CMS Releases FY 2025 Proposed Rule for Skilled Nursing Facilities

The Centers for Medicare & Medicaid Services (CMS) released a proposed rule April 3 to update the Medicare fee-for-service (FFS) prospective payment system (PPS) for skilled nursing facilities (SNFs) for federal fiscal year (FY) 2025.

Key provisions of the proposed rule include:

  • Increasing the per diem federal rate by a net 4.1% after the market basket update, productivity adjustment and other adjustments.
  • Updating the base year data used to determine the SNF market basket from 2018 to 2022.
  • Updating the wage index used under the SNF PPS to reflect data from the 2020 decennial census.
  • Increasing the labor-related share of the per diem rate from 71.1% to 71.9%.
  • Making technical revisions to the code mappings used to classify patients under the Patient Driven Payment Model (PDPM) that assigns patients to clinical categories.
  • Revising the CMS nursing home enforcement authority to allow the agency to impose multiple financial penalties on facilities with safety deficiencies.
  • Adopting four new patient assessment items related to health-related social needs with SNFs required to collect and report specific data elements related to living situation, food and utilities beginning with the FY 2027 SNF quality reporting program (QRP).
  • Modifying the patient assessment item on transportation to simplify the response options and revise the look-back period.
  • Adopting a data validation process for the SNF QRP beginning with the FY 2027 program.
  • Proposing operational updates to the SNF Value-Based Purchasing program, including policies regarding measure removal and review and corrections.
  • Updating the case mix methodology used to calculate the Total Nurse Staffing measure.
  • A Request for Information (RFI) on potential updates to the Non-Therapy Ancillary component of the PDPM.

The MHA will provide SNFs with a facility-specific impact analysis and additional details on the proposed rule in the near future. The MHA also encourages members to submit comments to the CMS by May 28 and to contact the MHA with issues identified by May 22.

Members with questions should contact Vickie Kunz at the MHA.

CMS Releases Inpatient Rehabilitation Facilities FY 2025 Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) released a proposed rule March 29 to update the Medicare fee-for-service prospective payment system (PPS) for inpatient rehabilitation facilities (IRFs) for federal fiscal year (FY) 2025.

Key provisions of the proposed rule include:

  • Increasing the IRF PPS payment rate by a net 1.8% after all adjustments, from $18,541 to $18,872. IRFs that fail to comply with the CMS IRF Quality Reporting Program (QRP) requirements are subject to a two-percentage point reduction.
  • Updating the wage index using the most recent Office of Management and Budget statistical area delineations based on the 2020 Decennial Census.
  • Increasing the labor-related share from the current 74.1% to 74.2%.
  • Increasing the cost outlier threshold by 17% from the current $10,423, to $12,158 to achieve the 3% target for outlier payments as compared to aggregate IRF payments, decreasing the number of cases that qualify for outlier payments.
  • Updating the case mix group relative weights and average length of stay values using FY 2023 IRF claims and FY 2022 IRF cost report data.
  • Requiring IRFs to report four new items using the IRF-Patient Assessment Instrument (PAI) as standardized patient assessment data elements under the social determinants of health category beginning with the FY 2028 IRF quality reporting program (QRP) including:
    • One item for Living Situation.
    • Two items for Food.
    • One item for Utilities
  • Modifying the Transportation item collected in the IRF-PAI.
  • Requesting information on quality measure concepts for the IRF QRP in future years and an IRF star rating system.

The MHA will provide IRFs with a facility-specific impact analysis and additional details on the proposed rule in the near future. The MHA also encourages members to submit comments to the CMS by May 28 and to contact the MHA with issues identified by May 21. Members with questions should contact Vickie Kunz at the MHA.

MDHHS Issues RFP for EMS Workforce Grants

The Michigan Department of Health and Human Services (MDHHS) issued a request for proposal (RFP) for emergency medical services (EMS) workforce grants to improve accessibility of EMS training programs. Through the $9 million grant, the MDHHS will expand access to EMS education programs and address the statewide shortage of paramedics.

