MHA Monday Report June 14, 2021

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Combating the Novel Coronavirus (COVID-19): Weeks of June 7

The Michigan First-Dose Tracker indicates that, as of June 10, 60% of Michiganders ages 16 and over had received a COVID-19 vaccine. By June 12, more than 892,000 cases of COVID-19 had been confirmed in the state since the pandemic began; but more than 852,000 …


MHA Provides Testimony in Senate on Newly Introduced Legislation

The Michigan Legislature addressed several bills impacting hospitals during the week of June 7, including legislation that would create new statewide systems of care for two time-sensitive emergency medical conditions, modernize scope of practice for …


Association Submits Comments on Medicare Post-acute Care Proposed Rules

The MHA recently submitted comments to the Centers for Medicare & Medicaid Services regarding the proposed rules to update the Medicare fee-for-service prospective payment systems for fiscal year 2022 for several post-acute care …


Community Benefit Reporting and the COVID-19 Pandemic Discussed in Webinar

The COVID-19 pandemic has had significant impacts on communities, patients and the hospitals that serve them and has severely affected hospital finances. Questions have arisen regarding how pandemic-related expenses, revenues and …


MHA and MHA Keystone Center Events Focus on Diversity, Equity and Inclusion

To act deliberately and purposefully to ensure outcomes across all patient populations are equitable, leaders should know where disparities exist, ways to prevent disparities and how to create a culture and system that reduces disparities to improve quality and …


Chief Medical Officer Debunks COVID-19 Vaccine Myths on MiCare Champion Cast

The MHA released a new episode of the MiCare Champion Cast, which features interviews with healthcare policy experts in Michigan on key issues that impact healthcare and the health of communities. …


High Reliability Leads to Safe Work Environment

Creating a highly reliable hospital requires a commitment to a just culture, continuous learning and designing care improvement. The webinar High Reliability in the Time of COVID-19, scheduled from noon to 1 p.m. EDT June 24, will review high reliability principles proven …


CyberForce|Q Offers Continuous, Collective Approach to Cybersecurity Assessments

The MHA’s newest Endorsed Business Partner, CyberForce|Q, offers a new approach to cybersecurity for healthcare organizations. CEO Eric Eder described a situation where a rural healthcare system’s CEO shared his organization’s experience …


Headline Roundup: Week of June 6 for COVID-19 in Michigan

The MHA has compiled a collection of media stories that include references to the MHA related to the last COVID-19 surge and vaccines. …

The Keckley Report

Post Pandemic, Affordability Looms as the Big Challenge in Healthcare — This Time, It’s Different

“Pre-pandemic, polls showed healthcare costs were a major concern to U.S. consumers. Post-pandemic, indications are it will re-surface as the industry’s biggest challenge, particularly affordability. But this time, consumers are likely to act differently on their concerns.”

Paul Keckley, June 8, 2021


MHA in the News

Modern Healthcare published an interview with MHA CEO Brian Peters June 7 discussing the new administrative rules requiring implicit bias training for licensure or registration of healthcare professionals in Michigan.

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.

Proposed Rule Released for Inpatient Psychiatric Facilities

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

The IPF proposed rule would:

  • Provide a net 2.2 % increase to the federal per diem base rate, increasing it from $815.22 to $833.50, while also increasing the payment for electroconvulsive therapy treatment from $350.97 to $358.84. IPFs that fail to comply with CMS quality reporting program requirements are subject to a 2 percentage point reduction to the federal rates.
  • Result in a slight decrease to the labor-related share from 77.3% to 77.1%.
  • Decrease the cost outlier threshold by 4% from the current $14,630 to $14,030, which should result in slightly more cases qualifying for an outlier payment.
  • Update the IPF PPS teaching policy for IPF hospital closures and displaced residents, making it consistent with changes included in the FY 2021 inpatient PPS final rule.
  • Modify the IPF quality reporting program by:
    • Adopting voluntary patient-level data reporting for data submitted for payment determination for FY 2023 and mandatory patient-level data reporting for payment determination for FY 2024 and future years.
    • Adopting the COVID-19 Healthcare Personnel Vaccination measure for the FY 2023 payment determination and subsequent years.
    • Adopting the Follow-up After Psychiatric Hospitalization (FAPH) measure for the FY 2024 payment determination and subsequent years.
    • Removing four measures starting with FY 2024 payment determinations:
      • Alcohol Use Brief Intervention Provided or Offered and Alcohol Use Brief Intervention Provided (SUB-2/2a).
      • Tobacco Use Brief Intervention Provided or Offered and Tobacco Use Brief Intervention Provided (TOB-2/2a).
      • Timely Transmission of Transition Record (Discharges from an Inpatient Facility to Home/Self Care or Any Other Site of Care).
      • Follow-up After Hospitalization for Mental Illness (FUH).

Within the proposed rule is a Request for Information (RFI) seeking input on closing the health equity gap in the CMS quality programs. The agency seeks to base reporting of health disparities on social risk factors and race and ethnicity so it is more comprehensive and actionable for facilities, providers and patients. The CMS will use the feedback to inform a future, comprehensive RFI focused on closing the health equity gap in the CMS programs and policies.

The CMS will accept comments on the proposed rule until June 7. The MHA will provide IPFs 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.