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

News to Know – Week of June 27

  • The MHA will host an educational webinar at 10 a.m. June 29 to assist hospitals in reviewing and reporting their fiscal year (FY) 2024 preliminary data recently released by the Centers for Medicare & Medicaid Services. This data is being used to develop the FY 2024 Medicare wage index, effective Oct. 1, 2023, which impacts Medicare payments in all prospective payment systems. Hospitals are encouraged to review their data and submit requests for any changes to their Medicare Administrative Contractor by Sept. 2. Login information for the Zoom event will be provided upon registration, which is required. Members should contact Crystal Mitchell at the MHA regarding registration, while other questions should be directed to Vickie Kunz at the MHA.
  • The MHA has submitted comments to the Centers for Medicare & Medicaid Services regarding the proposed rule to update the fiscal year 2023 Medicare fee-for-service inpatient prospective payment system. The association will provide additional information and an updated hospital-specific impact analysis following release of the final rule, which is expected to occur around Aug. 1 for the Oct. 1 effective date. Members with questions should contact Vickie Kunz at the MHA.
  • The MHA has launched a new Federal Legislation and Litigation Tracker. The new resource gives users a comprehensive look at healthcare legislation introduced in the U.S. House of Representatives and the U.S. Senate. The tracker provides district-specific data, allowing users to easily follow the work of lawmakers representing their area. For more information, contact Renée Smiddy at the MHA.

MHA Monday Report June 20, 2022

MHA Monday Report

capitol buildingBehavioral Health Supplemental Budget, Policy Bills Advance


Ask Congress to Support SAVE Act to Protect Healthcare Workers

The Safety from Violence for Healthcare Employees (SAVE) Act is newly proposed federal legislation to give healthcare workers the same legal protections against assault and intimidation that flight crews and airport workers have under federal law. U.S. Reps. Madeleine Dean (D-PA) and Larry Bucshon, MD …


MHA CEO Brian Peters; Beth Bedra, RN, patient safety officer, ProMedica Monroe Regional Hospital, and Sarah Scranton, MPA, vice president, safety and quality, MHA and MHA Keystone executive director.

ProMedica Monroe Regional Hospital Receives Q1 MHA Keystone Center Speak-up! Award

The Michigan Health & Hospital Association (MHA) Keystone Center honored Beth Bedra, patient safety officer at ProMedica Monroe Regional Hospital, June 9 with the quarterly MHA Keystone Center Speak-up! Award. …


Paul KeckleyThe Keckley Report

May 2022 CPI Report: Healthcare Prices Up, Especially Insurers

“Comparatively, healthcare has seen relatively constrained price increases while the rest of the economy’s price hikes have soared: In the last 12 months, the energy index rose 34.6%–the largest 12-month increase 2005, the food index increased 10.1%–the first increase of 10% or more since 1981, vs. 4.0% for medical care–notably the lowest 12 month increase of any category in the CPI.”

Paul Keckley, June 13, 2022


News to Know

The MHA has submitted comments regarding the proposed rule to update the fiscal year 2023 Medicare fee-for-service inpatient prospective payment system.

MHA Monday Report June 13, 2022

MHA Monday Report

capitol buildingHouse and Senate Continue Health Policy Testimony


MHA Draft Comments on IPPS Proposed Rule Available for Member Review

The MHA has drafted comments regarding the fiscal year 2023 Medicare proposed rule to update the Medicare fee-for-service inpatient prospective payment system (IPPS). Hospitals are encouraged to review the impact of the proposed rule on …


The Keckley Report

Medicare Trustees Report is Misleading, Especially for Hospitals

“Last Thursday, the Medicare Trustees released their latest assessment of the long-term adequacy of the Trust Funds that reimburse [healthcare providers on] behalf of Medicare’s 64 million seniors andPaul Keckley disabled adults. …

“This report is the Trustees’ 57th. Its projections are developed in two time-frames … A careful read provides a cautionary view about future Medicare funding adequacy.”

Paul Keckley, June 6, 2022


News to Know

The MHA is developing an advocacy day specially designed for small or rural hospital members. Rural Advocacy Day will be held Sept. 21 at the MHA Capitol Advocacy Center in downtown Lansing.

MHA in the News

MHA CEO Brian Peters expressed the MHA’s support for the Michigan Department of Licensing and Regulatory Affair’s new implicit bias training requirement for all professions licensed or registered under the Public Health Code in a story by Michigan Capitol Confidential.