Applicants are eligible for up to $400,000 in grant money to use during the one-year program, from Oct. 1, 2024, through Sept. 30, 2025.

These funds can be used to cover tuition costs and offer students an hourly wage for time spent in EMS training programs. Additional funding categories include initiatives to increase access in underserved areas, outreach campaigns to increase student enrollment and efforts to mitigate barriers to enrollment or student success.

Grant applications must be submitted electronically through EGrAMS by 3 p.m. May 30. An optional pre-application webinar will be held April 8 from 11 a.m. – 12:30 p.m. A recording of the webinar will be available later. The MDHHS will accept questions by email until April 11 and plans to release a FAQ April 17 on the EGrAMS website.

Members are encouraged to attend the pre-application webinar and submit an application.

Members with questions may contact Kelsey Ostergren at the MHA.

 

Webinar Detailing Virtual Care Models Approved for CE

The MHA is hosting the webinar Virtual Care Models that Improve Engagement and Support Staff from noon to 1 p.m. May 2. Representatives from Henry Ford Health and Trinity Health Grand Rapids will outline the design and interface of virtual care models among technology, care teams and patients; explain how to gain input and buy-in from leadership and staff; and share the outcomes that demonstrate the value of virtual care to the care team, patients and families. The webinar is approved for nursing and social work continuing education credit.

Virtual nursing is a cornerstone of modern healthcare, facilitating rapid and seamless communication between patients and nurses. Real-time virtual interactions enable patients to have their questions and concerns addressed promptly, leading to enhanced engagement and satisfaction with the healthcare team.

The webinar highlights the MHA Person & Family Engagement Roadmap, featuring research and tools supported by the Centers for Medicare & Medicaid Services and the Institute for Patient- and Family-Centered Care, which are proven to re-engage patients and improve person and family engagement. Registration is free to charge for MHA member organizations.

Members with questions about the MHA Person & Family Engagement Roadmap or webinar may contact Erin Steward at the MHA.

Nominations Open for 2024 Advancing Safe Care Award

mha advancing safe care awardThe MHA is accepting nominations for its annual Advancing Safe Care Award to recognize Michigan hospitals that are tackling issues daily to make care safer and more dependable. Eligible nominees include teams from hospitals across the state dedicated to transparency regarding the quality of care provided to their patients and providing unmatched care to different patient populations. Nominations for the 2024 award will be accepted through April 26.

The award honors teams within MHA-member hospitals who are committed to providing quality care to diverse socioeconomic populations, promoting transparency within organizations, leading the charge for quality improvement and achieving better outcomes due to strong culture of safety. The award does not limit the number of team members who can be included in the nomination.

Judging for this award is based on four criteria:

  • Reducing health disparities among specific patient populations.
  • Supporting a learning culture committed to trust, feedback and higher problem-solving.
  • Evidence of transparency among care teams, with patients and families and with community stakeholders.
  • Improving safety by creating high degrees of psychological and physical safety.

Members seeking more information on nominating a team for the Advancing Safe Care Award may contact Erica Leyko at the MHA.

Workforce Talent Pipeline Management Academy Cohort

The U.S. Chamber of Commerce is launching another cohort of the Talent Pipeline Management (TPM) Academy May 7. This program provides business leaders, workforce professionals and employers with strategies to connect job seekers with necessary training and career opportunities. The TPM strategy is focused on a tailored approach to career pathways that effectively meet the dynamic needs of employers.

The TPM Academy will include eight live sessions spanning 12 weeks, from May 7 through July 13, 2024, with each course focusing on a different TPM strategy. Throughout the duration of the program, participants can also engage in 1:1 office hours for additional mentoring.

Members with questions may contact Lauren LaPine at the MHA.

MHA Panelists Featured During 2024 State of Reform Health Policy Conference

MHA staff participated in panel discussions April 4 during the 2024 State of Reform Health Policy Conference in Lansing, MI. MHA speakers included Laura Appel, executive vice president of government relations and public policy; Jim Lee, senior vice president, data policy & analytics; Adam Carlson, senior vice president, advocacy; and Lauren LaPine, senior director, legislative and public policy. Each provided valuable insight on the issues important to hospitals and the role of public policy in identifying solutions.

