MHA Monday Report Nov. 21, 2022

MHA Monday Report

Urge Congress to Support Hospitals by Enacting Key Priorities in Lame-duck Session

The American Hospital Association (AHA) recently released an action alert to impress upon lawmakers the immediate need to support hospitals and health systems. It is important the last session days of the year are used as an opportunity to advance key priorities at the federal level …


Webinar Outlines CRNA’s Role in the Future of Clinical Operations

Michigan legislation in 2022 modernized the scope of practice for certified registered nurse anesthetists (CRNAs), eliminating the state requirement that a CRNA must work under direct physician supervision. Hospitals can now choose the anesthesia care model that best fits their location, staffing and resources to offer safe and effective patient care …


Keckley Report 

Paul KeckleyThe Two Lessons Healthcare Should Take from Campaign 2022

“The public’s opinion (vote) on healthcare issues is defined by personal circumstances and core beliefs about a single issue. Most lack an informed view about the entire system. Healthcare must do a better job in educating citizens about our system of health and the roles of personal responsibility, commercial operations and governmental oversight. It must do a better job in understanding consumer needs and expectations especially in younger and independent-minded users.

The healthcare market is not homogenous: a one size fits all approach to service delivery, pricing, and user experiences is short-sighted. While single-issue voter blocks in healthcare matter (i.e., abortion, Medicaid expansion, drug prices, et al), they’re unlikely to advance a system of health that contributes effectively and appropriately to the future of our democracy—a key issue in Campaign 2022.”

Paul Keckley, Nov. 14, 2022


News to Know

  • DataGen is hosting a national webinar to review the 2023 Medicare fee-for-service outpatient prospective payment system final rule and hospital impact analysis at 3 p.m. on Nov. 30, 2022.
  • MHA Endorsed Business Partner NextJob is hosting a free webinar on Actionable Neuroscience Insights for Improved Workplace Performance at noon ET Dec. 7, 2022 to educate employees about the brain processes of perception, cognition and neuro-linguistics and share tips to help improve performance at work.

Laura AppelMHA in the News

The MHA received media coverage during the week of Nov. 14 on financial and staffing challenges impacting hospitals in Michigan and the potential for further state funding support …

MHA Monday Report Nov. 14, 2022

MHA Monday Report

MI Vote Matters logoRecapping 2022 Election Results

Midterm election results are in, bringing new leadership to the Michigan Legislature and a returning administration at the top of the ticket. Election 2022 will bring significant change to Lansing, as Democrats will now control the Governor’s office and both chambers of the state legislature for the first time since 1984 …


capitol buildingLegislature Returns for Lame Duck Session

The legislature returned during the week of Nov. 7 to vote on legislative leadership and kickoff the 2022 lame-duck session. Only a handful of MHA-tracked bills saw action, including legislation to implement the new federal Rural Emergency Hospital (REH) designation …


CMS Finalizes Rate Cuts in 2023 Medicare Physician Fee Schedule

The Centers for Medicare & Medicaid Services (CMS) recently released the 2023 Medicare Physician Fee Schedule (PFS) final rule, effective Jan. 1, 2023. The rule reduces the PFS conversion factor by $1.55 (4.7%) to $33.06 in a calendar year (CY) 2023 from $34.61 in CY 2022 …


October MA Enrollment Increases by 17,000 Beneficiaries

Medicare Advantage (MA) enrollment in Michigan totaled approximately 1.22 million in October, an increase of 17,000 beneficiaries since July. The October enrollment is spread across 48 MA plans that are currently operating in the state …


The MHA Keystone Center Offers Ongoing Workforce Well-Being Courses

Through a partnership with the Duke Center for Healthcare Safety and Quality, the MHA Keystone Center is pleased to offer the second iteration of its WELL-B webinar series geared to support healthcare workers experiencing burnout …


The Keckley Report 

Paul KeckleyThe Physician Pay Rule in Context: Profession “Heal Thyself”

“Last Tuesday, the Center for Medicare and Medicaid Services (CMS) published its 2023 payment schedule for physicians along with changes in the Medicare shared savings program, outpatient, behavioral and home health services…

Healthcare is at a crossroad. Physicians are caught in the crossfire of policies to lower health costs and capital necessary to transform the system from specialty care and volume-based incentives to value and wellbeing.”

