New CMS Requirements for Reporting of Hospital Respiratory Data

The MHA recently submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed updates to the Medicare Inpatient Prospective Payment System for fiscal year 2025. Updates to the hospital and Critical Access Hospital conditions include revisions to the Conditions of Participation for infection prevention and control programs and antibiotic stewardship programs.

Part of the proposed rule aims to extend the current COVID-19 and influenza reporting requirements to include respiratory syncytial virus, with a new mandate for weekly reporting by hospitals. The MHA, with insights from the Association for Professionals in Infection Control & Epidemiology and feedback from member hospitals, expressed strong opposition about this proposal. The primary concern is the potential administrative burden it places on hospital’s infection prevention departments. During the COVID-19 public health emergency (PHE), hospitals faced significant challenges in meeting reporting requirements, often having to divert resources from direct patient care to data collection and reporting.

MHA members also voiced concerns about the utility and transparency of the data collected. Despite the vast amounts of information submitted during the COVID-19 PHE, hospitals have yet to receive actionable insights or reports summarizing the data. Without clear evidence that the data will be used effectively, the added burden of reporting seems unjustified, particularly when hospitals can analyze and use their data at the facility level, as needed.

Despite the MHA’s feedback, the CMS has finalized these new requirements. Members are encouraged to stay informed and prepare for these upcoming changes, effective Oct. 1, 2024.

Members with questions may contact Kelsey Ostergren at the MHA.

MHA Monday Report Aug. 12, 2024

MHA Shares State Impacts and Insights at Regional 340B Roundtable

MHA staff attended the Regional 340B Roundtable Aug. 7 in Florence, IN to join colleagues from the Indiana Hospital Association, Ohio Hospital Association, Kentucky Hospital Association and endorsed business partner, SunRx, to share best practices …


MHA Keystone Center Offers Learning Collaboratives for Peer Recovery Services

The MHA Keystone Center is partnering with the Community Foundation of Southeast Michigan to host a two-part, virtual series about peer recovery services for substance and opioid use disorders from 10 a.m. to 12 p.m. …


CMS Releases FY 2025 Final Rule for Skilled Nursing Facilities

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service prospective payment system for skilled nursing facilities for federal fiscal year (FY) 2025. Key provisions …


Kelley Cawthorne Ad


MHA Webinar Tying Person and Family Engagement to Culture Performance Deadline Approaching

One week remains before the registration deadline for the MHA webinar Tying Person and Family Engagement to Culture and Performance. Scheduled from noon to 1 p.m. Aug. 20, the webinar provides an opportunity for hospitals to …


CMS Releases FY 2025 LTCH Prospective Payment System Final Rule

The Centers for Medicare & Medicaid Services (C recently released a final rule to update the Medicare fee-for-service long-term care hospital (LTCH) prospective payment system for fiscal year 2025. Specifically, the final rule: Increases …


CMS Releases FY 2025 Hospital Inpatient Prospective Payment System Final Rule

The Centers for Medicare & Medicaid Services recently released a final rule to update the Medicare fee-for-service hospital inpatient prospective payment system for fiscal year (FY) 2025. Highlights of the final rule include: …


The Keckley Report

Big Sky is Cloudy for Hospitals

“As state hospital association leaders assemble in Big Sky, Montana this week, the environment for hospital-friendly legislation is threatening at best:

The public’s trust in hospitals has eroded. Hospital financial performance is a mixed bag: some are profitable and many aren’t. Congress thinks hospitals need more regulation to increase price transparency, require ownership disclosure, verify community benefits that justify tax exemptions and impose restrictions on hospital private equity investments. And programs through which state and federal health policies are authorized—HHS, CMS, FTC, FDA, CMMI et al—are in limbo as a result of the June 28, 2024 Chevron ruling by the Supreme Court. …

For hospitals, effective advocacy is imperative: the reservoir of good will enjoyed for decades is evaporating. Advertising “we’re there for you” is timely as rural providers need a lifeline, and public castigation of “corporate insurers and billionaire critics” necessary to rally supporters. But beyond these, two things are clear:

  • The marketplace for “hospitals” is fundamentally different than the past requiring a clearer value proposition and fresh messaging.
  • And in states, hospitals will encounter unique opportunities and challenges in plotting strategies for their future. No two are alike.

Big Sky is a symbolic locale for this week’s meeting of state health executives: the Big Sky over hospitals is cloudy.”