Topics of discussion included workforce shortages, artificial intelligence, depleted American Rescue Plan Act funding and certified community behavioral health clinics.

Other MHA members participating in the event included Tawana Nettles-Robinson, executive director, Detroit market, Trinity Health Michigan and Michelle Pena, MSN, RN, NEA-BC, chief nursing officer, Trinity Health Grand Rapids. Nettles-Robinson discussed health disparities while Pena focused on workplace violence. Seth Karnes, senior director of risk, consulting and training at HSS, an MHA Endorsed Business Partner, was a guest speaker on the workplace violence panel to share national insights and perspectives. Members may contact HSS to learn more about active violence training, risk assessments, de-escalation training and more.

Members with questions may contact John Karasinski at the MHA.

MHA Podcast Explores Important Role Hospitals Play in Public Health

The MHA released a new episode of the MiCare Champion Cast during National Public Health Week to explore how hospitals are engaged in public health. Featured guests include Julie Yaroch, D.O., president of ProMedica Charles and Virginia Hickman Hospital and senior vice president of ProMedica Inpatient and Retail Pharmacy, and Frank Nagle, MBA, director of Community Impact in Michigan at ProMedica.

One of the public health issues that continues to be a priority for Michigan hospitals and health systems is food insecurity. With this in mind, Yaroch and Nagle highlight the strong impact the ProMedica Farms and Veggie Mobile are having on residents and communities by improving access to fresh, affordable produce and nutrition education.

Located on the hospital campus, ProMedica Farms includes a hoop house, outdoor garden, education center, walking trails and playground, all of which are open to the community. The Veggie Mobile, which has served 50,000 residents since 2013, is a market on wheels that travels to 17 locations throughout Lenawee County to offer residents an assortment of fresh, low-cost produce. ProMedica received a Ludwig Community Benefit award for both initiatives in 2023, which is presented annually to MHA-member organizations integrally involved in collaborative programs to improve the health and well-being of area residents.

In the episode, Yaroch and Nagle share how these efforts began while highlighting the important role hospitals play in public health alongside government agencies, educational institutions and the community.

“When you go back in history, public and medical health used to be under the same roof,” said Yaroch, who serves as current chair of the MHA Public Health Task Force. “We just need to dust things off and remember the importance of coming together preventatively rather than reactively. We need to continue to have those relationships and touch bases so that we understand each other’s role and have trust.”

Born out of a partnership with Lenawee Health Network, both the Farms and Veggie Mobile were implemented over the course of 10 years following a community health needs assessment that screens social determinants of health and identifies areas of vulnerability.

“It started small and really grew just by raising awareness, forming connections and responding to community and patient needs,” said Yaroch. As efforts expand, Nagle noted that the goal is to have these models replicated to serve communities across the country.

Both the Farms and the Veggie Mobile have had significant impact since their start. In 2011, about 5% of adults reported eating the recommended servings of fruits and vegetables. In 2022, that increased to 21%. Yaroch noted that “getting outside of the four walls of your operation” is key to making public health efforts successful.

“Really take the time to ask, what can we do better?” said Nagle. “Let’s get to the root cause of these barriers and make informed and data-driven decisions with community member input that help overcome those.”

Additional results from the Farms and Veggie Mobile collected by the hospital, include:

  • 7,300 pounds (more than three tons) of produce harvested since 2018.
  • 13,626 pounds (seven tons) of produce donated and distributed to the community since 2018 from the Farm, Gus Harrison Correctional Facility and local farmers.
  • 100 gardening, nutrition and cooking workshops have served nearly 500 community members since 2018 from the Farm and Michigan State University Extension.
  • 340+ patients screened for food insecurity who received food at discharge or at their primary care provider’s office.