Paul Keckley, Nov. 7, 2022


Laura AppelMHA in the News

The MHA received media coverage on the continued surge of RSV cases across Michigan’s pediatric hospitals that is stressing hospital capacity during the week of Nov. 6. Laura Appel, executive vice president …

CMS Finalizes Rate Cuts in 2023 Medicare Physician Fee Schedule

The Centers for Medicare & Medicaid Services (CMS) recently released the 2023 Medicare Physician Fee Schedule (PFS) final rule, effective Jan. 1, 2023. The rule reduces the PFS conversion factor by $1.55 (4.7%) to $33.06 in a calendar year (CY) 2023 from $34.61 in CY 2022, which reflects a required statutory update of 0% and the expiration of the one-year Congress-approved 3% increase in PFS payments for CY 2022. The finalized rule also includes changes in policies for telehealth, opioid use disorder, dental services, and the Medicare Shared Savings Program (MSSP).

The CMS finalized:

  • Expanding the telehealth category 3 codes list and extend coverage through Dec. 31, 2023
  • Modifying opioid treatment program payment rates that will increase overall payments for medication-assisted treatment and other treatments for opioid use disorder
  • Clarified that Medicare Fee-For-Service (FFS) payment for dental services when it is an integral part of treatment, such as dental exams and necessary treatment before organ transplants, cardiac valve replacements and valvuloplasty procedures
  • Making several changes to increase participation in the MSSP, including updates to benchmarks to sustain long-term participation and reduce costs. The CMS also updated quality measurement policies, including a new healthy equity adjustment that will award bonus points to accountable care organizations serving high proportions of underserved beneficiaries

Members with questions and feedback should contact Renée Smiddy at the MHA.

CMS Releases Final Rule to Update OPPS

The Centers for Medicare and Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service (FFS) outpatient prospective payment system (OPPS) effective Jan. 1, 2023.

The rule restores 340B drug payments to the default rate, generally average sales price (ASP) plus 6%, up from the previous ASP minus 22.5%, in response to the recent federal Supreme Court (SC) ruling.  The CMS notes that the agency is still evaluating how to apply the SC’s decision in the American Hospital Association (AHA) v Becerra case which ordered the CMS to restore payments. The CMS will address this in future rulemaking prior to the 2024 OPPS proposed rule.  

The MHA, along with the AHA and others, continue to urge the Court to order the CMS to promptly repay hospitals harmed by the unlawful cuts implemented in 2018 and ensure that no hospitals are not penalized.  Other provisions of the final rule include:

  • Increasing the conversion factor by a net 1.7% after budget neutrality adjustments from $84.18 to $85.59 for hospitals that comply with the CMS outpatient quality reporting (OQR) program requirements.
  • Establishing the new rural emergency hospital provider type to allow critical access hospitals and rural hospitals with less than 50 beds to continue providing essential outpatient services while eliminating inpatient services.
  • Exempting rural sole community hospitals from the site neutral clinic visit cuts and instead paying the full OPPS rate for visits provided at grandfathered off-campus hospital outpatient departments.
  • Increasing the cost outlier threshold by 40% from $6,175 to $8,625, to maintain outlier payments at the targeted 1% of total OPPS payments, resulting in fewer cases qualifying for an outlier payment.
  • Removing 11 services from the inpatient only list and adding 8 services that were newly created by the American Medical Association Common Procedural Terminology Editorial Panel.
  • Implementing a permanent 5% cap on wage index decreases.
  • Adding four procedures to the Ambulatory Surgical Center covered procedures list.
  • Requiring prior authorization for an additional service category,­ facet joint interventions, beginning dates of service on or after July 1, 2023.
  • Continuing payment for virtual behavioral health services with an in-person service required within six months prior to the initiation of the virtual service and then annually thereafter, with exceptions made based on beneficiary circumstances. The CMS clarified that the requirement for an in-person visit within six months prior to the initial services is not required for patients who began receiving services during the public health emergency (PHE) or during the 151-day period following the end of the PHE.
  • Maintaining the current policy of providing separate payment for non-opioid pain management drugs and biologicals that function as supplies in the ASC setting.
  • Implementing a payment adjustment for costs incurred for domestically manufactured National Institute for Occupational Safety and Health (NIOSH)-approved surgical N95 respirators with payments provided biweekly as interim lump-sum payments and reconciled at cost report settlement for cost reporting periods beginning on or after Jan. 1, 2023.
  • Creating a new G-code for dental rehabilitation services that require monitored anesthesia and the use of an operating room and assigning it to APC 5871 (Dental Procedures), effectively increasing the payment from roughly $200 to approximately $2,000.
  • Changes to the hospital OQR program including:
  • Making the Cataracts: Improvement in Patient’s Visual Function within 90 Days Following Cataract Surgery (OP-31) measure voluntary rather than mandatory beginning with the 2025 reporting period and 2027 payment determination.
  • Aligning the patient encounter quarters for chart-abstracted measures to the calendar year for annual payment update determinations.
  • Adding a targeting criterion for measure data validation.