Paul Keckley, Aug. 5, 2024

CMS Releases FY 2025 Hospital Inpatient Prospective Payment System Final Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service hospital inpatient prospective payment system (IPPS) for fiscal year (FY) 2025.

Highlights of the final rule include:

  • Increasing the standard operating rate by a net 1.7%, after budget neutrality adjustments, from $6,497.77 to $6,606.51, for hospitals that successfully comply with the CMS quality reporting program and electronic health record requirements. Hospitals that do not meet requirements for these programs are subject to a lower annual update.
  • Updating the federal capital rate by 1.3%, from $503.83 to $510.51.
  • Increasing the cost outlier threshold by 8%, from $42,750, to $46,152, to maintain the target of paying 5.1% of aggregate IPPS payments as outlier.
  • Revising core based statistical areas (CBSAs) as a result of the new Office of Management and Budget labor market delineations based on the 2020 Decennial Census.
  • Implementing a separate IPPS payment for small, independent hospitals, defined as those with 100 or fewer beds that are not part of a chain organization, to voluntarily establish and maintain a six-month buffer stock of one or more of 86 essential medicines. This separate payment will not be budget neutral.
  • Creating 12 new Medicare Severity Diagnosis Related Groups (MS-DRGs) and deleting 5 MS-DRGs, most of which are within Major Diagnostic Category 08 (Diseases of the Musculoskeletal System and Connective Tissue).
  • Establishing a new mandatory CMS Innovation Center model, Transforming Episode Accountability Model, that would provide bundled payment for five surgical procedures to hospitals in 188 selected CBSAs.
  • Using the average of FY 2019, 2020 and 2021 Worksheet S-10 uncompensated care cost (UCC) data for the UCC pool allocation, which comprises 75% of Medicare disproportionate share hospital (DSH) payments. After adjusting this pool for the percent of uninsured individuals, total DSH and UCC payments will be approximately $200 million less than FY 2024 payments.
  • Adding seven new measures, primarily focused on patient safety-related practices and outcomes to the inpatient quality reporting program, while removing five measures and modifying two existing measures, including the Hospital Consumer Assessment for Healthcare Providers and Systems survey measure.
  • Increasing the performance-based scoring threshold from 60 points to 70 points, beginning with the electronic health record reporting period in calendar year (CY) 2025, and from 70 points to 80 points in CY 2026.
  • Increasing the number of mandatory electronic clinical quality measures that hospitals must report for both the IQR and the Promoting Interoperability programs.
  • Modifying and making permanent weekly reporting by hospitals, including critical access hospitals, of acute respiratory illness data beginning Nov. 1, 2024, on confirmed infection of COVID-19, influenza and respiratory syntactical virus among hospitalized patients, hospital capacity and limited patient demographic information, including age.
  • Finalizing the proposal to separate the Antimicrobial Use and Resistance Surveillance measure into separate measures (an Antimicrobial Use Surveillance measure and an Antimicrobial Resistance Surveillance measure), beginning with the electronic health record reporting period in CY 2025.
  • Adopting severity level changes related to seven social determinants of health diagnosis codes (SDOH Z codes) that describe inadequate housing and housing instability, moving these from non-complication or comorbidity to complication or comorbidity for FY 2025.

The MHA continues to review the final rule and will provide hospitals with an updated estimated impact analysis in the next few weeks. Members with questions should contact Vickie Kunz at the MHA.

CMS Releases FY 2025 LTCH Prospective Payment System Final Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service long-term care hospital (LTCH) prospective payment system (PPS) for fiscal year 2025.

Specifically, the final rule:

  • Increases the standard LTCH PPS rate by a net 2.6% from $48,117 to $49,383 for LTCHs that meet the CMS quality program reporting requirements. LTCHs that fail to meet these requirements are subject to a two percentage point reduction to the annual update.
  • Rebases the market basket to use 2022 cost report data instead of 2017.
  • Increases the high-cost outlier (HCO) threshold by 29% for standard LTCH cases from the current $59,873 to $77,048, to achieve the target of paying roughly 8% of aggregate LTCH payments as HCO payments.
  • Continues to pay cases at the site neutral rate if they fail to meet LTCH criteria.
  • Updates the cost outlier threshold for site-neutral cases to the inpatient PPS threshold finalized at $46,152, up from $42,750.
  • Revises core based statistical areas as a result of the new Office of Management and Budget labor market delineations based on the 2020 Decennial Census.
  • Updates the LTCH quality reporting program to require reporting of four new items to the LTCH Continuity Assessment Record and Evaluation Data Set, social determinant of health category. These include one item each for living situation and utilities and two items for food.
  • Modifies the Transportation assessment item to simplify response options and revise the look-back period.
  • Extends the window for admission assessments from three days to four, beginning with patients admitted on Oct. 1, 2026.

