Healthcare Remains Key Piece of Executive Budget Recommendation

MHA CEO Brian Peters

The following statement can be attributed to Brian Peters, CEO of the Michigan Health & Hospital Association.

MHA CEO Brian PetersHealthcare access is vital for the physical and economic health of our local economies. This budget proposal presented by the Whitmer administration checks the boxes hospitals and health systems need when it comes to crucial state funding. It includes new funding that can make significant impacts on maternal and infant health, behavioral health and the healthcare workforce, while maintaining existing support for a variety of needed healthcare programs.

Hospitals and health systems are focused on addressing health disparities. Supporting additional maternal health services can help reduce the disparity in maternal health outcomes among non-white women. Expanded Medicaid reimbursement for behavioral health services will improve access across the state and benefit the workforce. We’re encouraged to see funding for tuition-free community college pathways for Michiganders. This can increase the number of students pursuing healthcare pathways and address workforce shortages. Continuing funding pools to support rural and critical access hospitals, obstetrical services, graduate medical education, the Healthy Michigan Plan and Michigan’s Medicaid populations will help maintain access to care for underserved populations throughout Michigan.

Gov. Whitmer is clearly a healthcare champion. We look forward to working with other legislative healthcare champions during the budget process to make sure Michigan healthcare providers have the necessary funding support to advance the health and wellness of Michiganders and communities.

Media Recap: Rural Health & Nurse Staffing Ratios

Brian Peters

The MHA received media coverage the week of Oct. 9 on rural healthcare challenges and legislation proposing state mandated nurse-to-patient staffing ratios.

Brian PetersThe Detroit Free Press published an article Oct. 12 on the closure of Kelsey Hospital. Included is a quote from MHA CEO Brian Peters and MHA data regarding critical access hospitals and rural emergency hospitals. The story describes the close relationship and important impact hospitals have within their communities.

“We have to provide new options … new opportunities,” said Peters. “I think all of us — as residents of this state — want to have access to care, whether we’re in the big city or whether we’re on vacation in northern Michigan, or we’re commuting from point A to point B. You never know when you’re going to need health care and we need to have that infrastructure protected into the future.”

Two op-eds opposing one-size-fits-all nurse staffing ratios were also published. The first appeared in Bridge Michigan from MHA CEO Brian Peters, explaining the MHA’s opposition and the dramatic impact the legislation would have on a patient’s ability to access healthcare services.

Sen. Curt VanderWall speaks to the Legislative Policy Panel in 2019.
Then Sen. Curt VanderWall presents to the MHA Legislative Policy Panel in 2019.

Rep. Curt VanderWall (R-Ludington) also published op-eds in the Ludington Daily News and Cleburne Times-Review explaining his opposition and the need for nurse staffing solutions that grow the talent pipeline while maintaining the ability to make staffing decisions at the local level.

Members with any questions regarding media requests should contact John Karasinski at the MHA.

Critical Access Hospital Infection Control Opportunity

The Association for Professionals in Infection Control and Epidemiology (APIC) and its subsidiary organizations, APIC Consulting Services and the Certification Board of Infection Control and Epidemiology, have joined together to launch the APIC Health Equity Fund. The APIC Health Equity Fund will help underwrite the cost of infection prevention and control (IPC) tools and resources for underserved U.S. communities. Critical Access Hospitals are eligible to apply for a scholarship that includes infection prevention services valued at more than $50,000, including APIC memberships, certification in infection control exams, annual conference registrations and 150 hours of IPC consulting.

Members with interested facilities are encouraged to submit an application by Sept. 30. For more details or to apply for this opportunity, please visit the APIC website.

Members with questions may contact Kelsey Ostergren at the MHA.

Legislative Fiscal Year 2024 State Budget Renews Commitment to Healthcare

Brian Peters

The following statement can be attributed to Brian Peters, CEO of the Michigan Health & Hospital Association.

Brian PetersThe fiscal year 2024 state budget approved by the Michigan Legislature renews a longstanding commitment lawmakers have made to the health and wellness of Michigan’s hospitals, health systems and communities.