The MHA will provide hospitals with an updated impact analysis and additional details of the rule in the coming weeks.

Members with questions should contact Vickie Kunz at the MHA.

CMS Releases Final to Update Medicare PPS Effective 2023

The Centers for Medicare and Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service home health (HH) prospective payment system (PPS) effective Jan. 1, 2023. Key provisions include:

  • A net 1.0% decrease in the national 30-day standardized payment amount from $2,031.64 to $2,010.69 after budget neutrality adjustments, compared to the proposed 6.25% decrease. HHs that fail to comply with HH quality reporting program requirements are subject to a two percentage point reduction and are subject to a rate of $1,972.02.
  • A seven percentage point cut to all payments to achieve budget-neutrality for the Patient-Driven Groupings Model phased in over two years, with a 3.5 percentage point cut in 2023 and 2024.
  • A permanent 5% cap on wage index decreases.
  • Required submission of patient assessment data on all patients, regardless of payer, with a phased approach beginning Jan. 1, 2025, instead of 2024 as proposed.
  • Changes to the Expanded HH value-based purchasing model, including definitions for the baseline and model year and changing the baseline year for the 2023 program year to 2022 to use the most recently available data.

The MHA will provide members with an updated impact analysis and additional details of the final rule within the next few weeks. Members that have not received impact analyses in the past for affiliated, free-standing HH agencies are encouraged to provide the agency’s CMS certification number (also known as Medicare provider number), agency name and federal information processing standards code in order to receive an estimated impact analysis in the future.

Members with questions should contact Vickie Kunz at the MHA.

Webinar Prepares for The Joint Commission and CMS Health Equity Requirements

Recently, The Joint Commission (TJC) and the Centers for Medicare & Medicaid Services (CMS) announced their commitment in driving the next decade of health equity for people who are underserved. The commitment to advancing health equity will help foster a healthcare system that benefits all for generations to come. These new requirements include the expansion of collection, reporting and analysis of standardized data. Hospitals and health systems must be prepared to understand and report these new requirements to continue to receive reimbursement from the CMS.

The MHA Health Foundation webinar Prepare for The Joint Commission and CMS Health Equity Requirements will:

  • Describe the new health equity-related reporting requirements to stay compliant with TJC and the CMS.
  • Demonstrate how you can assess hospital readiness to meet the new requirements.
  • Outline sources for data, including hospital community health needs assessments, for health equity reporting.
  • Describe how to assess and analyze your patients’ social risk factors and how these needs evolve over time.

The webinar is scheduled from 11 a.m. to noon, Nov. 15 and MHA-member hospitals can register for an unlimited number of connections per hospital/entity for $200.

Members with questions should contact Erica Leyko at the MHA.

CMS Announces 2023 Medicare Premiums and Deductibles

The Centers for Medicare & Medicaid Services (CMS) recently announced the calendar year 2023 Medicare fee-for-service Part A deductible for inpatient hospital services will increase by $44 to a new total of $1,600. The Part A daily coinsurance amounts will be:

  • $400 for days 61-90 of hospitalization in a benefit period.
  • $800 for lifetime reserve days.
  • $200 for days 21-100 of extended care services in a skilled nursing facility in a benefit period.

