Tag: FFS

MHA Drafts Comments on 340B Provisions and REH Payment Policies

Member News

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.

CMS Releases FY 2023 Final Rule to Update Long-term Care Hospital PPS

Member News

The Centers for Medicare and Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service (FFS) long-term care hospital (LTCH) prospective payment system (PPS) for fiscal year (FY) 2023, which begins Oct. 1, 2022. The rule will:

  • Increase the standard federal rate by a net 3.8% for cases that meet LTCH criteria for services provided by LTCHs in compliance with CMS quality program reporting requirements.
  • Continue paying cases that fail to meet the required LTCH criteria (diagnosis-related group (DRG), intensive care unit, or ventilator criteria) at the site-neutral rate under the dual-rate payment system implemented in FY 2016.
  • Establish a high-cost outlier (HCO) threshold of $38,518 for cases paid based on the LTCH standard rate, up 17% from the current $33,015 threshold, resulting in fewer cases qualifying for an outlier payment. The CMS adjusts this threshold annually to maintain outlier payments at the targeted 8% of aggregate LTCH payments. Cases paid at the site neutral rate are subject to the inpatient PPS HCO, finalized at $38,859 for FY 2023.
  • Set a permanent cap to limit annual wage index decreases at 5%.
  • Calculate Medicare Severity-Long Term Care-DRG relative weights using an averaging approach, with COVID-19 cases included and excluded and then averaging the two sets of relative weights.
  • Set a permanent cap on annual decreases at 10% for MS-LTC-DRG relative weights to mitigate negative impacts of significant weight decreases.

The MHA is continuing to review the final rule and will provide hospitals with an updated impact analysis in the near future. Members with questions should contact Vickie Kunz at the MHA.

Proposed Rule to Update Inpatient Rehabilitation Facilities Payment for FY 2023

Member News

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service (FFS) prospective payment system (PPS) for inpatient rehabilitation facilities (IRFs) for fiscal year (FY) 2023, which begins Oct. 1, 2022. Key highlights of the proposal include a/an:

  • 2.7% increase to the IRF standard federal rate for providers in compliance with the CMS IRF quality reporting program (QRP), resulting in a proposed rate of $17,698, up from the current $17,240, for IRFs that comply with the IRFQRP.
  • Update to the case mix group relative weights using updated FY 2021 claims and the most recent cost report data.
  • Permanent policy to smooth the impact of year-to-year payment reductions related to decreases in the wage index. The CMS is proposing that an IRF’s wage index for FY 2023 and subsequent years would not be less than 95% of its prior year wage index.
  • Increase in the labor-related share from the current 72.9% to 73.2%, which will increase payments for IRFs with a wage index greater than 1.0.
  • 37% increase in the outlier threshold amount from the current $9,491 to $13,038 to maintain estimated outlier payments at 3% of total estimated aggregate IRF PPS payments. This will result in fewer cases being eligible for an outlier payment.
  • Modification to existing facility payment adjustments for teaching, low-income and rural IRFs.
  • Update to the existing policy affecting displaced medical residents.
  • Solicitation of comments on expanding the current IRF transfer policy to include discharges to home health as recommended by the Office of Inspector General.
  • Requirement that IRFs collect quality data on all patients, regardless of payer, beginning Oct. 1, 2023.
  • Request for information on some quality reporting-related topics:
    • Potential inclusion of an updated healthcare-associated infection measure in the IRFQRP. The National Healthcare Safety Network Healthcare-associated Clostridioides difficile Infection Outcome Measure would use data from electronic health records.
    • Feedback on strategies to improve measurement of disparities in healthcare outcomes. The CMS requests input on its framework to collect, stratify and report quality performance data across programs, as well as specific methods the agency could use with the IRFQRP.

The MHA will review details of the proposed rule and provide IRFs with an estimated impact analysis for Medicare FFS patients soon. The CMS is accepting comments until May 31. Members with questions should contact Vickie Kunz at the MHA.

Association Submits Comments on Medicare Post-acute Care Proposed Rules

Member News

The MHA recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) regarding the proposed rules to update the Medicare fee-for-service (FFS) prospective payment systems for fiscal year (FY) 2022 for several post-acute care settings including:

The CMS proposes to adopt a new measure — COVID-19 vaccination among healthcare personnel — in the quality reporting program for these facilities and would collect data beginning Oct. 1, 2021, with the quarterly vaccination rate publicly reported on the Care Compare website. The MHA opposes the adoption of this measure prior to full approval by the Food and Drug Administration.

The CMS also included a request for information in each proposed rule seeking ways to close the health equity gap. While the MHA supports efforts to close the health equity gap, the comment letters expressed concern about the increased administration burden associated with additional quality measures and standardized patient assessment data elements. The MHA urged the CMS to honor its “Patients Over Paperwork” initiative and streamline, align and focus on measures that matter most for patient care and outcomes.

The MHA is preparing comments on the FY 2022 proposed rules to update the inpatient and long-term acute care hospital prospective payment systems and encourages hospitals to contact Vickie Kunz at the MHA by June 18 with any issues identified. Members will have access to the draft comment letters for these rules prior to the June 28 due date and are encouraged to submit their own comments. Members may direct questions on any of the proposed rules to Vickie Kunz at the MHA.