We are extremely pleased to see the inclusion of new funding to support trauma centers and inpatient psychiatric services that will provide a net benefit of $92 million. Trauma centers at hospitals provide lifesaving treatment to people with the most severe injuries, ready at a moment’s notice for mass casualty events and catastrophic accidents with a vital network of EMS services. This added funding makes Michigan a national leader in recognizing the importance of access to trauma services and makes sure trauma centers can continue to be equipped with the resources needed to staff these services 24/7, year-round.

Michigan is also in the middle of a behavioral health crisis where the demand of patients needing inpatient care continues to increase. We commend the Legislature for recognizing this need and increasing rates to inpatient psychiatric facilities based on patient acuity to help hospitals afford the staffing, security and facilities necessary to accept patients with more severe illness.

In addition, the budget continues to support long-standing programs crucial to access to healthcare services throughout Michigan. These include funding for rural and critical access hospitals, obstetrical services, graduate medical education, the Healthy Michigan Plan and Michigan’s Medicaid population.

We look forward to a signed budget that provides hospitals with the needed support to continue to provide high-quality care to every patient.

MDHHS Releases Proposed Policy on REH Reimbursement

The Michigan Department of Health and Human Services (MDHHS) recently released a proposed policy to establish Medicaid reimbursement methodology for hospitals that convert to the new rural emergency hospital (REH) provider type. Critical access hospitals and rural hospitals with 50 or fewer beds are eligible to apply for the Medicare REH designation effective Jan. 1, 2023.

Hospitals that convert to the REH designation are required to update their enrollment and subspeciality with the MDHHS and must end date their inpatient services. Providers must notify the MDHHS via the Community Health Automated Medicaid Processing System within 35 days of any change to their enrollment information.

The MDHHS will reimburse REHs using existing Outpatient Prospective Payment System (OPPS) methodology. Critical access hospitals that convert to the REH designation will continue being paid based on the higher OPPS payment factor while others will be paid based on their current payment factor. The MDHHS updates the outpatient payment factors annually effective Jan. 1 to maintain budget neutrality following the Medicare update.

Hospitals are encouraged to review existing supplemental payment program policy to evaluate the potential impact. While the proposed policy does not provide specifics, the MHA anticipates that REHs will continue to receive outpatient Medicaid Access to Care Initiative and Hospital Rate Adjustment payments. The MHA will ask the MDHHS to clarify how the REH conversion will impact supplemental payment programs in the final policy. Hospitals are encouraged to review the proposed policy and submit comments to the MDHHS by May 10.

Members that are evaluating REH conversion are encouraged to contact Lauren LaPine at the MHA and  members with questions regarding the proposed reimbursement policy should contact Vickie Kunz at the MHA.

MHA CEO Report — The Challenges for Rural Hospitals

“The country is lyric, the town dramatic. When mingled, they make the perfect musical drama” Henry Wadsworth Longfellow

Having just returned from the annual American Hospital Association (AHA) Rural Health Care Leadership Conference, where I was joined by a strong contingent of MHA members and staff, the future of our rural hospitals has been top of mind.

When I was in graduate school at the University of Michigan many years ago, I recall clearly our discussions related to rural health. In short, we were taught that rural America was statistically older, poorer and sicker than the rest of the country – and this demographic and socioeconomic reality led to all kinds of challenges for those responsible for the health of rural populations and the viability of rural hospitals.

Fast forward to the most recent (2020) census and this dynamic remains true. In addition, we discovered that between 2010 and 2020, rural America actually lost population for the first time in history. Here in Michigan, the latest projections indicate that while the total state population will grow moderately over the next 20 years, the population in rural Michigan will remain flat or even decrease.

The operating environment has never been more difficult for healthcare organizations, for reasons we have documented at length in prior CEO Reports. This statement is particularly true for rural hospitals – 100 of which from across the country have actually closed since 2005. Many more have had to make the difficult decision to terminate service lines or otherwise scale back their operations to keep their doors open. What is driving these challenges?  A few items come immediately to mind:

  • An older and poorer population translates into a higher percentage of government payors (Medicare and Medicaid), which traditionally do not fully cover the true cost of care.
  • The traditional volume-based reimbursement model that has been one of the cornerstones of American healthcare does not serve rural providers – which often lack sufficient volume – particularly well. The pitfalls of the volume-based model were on full display during the worst days of the COVID-19 pandemic, particularly when non-emergent procedures were suspended.
  • Recruiting physicians today most often involves recruiting a spouse as well; in other words, there must be a good job match for both parties to spur a relocation. Physician recruitment is more difficult in rural communities for the simple fact that there are fewer potential jobs for that spouse. In addition, the on-call coverage demands can be particularly significant in rural areas, because the number of available rotating on-call clinicians is simply fewer. I would be remiss if I didn’t mention the Merritt Hawkins firm, which is one of our original MHA Service Corporation Endorsed Business Partners, and is dedicated to working with our members to create solutions to some of the most vexing challenges of the day.
  • Lastly, it is no secret the country is in the middle of a behavioral health crisis, with a lack of available placements leading to behavioral health patients boarding in emergency departments throughout the state, awaiting placement in a more appropriate setting. Hospitals are experiencing higher costs caring for these patients, increasing security to protect other patients and staff, while receiving little to no reimbursement since these patients have yet to be admitted to an inpatient psychiatric unit. This lack of access is even worse in rural areas. For example, the Upper Peninsula only has one licensed child psychiatrist for the entire region.

The reality is that when we think about rural Michigan and the more densely populated areas of the state, we are all inextricably linked. There is no “us and them.” People from the big city travel every day to rural communities for conferences and events, meetings, sales calls, deliveries, vacations and visits with friends and family (and people from rural communities come to the big city for the same reasons). While we want to ensure the vibrancy of a hospital in a rural community so that the residents have access to quality healthcare, we should all want the same thing, because we never know when we might be on one of those sales calls or vacations and need that same access. This is not just theoretical, as I have countless stories about this phenomenon playing out in real life, and I suspect you do as well.

Moreover, hospitals are one of the largest – if not the largest – employers in many rural Michigan communities, playing a crucial role in the economic vibrancy of the state. Healthcare careers provide stable, good paying jobs and positively impact lives every day. Not only are hospitals important for access to care, but also as economic drivers. 121,000 total workers are associated with the healthcare sector in rural Michigan, including 81,000 direct jobs. These direct healthcare workers received $7.6 billion in total wages, salaries and benefits and contributed $1.4 billion in local, state and federal taxes. In addition, the existence of a hospital nearby is one very important item for businesses of all kinds when considering investment in a new factory, office or headquarters.

So, the vibrancy of our rural hospitals should be a priority. What is the MHA doing about it? As it turns out, we have done a lot. Beyond our advocacy on the traditional Medicaid and Medicare budgets, certificate of need, medical liability, workforce funding and many, many other public policy issues that affect all our members, here are just a few of our rural advocacy highlights:

  • We fought hard to secure passage of the Healthy Michigan Plan (our Medicaid expansion program) and have advocated for full funding in every budget cycle since. For the reasons cited above, this is particularly impactful for our rural hospitals.
  • We worked to pass, implement and protect the Critical Access Hospital program, which has created an important lifeline for 37 Michigan hospitals. And the MHA was successful in changing existing statue at the end of 2022 to make adoption of the new Rural Emergency Hospital designation possible for our members.
  • We have worked very hard to protect the 340B drug pricing program, which is vital to many rural hospitals and their ability to provide access to care to all in their communities. Our work includes advocacy with both the state legislature and Congress, and even in the federal courts, where the MHA has filed amicus curiae briefs related to recent 340B cases.
  • The MHA successfully advocated for two new supplemental Medicaid payment pools that specifically benefit our rural members with implementation of the rural access pool in fiscal year (FY) 2012 and the obstetrical stabilization fund in FY 2015. Our advocacy efforts were also successful in securing Medicaid outpatient rate increases in FY 2020, the first increase in two decades, followed by an additional increase in FY 2021. These increases resulted in a 63% increase for critical access hospitals and a 21% increase for all other hospitals compared to Jan. 1, 2020, rates.
  • We successfully advocated for an extension of both the Medicare-dependent Hospital and Low-volume Adjustment programs during the 2022 Congressional lame-duck session, which provide critical support to many rural hospitals.
  • Finally, we have successfully advocated for passage and implementation of state legislation that modernizes the scope of practice for certified registered nurse anesthetists and allows flexibility for each hospital to choose the anesthesia care model that best fits its location, staffing and resources to offer safe and effective patient care.