The monthly Part A premium, paid by beneficiaries who have fewer than 40 quarters of Medicare-covered employment and certain people with disabilities, will increase by $7 in 2023 to a total of $506. Certain voluntary enrollees eligible for a 45% reduction in the monthly premium will pay $278.

The annual deductible for Medicare Part B will decrease by $7 to a total of $226, while the standard monthly premium for Medicare Part B will decrease by $5.20 to a total of $164.90.

Members with questions should contact Vickie Kunz at the MHA.

MHA Monday Report Sept. 12, 2022

MHA Monday Report

Healthcare Remains Michigan’s Largest Private-sector Employer Despite Pandemic Losses

The Partnership for Michigan’s Health reports healthcare directly employed nearly 572,000 Michigan residents in 2020, demonstrating that healthcare continues to be the largest private-sector employer in the state despite staffing losses attributed to the COVID-19 pandemic. The 2022 release …


Lt. Gov. Hosted at Capitol Advocacy Center


MHA Drafts Comments on 340B Provisions and REH Payment Policies


MHA Offering Basics of Case Management Boot Camp


Implicit Bias Trainings Available to Meet LARA Requirement


Webinar Explores Guidelines for Strategic Planning


Virtual Nurse Preceptor Academy Supports New Employee Training and Retention


MHA CEO Report – Time to Focus on Cybersecurity


AHA Trustee Insights Outlines Financial Turnaround and Succession Planning


Paul KeckleyThe Keckley Report

In Campaign 2022, Healthcare Voters Will Matter More

“Today begins the countdown to election day November 8: in 63 days, voters will elect 36 Governors, 30 State Attorneys General, 27 Secretaries of State, 35 US Senators, 435 US House of Representatives and State Legislators in 46 states. It’s a consequential election for the country and for its healthcare industry…

Campaigns will avoid healthcare issues other than abortion. Conceding that healthcare is expensive and access uneven, most midterm campaigns will default to partisan themes…”

Paul Keckley, Sept. 6, 2022


News to Know

  • The deadline to provide contact information in preparation for the state’s anticipated grant program to implement an Emergency Department Medication for Opioid Use Disorder program has been extended to Sept. 23.

MHA in the News

MHA CEO Brian Peters

News to Know – Week of Sept. 12

  • The Centers for Medicare and Medicaid Services recently released a final rule to update the Medicare fee-for-service inpatient prospective payment system for fiscal year 2023, which begins Oct. 1, 2022. Hospitals are invited to participate in a national webinar hosted by DataGen at 3 p.m. Sept. 14 to review key provisions of the rule and estimated impact analysis provided by the MHA. The webinar is free of charge, but registration is required.
  • The deadline to provide contact information in preparation for the state’s anticipated grant program to implement an Emergency Department Medication for Opioid Use Disorder program has been extended to Sept. 23.

MHA Drafts Comments on 340B Provisions and REH Payment Policies

The MHA has drafted comments in response to the Centers for Medicare and Medicaid Services (CMS) proposed rule to update the Medicare fee-for-service (FFS) outpatient prospective payment system (OPPS) for calendar year 2023. The MHA submitted comments regarding the 340B provisions in mid-August urging the CMS to:

  • Restore payment rates for 340B drugs to average sales price (ASP) plus 6%.
  • Hold all hospitals harmless for 2018-2022 claims.
  • Find new funds to restore 340B payments to ASP plus 6% with no reduction to the outpatient conversion factor.

The MHA also prepared comments in response to the proposed payment policies for rural emergency hospitals (REHs), a new hospital designation established by the Consolidated Appropriations Act, for critical access hospitals and rural prospective payment system hospitals with fewer than 50 beds.

The MHA recently posted hospital-specific estimated impact reports of the OPPS proposed rule on the hospital association reporting portal (HARP) for members to access and encourages hospitals to review the impact of the proposed rule on their operations and submit comments to the CMS by 5 p.m. Sept. 13. The CMS is expected to release a final rule to update the OPPS, including finalization of REH payment policies around Nov. 1 for the Jan. 1, 2023 effective date.

The MHA will provide an updated impact analysis following release of the final rule. Members with questions should contact Vickie Kunz at the MHA.