MHA Monday Report Aug. 15, 2022

MHA Monday Report

Primary Election Sets Field for November
MI Vote Matters


CMS Releases FY 2023 Final Rule to Update Hospital IPPS


CMS Releases FY 2023 Inpatient Psychiatric Facility Final Rule


Final Rule to Update Inpatient Rehabilitation Facilities Payment for FY 2023


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


Survey Published for Opioid Use Disorder Contacts


Hospitals Encouraged to Review Medicare Advantage Enrollment Plans


Address Healthcare Employee Retention with Data ToolsSalary.com


Paul KeckleyThe Keckley Report

Solving Healthcare Workforce Shortages Requires Taking Self-care More Seriously

“The Labor Department reported that the U.S. added 528,000 jobs in July including 69,600 in healthcare. The unemployment rate fell to 3.5%, June job openings were down to 10.7 million from 11.3 million in May and government officials announced that the economy has now recouped the 22 million jobs lost in the pandemic.

But the more sobering news is that inflation has negated the workforce’ 5.1% wage gain in the last year and 1 in 5 workers is looking for employment elsewhere for higher pay and better benefits. And it’s even worse in the healthcare delivery workforce—the hospitals, long-term care facilities, clinics and ancillary service providers where 12 million work. During the COVID-19 pandemic, hospital employee turnover increased to 19.5%–five times higher than the general workforce. And today, 45% of physicians report burnout—double the rate pre-pandemic.”

Paul Keckley, August 8, 2022


News to Know


MHA in the News

MHA CEO Brian Peters

Final Rule to Update Inpatient Rehabilitation Facilities Payment for FY 2023

The Centers for Medicare & Medicaid Services (CMS) recently released a final 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 provisions of the rule include:

  • Requirement that the IRF-patient assessment instrument be completed on ALL patients, regardless of payor, beginning Oct. 1, 2024. This is delayed from the proposed Oct. 1, 2023 reporting date.
  • A 3.7% net increase to the IRF standard federal rate for providers in compliance with the CMS IRF quality reporting program, resulting in a rate of $17,878, up from the current $17,240. This increase is higher than the 2.7% proposed net increase due to comments received urging the CMS to more accurately reflect inflationary pressures experienced by IRFs and other providers.
  • Unchanged labor-related share with the CMS maintaining the current 72.9%.
  • Updated case mix group relative weights using updated FY 2021 claims and FY 2020 cost report data.
  • Permanent policy to limit annual wage index decreases to 5%.
  • A 32% increase in the outlier threshold amount from the current $9,491 to $12,526 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.
  • Codification of the existing teaching status adjustment policy for IRF closures and displaced medical residents.
  • Indication that the CMS will respond in a potential future rule to comments received regarding expansion of the IRF transfer payment policy to include patients discharged to home health.

The MHA continues to review details of the final rule and will provide IRFs with an updated impact analysis for Medicare FFS patients in the near future. Members with questions should contact Vickie Kunz at the MHA.

MHA Monday Report April 11, 2022

MHA Monday Report

MHA Covid-19 update

Combating the Novel Coronavirus (COVID-19): Week of April 4

The Michigan Department of Health and Human Services reported there were an average of 752 new confirmed and suspected COVID-19 cases per day from April 2 through April 6. As of April 6, 453 adults and 17 children were hospitalized with confirmed and suspected cases; 96 adults were in intensive care units, 39 of them …


capitol building

Prior Authorization Bill Signed into Law

Legislation to decrease wait times for commercial insurance prior authorization requests was signed into law by Gov. Gretchen Whitmer April 7. Senate Bill 247, introduced by Sen. Curt VanderWall (R-Ludington), will shorten the timeline for approval to seven calendar days or 72 hours for urgent requests, as well as ensure that …


Medicaid Proposed Policy to Allow Back Transfers for NICU Infants

The Michigan Department of Health and Human Services recently released a proposed policy, effective July 1, 2022, allowing authorization for return transfers of stabilized infants from a neonatal intensive care unit back to the community hospital from which the patient was …


Proposed Rule to Update Inpatient Rehabilitation Facilities Payment for FY 2023

The Centers for Medicare & Medicaid Services recently released a proposed rule to update the Medicare fee-for-service prospective payment system for inpatient rehabilitation facilities for fiscal year 2023, which begins Oct. 1, 2022. Key highlights of the proposal include …


CMS Releases FY 2023 Proposed Rule for Inpatient Psychiatric Facilities

The Centers for Medicare & Medicaid Services recently released a proposed rule to update the Medicare fee-for-service prospective payment system for inpatient psychiatric facilities for fiscal year 2023, which begins Oct. 1, 2022. Key highlights of the proposal include …


Webinar Focused on Governance and Leadership Accountability

Where is the line between governance and management? The truth is each board must set its own boundaries on governance versus management decisions, and boards must continuously revisit this line. The webinar You and Your Board: Creating a Synergistic Combination, offered from noon to 1 p.m. April 27 …


MHA Hosts Twitter Chat on Emergency Department Medication for Opioid Use Disorder

The MHA hosted a one-hour Twitter chat March 4 to discuss Emergency Department (ED) Medication for Opioid Use Disorder (MOUD). The chat allowed participants to engage with their peers and share information and resources related to ED MOUD, as many of these programs help address …


Explore Resources During Workplace Violence Awareness Month

Healthcare workers across the country are experiencing a growing rate of incidents of violence against front-line caregivers, including workers in Michigan. In fact, healthcare workers are nearly four times more likely to experience violence than individuals in other industries, according to the …


Paul KeckleyThe Keckley Report

Medicare Trustees’ NHE Report: Interesting Read but Understandably Flawed

“Last Monday, Medicare Trustees released the 56th edition of their National Health Expenditures (NHE) Forecast for 2021-2030 which is widely used by policymakers and operators to gauge what’s ahead for U.S. healthcare. Regrettably, it’s flawed.”