Our advocacy is also focused on ensuring our members can tell their story and connect with lawmakers, both at the state and federal levels. The MHA hosted its first ever Rural Advocacy Day last September in Lansing to facilitate conversation between rural hospital leaders and members of the Michigan Legislature. The MHA also accompanied members in February for the National Rural Health Association’s Rural Health Policy Institute event. MHA members met with Michigan’s congressional delegation and staff during the trip to discuss rural health issues facing Michigan hospitals. And if you haven’t yet had the opportunity to listen to the Rural Health Rising podcasts, I encourage you to tune in to our friend JJ Hodshire, the CEO of Hillsdale Hospital and an MHA Board member, as he does a fantastic job shining a light on a wide range of rural health issues – with an impressive set of special guests – in real time.

Successful advocacy and storytelling require teamwork. As mentioned above, for years we have partnered closely with the AHA and the National Rural Health Association. We have also enjoyed a close partnership with the Michigan Center for Rural Health (MCRH), and I am pleased to share Hunter Nostrant, CEO of Helen Newberry Joy Hospital, is a member of both the MHA Board of Trustees as well as the MCRH Board.

The mission of the MHA is to advance the health of individuals and communities, and in that context, we have always strived to represent all our members and communities. Each hospital is vital to the health of our great state. While the path forward may be difficult, I’m encouraged by the many rural hospital leaders – some of the nicest, and most talented people that I have met – that have developed innovative and strategic ways to address these challenges and position themselves to be able to care for their communities for years to come.

As always, I welcome your thoughts.

MHA CEO Report — Benefits of the State Budget

“We must find time to stop and thank the people who make a difference in our lives.” ― John F. Kennedy

We have rightfully spent a lot of time in the past two years thanking the heroes who work in our hospitals and other healthcare settings for the incredible work they have done in the face of extreme challenge.

I want to take a moment now to thank another group of people who have recently helped our cause through their bipartisan actions; our elected officials in Lansing were extremely busy the last week of June passing the fiscal year 2023 state budget, which has since been signed by Gov. Whitmer. Our MHA mission is to advance the health of individuals and communities — and this budget absolutely provides significant help in that regard. While some elements of the new budget represent long-standing MHA priorities, others are new funding items that have the potential to reshape access to care and help our members and the patients and communities they serve.

Our MHA team does a tremendous job advocating for the importance of items such as the Healthy Michigan Plan, graduate medical education of physician residents, disproportionate share hospital funding, maximization of our robust provider tax program and Medicaid payment rates, the rural access pool and obstetrical stabilization fund, and critical access hospital reimbursement rates. Every election cycle, new legislators are welcomed to Lansing and the MHA’s efforts never stop to ensure these decisionmakers are aware of the impact these budget items play in their communities. The bottom line is the financial viability of hospitals is increasingly reliant on these important programs, and the MHA is dedicated to protecting them.

Hospital closures continue to happen across the country. However, they have occurred at a much higher rate in states that have not participated in Medicaid expansion through the Affordable Care Act. Maintaining funding for our expansion program — the Healthy Michigan Plan — has been one of our top priorities, and the pandemic has made the importance of insurance coverage more important than ever. In short, when the pandemic hit and thousands of Michiganders lost their jobs, the Healthy Michigan Plan was there to ensure access to good healthcare.

Our hospitals that treat the highest numbers of uninsured and underinsured patients also qualify for disproportionate share hospital funding, which provides enhanced reimbursement to account for the higher costs of care. This pool is funded through hospital provider taxes that reduce the state’s general fund contribution to the overall Medicaid program.

Small, rural and independent hospitals can often experience financial challenges in a particularly acute way, thus items such as the rural access pool, obstetrical stabilization fund and critical access hospital reimbursement rates also support access to healthcare services in rural areas. Labor and delivery units typically do not contribute to positive margins, but they are extremely important for families and communities. The obstetrical stabilization fund provides additional means for hospitals in rural areas to maintain these services so expectant mothers can avoid driving exorbitant distances for these services. Lastly, the state also included $56 million in new funding to increase Medicaid reimbursement rates for primary care services, which will help individuals on Medicaid receive the necessary primary and preventative care that can help prevent hospitalizations and reduce overall healthcare costs.