The MHA continues to review the final rule and will provide LTCHs with an updated estimated impact analysis in the next few weeks.  Members with questions should contact Vickie Kunz at the MHA.

 

CMS Releases FY 2025 Final Rule for Skilled Nursing Facilities

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

Key provisions include:

  • Increasing the per diem federal rate by a net 4.2% 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 72%.
  • Making technical updates to the code mappings used to classify patients under the Patient Driven Payment Model that assigns patients to clinical categories.
  • Revising the regulations to allow the CMS to impose additional financial penalties on facilities with health and safety deficiencies as identified.
  • 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 transportation item on the patient assessment item to simplify response options while also using a defined 12-month 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.

The MHA will provide SNFs with an updated facility-specific impact analysis and additional details on the final rule, effective Oct. 1, in the near future. Members with questions should contact Vickie Kunz at the MHA.

MHA Monday Report Aug. 5, 2024

Michigan Supreme Court Issues Ruling on Paid Sick Leave & Minimum Wage

The Michigan Supreme Court issued a ruling July 31 in Mothering Justice v. Attorney General that upholds voter initiative petitions on paid sick leave and minimum wage. Those laws, as originally enacted, will go into …


Michigan Medicaid Facility Rates Increased for Dental Procedures Under General Anesthesia

The Michigan Department of Health and Human Services issued a final policy to increase Medicaid payment rates for dental services provided to patients under general anesthesia in ambulatory surgical centers and outpatient hospitals, …


MDHHS and Michigan 211 Launches New Website for Grief and Bereavement Support

The Michigan Department of Health and Human Services (MDHHS), in partnership with Michigan 211, recently launched a new website aimed to providing support services for families who have experienced loss of a mother or infant. …


Kelley Cawthorne Ad


CMS Releases FY 2025 Final Rule for Inpatient Psychiatric Facilities

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service prospective payment system for inpatient psychiatric facilities for federal fiscal year (FY) 2025. Key provisions …


Applications Open for MI Behavioral Health Internship Stipend Program

The Michigan Department of Health and Human Services has allocated $3.5 million for the Behavioral Health Internship Stipend Program. This program will offer up to $15,000 stipends to student interns enrolled in behavioral health …


CMS Releases FY 2025 Final Rule for Inpatient Rehabilitation Facilities

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service prospective payment system for inpatient rehabilitation facilities for federal fiscal year (FY) 2025. Key provisions …


The Keckley Report

The Five Characteristics of the Blame and Shame Game in Healthcare

“The Blame and Shame Game spikes in election cycles as candidates pit themselves against their opponents. Healthcare plays its own version: last week is indicative: …

As Congress heads home for their August recess this week and Campaign 2024 intensifies, there’s no doubt healthcare issues will be prominent in local, state and national news. It’s also likely much of that coverage will be negative due to mounting cynicism about the industry’s business, consolidation, and opaque pricing and intensifying blame and shame games between hospitals and insurers, primary care and specialty physicians, PBMs and drug manufacturers, public health and healthcare delivery and others.

Blame and shame rhetoric about these tensions is not new, but its intensity is higher than ever as are the stakes. Blame and Shame is Chapter Two in most organization’s playbooks. Chapter One, the organization’s mission, vision, purpose and strategic plan is often missing and frequently premised on false assumptions. Thus, the “strategy” defaults to calling out the wrongdoings/shortcoming of adversaries and critics and little more. And their rhetoric is laced with terms for which accountability is suspect i.e. community benefit, affordability, value, quality and others. …

Here’s too much at stake to expect any inside sector to do this on its own: Blame and Shame is easier.”

Paul Keckley, July 29, 2024


News to Know 

The Primary Election is Tuesday, Aug. 6. Polls open at 7 a.m. and close at 8 p.m. Voters in line at 8 p.m. can still cast ballots. Those who missed the deadline to register online or by mail can do so in-person through Election Day with their local clerk. To check registration status, polling location or preview a ballot, visit the Michigan voter webpage.