Paul Keckley, April 4, 2022


News to Know

The Circle of Life Awards recognize innovative palliative or end-of-life care providers that measure and evaluate the impact of their work on patients, family and/or the community. Part 1 applications for the 2023 awards will be accepted through May 31.

Final Rule Released for FY 2022 Inpatient Rehab Facility Prospective Payment System

The Centers for Medicare & Medicaid Services (CMS) released a final rule to update the Medicare fee-for-service prospective payment system for inpatient rehabilitation facilities (IRFs) for fiscal year (FY) 2022, which begins Oct. 1, 2021.

Key provisions of the rule will:

  • Increase the standard federal rate by 2.3% from $16,856 to $17,240 for facilities that comply with the IRF quality reporting program (QRP). Facilities that fail to comply are subject to a 2 percentage point reduction.
  • Increase the cost outlier threshold by 20% from $7,906 to $9,491, resulting in fewer cases qualifying for an outlier payment.
  • Modify the IRF QRP by:
    • Adding the COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) measure, requiring IRFs to report HCP vaccinations in their facilities beginning with the FY 2023 IRF QRP.
    • Modifying the denominator for the Transfer of Health Information to the Patient-Post Acute Care (PAC) quality measure to exclude patients discharged home under the care of a home health or hospice provider.
    • Finalizing its proposals regarding publicly reported data affected by COVID-19 reporting exemptions by calculating assessment-based measures using data from the second through fourth quarters of 2019 and claims-based measures using all four quarters of 2018 and the third and fourth quarters of 2019 for updating the Care Compare website in December 2021.

The CMS sought feedback on closing the health equity gap and is taking all comments into consideration as the agency continues efforts to address and develop policies. The CMS also continues working to improve the quality of healthcare through measurement, transparency and public reporting of data using Fast Healthcare Interoperability Resources in Support of Digital Quality Measurement within the IRF QRP, aligning where possible with other quality programs.

The MHA will provide IRFs with an updated estimated impact analysis and summary of the final rule soon. Members with questions should contact Vickie Kunz at the MHA.

Proposal Would Delay Quality Reporting for Long-term Care, Inpatient Rehab Facilities

The Centers for Medicare & Medicaid Services (CMS) recently included proposals related to the quality reporting programs for long-term care hospitals (LTCHs) and inpatient rehabilitation facilities (IRFs) in its proposed rule to update the Medicare fee-for-service prospective payment system for home health agencies (see related article). LTCHs and IRFs were initially scheduled to begin reporting two new quality measures Oct. 1, 2020, including Transfer of Health Information to the Provider and Transfer of Health Information to the Patient, as well as several standardized patient assessment data elements (SPADES).

Due to the COVID-19 public health emergency (PHE), the CMS declined to release updated versions of the patient assessment tools necessary for reporting this information and delayed the compliance date for reporting these items until Oct. 1 of the year that is at least one full fiscal year after the end of the COVID-19 PHE. The CMS proposes to require reporting of these measures and SPADES beginning Oct. 1, 2022, since COVID-19 cases and deaths have declined. The MHA encourages LTCHs and IRFs to submit comments to the CMS regarding this provision by Aug. 27. Members with questions should contact Vickie Kunz at the MHA.

Association Submits Comments on Medicare Post-acute Care Proposed Rules

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.

Comments Being Accepted on Inpatient Rehabilitation Facilities Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) released a proposed rule to update the Medicare fee-for-service prospective payment system for inpatient rehabilitation facilities (IRFs) for fiscal year (FY) 2022, which begins Oct. 1, 2021.

Key provisions of the proposal would:

  • Increase the standard federal rate by 2.5% from $16,856 to $17,273 for facilities that comply with the IRF quality reporting program (QRP). Facilities that fail to comply are subject to a 2 percentage point reduction.
  • Increase the cost outlier threshold by 16% from $7,906 to $9,192, resulting in fewer cases qualifying for an outlier payment.
  • Modify the IRF QRP by:
    • Proposing the addition of the COVID-19 Vaccination Coverage among Healthcare Personnel (HCP) measure, requiring IRFs to report HCP vaccinations in their facilities.
    • Updating the denominator for the Transfer of Health Information to the Patient-Post Acute Care quality measure to exclude patients discharged home under the care of a home health or hospice provider.
    • Updating the number of quarters of data used for public reporting to account for the COVID-19 public health emergency reporting exception granted for Jan. 1 – June 30, 2020.

As it works to make healthcare quality more transparent to consumers and providers, the CMS is seeking input on ways to attain health equity for all patients through policy solutions, as demonstrated by the adoption of standardized patient assessment data elements (SPADEs). These data elements include several social determinants of health that were finalized in the FY 2020 final rule for the IRF QRP. Through a Request for Information within the proposal, the CMS is seeking comment on expanding measure development and the collection of other SPADEs that address health equity gaps. The agency also seeks feedback on its plans to define digital quality measures for the IRF QRP and the potential use of fast healthcare interoperability resources within the IRF QRP, aligning with other quality programs where possible.

The CMS will accept comments on the proposed rule until June 7. The MHA will provide IRFs with an estimated impact analysis and summary of the proposed rule within the next month. Members with questions should contact Vickie Kunz at the MHA.