The top concern of hospital leaders remains workforce sustainability, and the continued funding for graduate medical education is one tool we must continue to use to maintain the physician talent pipeline that is sorely needed. At the same time, we are extremely happy to see inclusion of state funds to expand access to Bachelor of Science in Nursing degree programs at the state’s community colleges to help address the nurse talent pipeline, a $56 million line item. This proposal was supported by the MHA when it was formally introduced, and we look forward to seeing our post-secondary partners implement it to grow the healthcare workforce.

Lastly, behavioral health investments have been at the forefront of our advocacy efforts for some time and we were very pleased to see new funding to improve and enhance state behavioral health facility capacity. Michigan lacks adequate capacity to treat patients with behavioral and mental illness and this new funding is an important and necessary step to address the shortage. Included is $50 million to expand pediatric inpatient behavioral health capacity, $30 million to establish crisis stabilization units and $10 million to fund the essential health provider loan repayment program to cover behavioral health professionals.

In total, the budget includes $625 million in new investments for behavioral health funding and investments in workforce. While this will not solve all the issues impacting hospitals, it provides needed resources and demonstrates the commitment of lawmakers to a healthy Michigan. This budget also signifies that our work must continue to advocate for the resources necessary for hospitals and health systems to care for all Michiganders. Once again, on behalf of the entire MHA family, I want to acknowledge and thank both Governor Whitmer, as well as lawmakers in the state House and Senate, for their support of this latest state budget. And I would also encourage anyone who cares about access to quality, affordable healthcare to engage in the process, share your stories and input with those who can make a difference going forward. But also remember to say thank you when they support our cause.

As always, I welcome your thoughts.

Member Feedback Requested on Rural Emergency Hospital Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) released a proposed rule June 30 that would establish conditions of participation (CoPs) that Rural Emergency Hospitals (REHs) must meet to participate in the Medicare and Medicaid programs. This proposed rule also includes changes to the Critical Access Hospital CoPs. Proposed payment and enrollment policies, quality measure specifications and quality reporting requirements for REHs will be included in future rulemaking. The CMS also modifies the provider agreement regulations to include REHs. The public comment period will end Aug. 29.

The MHA has been working closely with the Michigan Department of Health and Human Services (MDHHS) and the Michigan Department of Licensing and Regulatory Affairs (LARA) over the past few months to develop the licensure criteria and conversion process for eligible facilities in Michigan to convert to an REH after Jan. 1, 2023. The MHA will develop a comment letter in response to the proposed rule and share a draft with small/rural members prior to submission. To include input from Michigan hospitals eligible to convert to an REH in its comments, the MHA has created a brief survey to collect critical feedback that should be submitted by Aug. 1. Members with questions or concerns are encouraged to contact Lauren LaPine at the MHA.

Fiscal Year 2023 State Budget Advances Health of Individuals and Communities

Brian Peters

The following statement can be attributed to Brian Peters, CEO of the Michigan Health & Hospital Association. *The budget has since been signed by Gov. Whitmer on July 20, 2022.

Brian PetersThe fiscal year 2023 state budget approved by the Michigan Legislature provides necessary resources to assist hospitals and health systems in advancing the health of individuals and communities throughout our state. We appreciate the work and consideration placed by lawmakers that continues to protect hospital priorities.

These priorities include maintaining funding for the Healthy Michigan Plan, graduate medical education of physician residents, disproportionate share hospitals which treat the highest numbers of uninsured and underinsured patients, the rural access pool and obstetrical stabilization fund, and critical access hospital reimbursement rates which all support access to healthcare services in rural areas. Each of these areas are instrumental to keeping hospitals financially secure, particularly in areas serving vulnerable and underserved populations.

We are also extremely happy to see new funding to improve and enhance state behavioral health facility capacity and to address the healthcare workforce. Michigan lacks adequate capacity to treat patients with behavioral and mental illness and this new funding is an important and necessary step to address the shortage. The investment of state funds to expand access to bachelor of science in nursing degree programs at the state’s community colleges is a significant movement towards replenishing Michigan’s healthcare talent pipeline.

We look forward to a signed budget that provides the resources necessary for hospitals and health systems to care for all Michiganders.