CMS Releases FY 2025 Final Rule for Inpatient Psychiatric Facilities

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service prospective payment system (PPS) for inpatient psychiatric facilities (IPFs) for federal fiscal year (FY) 2025. Key provisions of the rule include:

  • Increasing the Electroconvulsive Therapy (ECT) payment per treatment by 71.5% from $385.58 to $661.52 for IPFs that comply with IPF quality reporting program (QRP) requirements and $648.65 for IPFs that fail to report data. The CMS believes this will improve access to ECT services.
  • Decreasing the IPF PPS federal per diem base rate by a net 2.1% after all adjustments, from $895.63 to $876.53. IPFs that fail to comply with the CMS IPF QRP requirements would be paid using a base rate of $859.48.
  • 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 78.7% to 78.8%.
  • Increasing the cost outlier threshold by 14% from the current $33,470 to $38,110 to achieve the 2% target for outlier payments, as compared to aggregate IPF payments, decreasing the number of cases that qualify for outlier payments.
  • Finalizing changes to the patient-level adjustments.
  • Maintaining the existing facility-level adjustment factors for rural location, teaching status and emergency department.
  • Changes to the IPFQR Program:
    • Finalizing the proposed adoption of the 30-Day Risk-Standardized All-Cause Emergency Department Visit following an IPF discharge measure beginning with the FY 2027 payment determination.
    • Not finalizing the proposal to require IPFs to submit patient-level data on a quarterly basis based on comments received and determining that some IPFs may be unable to meet this requirement in the proposed timeframe.
  • Summarizing comments received about the IPF PPS Patient Assessment Instrument (IPF-PAI), as required by the Consolidated Appropriations Act, 2023 and considering the comments for development of the IPF-PAI and in future rulemaking.

The MHA will provide IPFs with an updated facility-specific impact analysis and additional details on the final rule, effective Oct. 1, in the near future. Members with questions should contact Vickie Kunz at the MHA.

CMS Releases FY 2025 Final Rule for Inpatient Rehabilitation Facilities

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

Key provisions of the rule include:

  • Increasing the IRF PPS payment rate by a net 2% after all adjustments, from $18,541 to $18,907. 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 74.4%.
  • Increasing the cost outlier threshold by 15.5% from the current $10,423 to $12,043 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 (beginning with patients admitted Oct. 1, 2026) using the IRF-Patient Assessment Instrument (IRF-PAI) as standardized patient assessment data elements under the social determinants of health (SDOH) category beginning with the FY 2028 IRF QRP including:
    • One item for living situation.
    • Two items for food.
    • One item for utilities.
  • Modifying the Transportation item collected in the IRF-PAI under the SDOH category beginning with patients admitted Oct. 1, 2026
  • Continuing to evaluate, refine and develop new measures for the IRF QRP to ensure Medicare patients and caregivers have meaningful information to make informed decisions.
  • Creating a five-star IRF QRP rating system to distinguish between quality of care offered by providers.

The MHA will provide IRFs with an updated facility-specific impact analysis and additional details on the final rule, effective Oct. 1, in the near future. Members with questions should contact Vickie Kunz at the MHA.

MHA Monday Report July 29, 2024

Governor Signs FY 25 Budget and FY 24 Supplemental

 

Gov. Whitmer signed the fiscal year (FY) 2025 state budget on July 24. The budget proposal fully funds the Michigan Medicaid program, including significant increases to provider-funded Medicaid reimbursements in FY 24 and 25. The budget also …

 


Governor Signs Law Reducing Medical Waste

Gov. Whitmer signed Senate Bill 482, now Public Act (PA) 105 of 2024, on July 23, which extends the timeline for the disposal of sharps containers. Previously, state law mandated that sharps containers be removed …

 


 

June Medicaid and Medicare Enrollment in Michigan

 

The MHA updated its analysis of Medicaid and Medicare enrollment to reflect June 2024 data. The analysis now includes program enrollment as a percentage of each county’s total population and the split between fee-for-service and …

 


CMS Releases 2025 Physician Fee Schedule Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the physician fee schedule (PFS) payment system effective Jan. 1, 2025. The proposal would: Reduce the PFS conversion factor by …

 


Webinar Explores Connection Between Person and Family Engagement and Performance

The MHA is hosting the webinar Tying Person and Family Engagement (PFE) to Culture and Performance from noon to 1 p.m. Aug. 20. The webinar will provide examples of how peers at hospitals are creating a PFE …