The episode is available to stream on SpotifyYouTubeApple Podcasts and SoundCloud. Those interested in learning more can visit the ProMedica Farms and Veggie Mobile websites. To get involved or learn more about the MHA Public Health Task Force, contact Lauren LaPine at the MHA. To nominate a hospital or health system for future Ludwig Community Benefit awards, visit the MHA website.

MiCare Champion Cast · National Public Health Week: Learning More About ProMedica Farms and the Veggie Mobile

Questions or idea submissions for future MiCare Champion Cast episodes can be sent to Lucy Ciaramitaro at the MHA.

News to Know – April 1, 2024

  • Registration is now open for the 2024 MHA Graduate Medical Education (GME) Capitol Day, scheduled from 8:30 a.m. to 3:30 p.m. Wednesday, May 1, at the MHA Capital Advocacy Center. Physician residents, GME program administrators and directors are encouraged to attend the event. Due to legislative schedules and meeting space limitations, each participating group is encouraged to register no more than three physician residents per hospital. Members are encouraged to register by April 19. Members with questions regarding registration may contact Meghan Protz-Sanders at the MHA and members with questions about further details may contact Elizabeth Kutter at the MHA.
  • Registration is open for the 2024 Michigan Maternal Infant Health Summit scheduled June 17-18 at the Lansing Center. The Michigan Department of Health & Human Services Division of Maternal & Infant Health event provides a unique opportunity for multidisciplinary collaboration, convening both national and statewide stakeholders working to advance maternal, infant and family health. The Michigan Maternal Infant Health Summit is a forum for innovation and change, addressing root causes of inequities, challenging systematic barriers and creating actionable solutions. Registration costs $125 per person and will be on sale until June 5 or until the event is sold out. Members with questions may visit the Michigan Maternal Infant Health Summit website.

MHA Comments on SUSTAIN 340B Discussion

Washington DC capitol building

Washington DC capitol buildingThe MHA submitted comments to U.S. Sens. Debbie Stabenow (D-MI), John Thune (R-SD), Shelley Moore Capito (R-WV), Jerry Moran (R-KS), Tammy Baldwin (D-WI) and Benjamin L. Cardin (D-MD) on proposed changes to the 340B Drug Pricing Program. The discussion draft circulated by this group follows their 2023 340B Request for Information, which also received comment from the MHA.

The Supporting Underserved and Strengthening Transparency, Accountability, and Integrity Now and for the Future of (SUSTAIN) 340B Act discussion draft includes several key provisions that would impact the 340B program. Specifically, the draft aims to address contract pharmacy arrangements, the definition of a patient for purposes of 340B, transparency, recognition of 340B child sites, program integrity, prevention of duplicate discounts, enhancing equitable treatment of program entities, user fees and implementation details. The MHA is pleased to be a part of these important discussions and appreciates the opportunities presented to weigh in on any changes to the program.

The MHA commentary on the discussion draft and suggested changes to the program include:

  • Ensuring 340B covered entities can contract with pharmacy partners to the extent that best serves their individual needs.
  • Opposing restrictions to a covered entity’s ability to contract with a pharmacy of their choosing.
  • Including a broad definition of patient to meaningfully impact drug affordability for individuals served by 340B hospitals.
  • Cautioning against new reporting or transparency requirements given existing requirements on participants and the need to protect against new administrative requirements and burdens on Michigan 340B hospitals. Covered entities should be able to share and tell their 340B stories and information in the manner that best fits each individual entity.
  • Broadly accepting child sites for purposes of the program. Healthcare delivery continues to evolve and child sites are an opportunity to deliver care to patients in a space that makes the most sense to both the program participant and the patient themselves. Recognition of child sites within the context of 340B improve and increase access to care for vulnerable populations.
  • Maintaining existing structure that allow covered entities to assess and prevent duplicate discounts. This includes partnership between all program participants when it comes to information sharing to ensure integrity while identifying both state and federal opportunities to better understand and streamline prevention of duplication of discount.
  • Opposing the implementation of a user fee while supporting appropriations for administration of the program.

Members with questions on 340B advocacy and engagement can reach out to Elizabeth Kutter at the MHA.