hospital is a third separate number —
101% of the cost of the service, minus the patient’s share.
At the small, rural hospitals Medicare designates as “critical access
hospitals,” Medicare beneficiaries are responsible for paying 20% of the
hospital’s charges for their outpatient care.
At large hospitals without this designation, patients pay 20% of the
Medicare payment amount. Because Medicare’s payment essentially matches
the cost, a share based on the payment is consistently less than a share
based on the hospital’s charge. It means that at a larger hospital, a
Medicare patient would pay less for a service with the same cost than a
patient at a critical access hospital.
The Green Mountain Care Board used a Feb. 11 hearing to discuss the
issue. The board invited Jeffrey Stensland, a former analyst with the
Medicare Payment Advisory Commission, which is an independent government
group that does policy research and offers legislative advice on
Medicare.
Stensland outlined just how burdensome this imbalance could become for
some rural patients.
Take an MRI that costs the hospital $600 to administer, for instance.
The hospital may post the charge as $1,000, to cover the cost and build
a revenue buffer. At a critical access hospital, the patient — or their
secondary insurer, such as a MediGap plan — would be responsible for 20%
of the charge, or $200.

Medicare would pay the hospital the remaining $406, Stensland explained,
to meet 101% of the full cost of the service ($606).
But, if the hospital posts higher charges, the patient’s payment share
grows as Medicare’s shrinks.
“The hospital will get the same amount, but it’s the portion of that
payment that matters, “ David Murman, a care board member, said during
the meeting.
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 “The higher the charges are, the
more the patient pays, and the less Medicare pays. So if you have
very high charges, Medicare pays very little. If the charges are
lower, then we have more Medicare revenue coming into the state, and
are putting less on our local populations.
“It’s a bizarre situation,” he added.
If a critical access hospital posts a $1,500 charge for that $600
MRI, the patient would pay $300 (20% of the charge), while Medicare
pays $306.
Expenses to patients can quickly run rampant,
Stensland showed. If the charges are five times the cost, then the
patient ends up footing the entire bill — since 20% of the charge
ends up being 100% of the cost, which is all Medicare is responsible
for.
Worse yet, Stensland said, if the charges are higher than five times
the cost, the patient pays more than what Medicare would have paid.
“In that perverse situation where the charges are really really
high, the beneficiary can actually be subsidizing the Medicare
program,” Sensland told the care board.
Changing locally
It’s a breakdown that worries the board chair, Owen Foster, as not
only inequitable but also illegal.
“It is really, really troubling that some of our seniors may be
paying a lot more if they’re in a rural community as opposed to in
Chittenden County,” he said in the February meeting.
Foster followed that meeting by sending Vermont’s critical access
hospitals, its industry group and insurers a letter outlining the
parts of Vermont law he sees this clashing with: “Financing of
health care in Vermont must be sufficient, fair, predictable,
transparent, sustainable, and shared equitably.”
He requested further information from the hospitals about their
charges and revenue, and he sought the hospitals’ participation and
ideas on solutions the state could pursue to address this.
Solving it, though, is another issue, said Green, the hospital
association spokesperson.

“We are alarmed this is happening,” she said. “We understand the
problem that needs to be solved and the impact to Vermonters and
hospitals. This is not good for either of us.”
The hospitals, the Medicare policy advisory group and the care board
have floated a number of possible solutions on the state and federal
level.
Green says the hospitals do support recommendations to tackle the
issue federally, since Medicare dictates these rules.
Other potential changes, like reducing the cost of the charges,
would be untenable to many of the state’s small critical access
hospitals.
In a letter back to Foster, the CEO of Grace Cottage Family Health
and Hospital in Townshend, wrote that even without detailed
calculations, the loss of revenue from reducing its charges would
“surely bankrupt” the hospital.
It’s a sentiment representatives from nearly all of the state’s
eight critical access hospitals voiced.
The problem is not unique to Vermont, but it’s likely heightened
here since so many more patients receive care at rural hospitals.
Foster and the care board are pushing for more information by March
16 so that the inequity can be righted for next fiscal year’s
budgets. The care board has authority to set and enforce hospital
budgets but has little sway over a hospital’s agreement with
insurers. The state has no authority over federal Medicare rules.
“What cannot happen is delay,” Foster wrote in a subsequent letter.
“We already know that rural Vermonters are being charged prices that
are neither defensible nor sustainable. It is unacceptable for this
to persist into another fiscal year.”
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