 


Engaging Providers and Transforming Revenue and Quality Performance Simultaneously

The MHA’s Endorsed Business Partner (EBP) program promotes industry-leading firms and connects member hospitals to solutions that alleviate pain points. The MHA recently endorsed ModusOne Health, which is the only physician-founded and operated clinical diagnosis improvement company (CDxI®) …


MDHHS

MDHHS Seeks Feedback from Older Adults and Caregivers on the 988 Suicide & Crisis Lifeline

The Michigan Department of Health & Human Services (MDHHS) is now surveying adults aged 60 and older and their caregivers about their experience with the 988 Suicide & Crisis Lifeline. The survey is scheduled to …

 


Expanding Peer Recovery Coach Services to Improve Patient Outcomes

The fiscal year (FY) 2025 budget includes critical funding to support the work of peer recovery coaches (PRCs) in Michigan hospitals. Kelsey Ostergren, director of health policy initiatives, MHA, and Michelle Norcross, senior director of safety & quality, MHA Keystone Center, share the impact these resources have on patients and communities …

 


Applications are Now Open for the Infection Prevention and Control Scholarship

The Association for Professionals in Infection Control and Epidemiology (APIC) has opened applications for the 2025 Critical Access Hospital (CAH) Scholarship program …


The Keckley Report

Campaign 2024 and US Healthcare: 7 Things we Know for Sure

“Over the weekend, President Biden called it quits and Democrats seemingly coalesced around Vice President Harris as the Party’s candidate for the White House. While speculation about her running mate swirls, the stakes for healthcare just got higher. Here’s why: …

Healthcare, to the Democratic-leaning voters is a right, not a privilege. Its majority think it should be universally accessible, affordable, and comprehensive akin to Medicare. They believe the status quo isn’t working: the federal government should steward something better. …

Regardless of the election outcome November 5, the U.S. healthcare industry will be under intense scrutiny in 2025 and beyond. It’s unavoidable.

Discontent is palpable. No sector in U.S. healthcare can afford complacency. And every stakeholder in the system faces threats that require new solutions and fresh voices.”

Paul Keckley, July 22, 2024


News to Know 

  • July 22 was the deadline to register by mail or online to be eligible to vote in the Primary Election on Aug. 6.

 


 

MHA in the NewsMHA CEO Brian Peters

Becker’s Hospital Review published an article July 23 that includes MHA CEO Brian Peters as one of 76 healthcare executives sharing their focus for the second half of 2024. Peters covered the importance of the …

 

CMS Releases 2025 Physician Fee Schedule Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the physician fee schedule (PFS) payment system effective Jan. 1, 2025.

The proposal would:

  • Reduce the PFS conversion factor by a net 2.8% from the current $33.29 to $32.36 after expiration of the 2.93% statutory payment increase for 2024 and a 0% conversion factor update.
  • Refine guidance regarding the complexity add-on code (G2211) for payment of evaluation and management visits.

Extend certain telehealth waivers through 2025 including:

  • Allowing providers to report enrolled practice addresses instead of home addresses when services are performed from their home.
  • Defining direct supervision to include virtual presence via audio/video real-time communications technology.
  • Revise the data reporting period and phase-in of payment reductions for clinical laboratory tests under the clinical laboratory fee schedule by updating the data reporting period to Jan. 1 – March 31, 2025.
  • Extending the phase-in of payment reductions by an additional year meaning that 2024 payments cannot be reduced below 2023 amounts and 2025-2027 payments cannot be reduced more than 15% compared to the previous year.
  • Delay implementation of the CMS’ rebased and revised Medicare economic index until future rulemaking.
  • Codify policies established in revised guidance for Medicare Part B and Part D drug inflation rebate programs and propose new and revised policies for these programs.
  • Exclude suspected anomalous spending from financial calculation for the Medicare Shared Savings Program (MSSP).
  • Add six new measures to the MSSP measure set and streamline reporting options
  • Add six new optional merit-based incentive payment system value pathways for 2025.

The MHA encourages members to contact Vickie Kunz by Aug. 30, regarding issues identified. Hospitals are encouraged to review the proposed rule and submit comments to the CMS by Sept. 9.  The CMS is expected to release a final rule around Nov. 1, for the Jan. 1, 2025, effective date.  Members with questions may contact Vickie Kunz at the MHA.