MHA Draft Comments on IPPS Proposed Rule Available for Member Review

The MHA has drafted comments regarding the fiscal year 2023 Medicare proposed rule to update the Medicare fee-for-service inpatient prospective payment system (IPPS). Hospitals are encouraged to review the impact of the proposed rule on their operations and submit comments to the Centers for Medicare & Medicaid Services by close of business June 17 by searching the state’s website for file code “1771-P.”

The MHA will provide updated information following release of the IPPS final rule, which is expected to occur around Aug. 1 for the Oct. 1, 2022, effective date.  Members with questions should contact Vickie Kunz at the MHA.

MHA Monday Report April 25, 2022

MHA Monday Report

capitol building

Senate Moves Appropriations Subcommittee Budgets and Advances Opioid Settlement Legislation

The Michigan Senate Appropriations Subcommittee on Health and Human Services reported out April 20 their budget recommendation for the fiscal year 2023 budget beginning Oct. 1. Senate Bill 828 protects hospital priorities including maintaining funding for the Healthy Michigan Plan …


DIFS Utilization Review Decisions Favor Hospitals

The Michigan Department of Insurance and Financial Services (DIFS) issued in early April two important utilization review decisions in favor of hospitals related to auto no-fault insurance reimbursement. Under the new system enacted as part of Public Act 21 of 2019, hospitals …


LARA Rules Requiring Implicit Bias Training Take Effect June 1

The Department of Licensing and Regulatory Affairs (LARA) revised Public Health Code Rules requiring implicit bias training for all professions licensed or registered under the Public Health Code, except for Veterinary Medicine, effective June 1. …


CMS Releases FY 2023 Proposed Rule to Update Hospital IPPS

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service hospital inpatient prospective payment system for fiscal year 2023. When all proposed changes are considered, the rule is expected to result in a net decrease …


Cybersecurity Member Forum Scheduled for June 2

The MHA will host a cybersecurity member forum from 9 a.m. to 3 p.m. June 2 at the Henry Center for Executive Development. Increasing cybersecurity threats support the need for leaders to identify vulnerabilities of medical devices and supply chains, to select staff who can lead threat mitigation …


Long-term Acute-care Hospital Payment System Proposed Rule Released

The Centers for Medicare & Medicaid Services recently released a proposed rule to update the Medicare fee-for-service long-term care hospital prospective payment system for fiscal year 2023. …


Webinar Focused on Long-Term Goal Planning and Accountability

Successful stewardship of an organization is central to the role of governance. In many boardrooms, an inward, short-term operational focus robs governing boards of their attention to external forces and long-term strategic imperatives. It takes discipline and a symbiotic relationship between the board …


Nurse Preceptor and Clinical Faculty Academy Available Online

New nurses can be overwhelmed with responsibilities, which is why nurse preceptors make a difference. Nurse preceptors help new nurses develop their professional identity, access appropriate clinical research and learn from mistakes. …


The Keckley Report

Paul Keckley

Why Not-for-profit Hospitals Are Soft Targets

“Last week, the Lown Institute issued its latest report card on not-for-profit hospitals finding most undeserving of their tax breaks. …

“In response, the American Hospital Association (AHA) released a statement criticizing the Lown Institute’s ‘faulty methodology’ and defending hospitals’ use of financial resources.”

Paul Keckley, April 18, 2022

CMS Releases FY 2023 Proposed Rule to Update Hospital IPPS

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service (FFS) hospital inpatient prospective payment system (IPPS) for fiscal year (FY) 2023. When all proposed changes are considered, the rule is expected to result in a net decrease due to proposed cuts to disproportionate share hospital (DSH) and other payments. The MHA considers these cuts to be unacceptable given the extraordinary inflationary environment and extreme labor and supply cost pressures that hospitals continue to experience.  The proposed rule would:

  • Reduce national DSH and uncompensated care (UCC) pool payments by $800 million. The CMS projects a UCC pool of roughly $6.5 billion to be allocated to hospitals based on audited Worksheet S-10 data from FY 2018 and FY 2019 cost reports. The CMS proposes to use a three-year average to calculate payments starting in FY 2024.
  • Eliminate payment enhancements for Medicare-dependent hospitals and low-volume hospitals absent congressional action to extend those payments beyond the Sept. 30, 2022, expiration date.
  • Provide a net 3.2% increase in the federal operating rate for hospitals that successfully participate in the inpatient quality reporting program (QRP) and are meaningful electronic health record users.
  • Increase the standard federal capital rate by 1.6% from $472.60 to $480.29.
  • Establish a cost outlier threshold of $43,214, up 39% from the current $30,988 threshold, resulting in fewer cases qualifying for an outlier payment. The CMS adjusts the threshold annually to ensure that outlier payments do not exceed the established target of 5.1% of aggregate IPPS payments.
  • Cap wage index decreases at 5%, ensuring each hospital’s wage index is at least 95% of its final wage index for the prior fiscal year. This policy would be funded by a national adjustment to the standard federal operating rate. The CMS proposes to continue the current policy that provides a wage index increase for hospitals in the bottom quartile.
  • Modify graduate medical education policy related to full-time-equivalent caps and increase flexibility for rural hospitals that participate in a rural track program.
  • Suppress several measures in the hospital value-based purchasing program and continue the special scoring methodology used for FY 2022 to ensure hospitals are neither penalized nor rewarded due to the COVID-19 public health emergency.
  • Suppress all six measures in the hospital acquired conditions (HAC) reduction program. If finalized as proposed, hospitals will not be given a measure score, a total HAC score, or a payment penalty for FY 2023.
  • Establish a publicly reported hospital designation on the quality and safety of maternity care in efforts to reduce maternal mortality and morbidity, a priority of the Biden-Harris administration. The CMS would award this designation to hospitals that report “Yes” to both questions in the Maternal Morbidity Structural Measure, previously finalized in the Hospital Inpatient QRP.
  • Seek input on ways to advance health equity. The CMS is seeking comment on key considerations to improve data collection to better measure and analyze disparities across CMS programs and policies and approaches for updating the Hospital Readmission Reduction Program to encourage providers to improve performance for socially at-risk populations.
  • Seek input on the appropriateness of a payment adjustment for FY 2023 and beyond to recognize the additional resource costs associated with acquiring surgical N95 respirators that are approved by the National Institute for Occupational Safety and Health and are wholly domestically made.

The MHA is continuing to review the proposed rule and will provide hospitals with an estimated impact analysis soon. The association will also share its draft comments with members when available. The CMS will accept comments on the proposal through June 17. Members with questions should contact Vickie Kunz at the MHA.

Proposed Rule Released on Medicare Inpatient Prospective Payment System

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service hospital inpatient prospective payment system for fiscal year (FY) 2022. Provisions of the proposed rule would take effect Oct. 1, 2021, unless otherwise noted. Highlights of the proposed rule would:

  • Repeal the requirement that hospitals report the median payer-specific negotiated rate for inpatient services by Medicare severity diagnosis-related Group (MS-DRG) for Medicare Advantage plans on the Medicare cost report for periods ending on or after Jan. 1, 2021. The CMS proposes to repeal the market-based MS-DRG relative weight methodology the agency had planned to implement in FY 2024 and, instead, would continue using the existing cost-based methodology.
  • Provide hospitals with a neutral score for the FY 2022 value-based purchasing program due to suppressing many of the measures impacted by the public health emergency (PHE). The CMS proposes to score hospitals for the FY 2022 readmissions and hospital-acquired conditions reduction programs.
  • Extend new COVID-19 treatments add-on payment for certain eligible products through the end of the fiscal year in which the PHE ends while also extending technology add-on payments for 14 technologies that otherwise would be discontinued in FY 2022.
  • Provide a net 3% increase to the standard operating rate, after budget neutrality, for hospitals that comply with the CMS quality reporting program (QRP) requirements and a 1.2% increase in the federal capital rate.
  • Increase the cost outlier threshold by 6.5% from the current $29,064 to $30,967, resulting in fewer cases qualifying for an outlier payment.
  • Decrease the Medicare uncompensated care (UCC) pool by approximately $660 million, resulting in a UCC pool of roughly $7.6 billion that would be distributed using Worksheet S-10 data from FY 2018 cost reports.
  • Add 1,000 new medical resident slots that will be phased in at no more than 200 slots per year beginning in FY 2023, with additional funding at approximately $1.8 billion from FY 2023 to FY 2031. The CMS proposes to prioritize applications from hospitals that serve geographic areas and underserved populations with the greatest need.
  • Continue the electronic health record reporting period of a minimum of any continuous 90-day period for new and returning eligible hospitals and increase the reporting period to a minimum of any continuous 180-day period for calendar year 2024.
  • Seek input via a formal request for information on closing the health equity gap in CMS quality programs. Specifically, the CMS seeks input on ways to revise several related CMS programs to make reporting of health disparities based on social risk factors, race and ethnicity more comprehensive and actionable for hospitals, providers and patients.
  • Adopt several new measures in the hospital inpatient quality reporting program, including the COVID-19 Vaccination Coverage Among Health Care Personnel measure for the FY 2023 payment determination.
  • Remove several measures from the inpatient QRP.

The MHA will provide hospitals with an impact analysis within the next month and make its draft comments available prior to the June 28 due date. The association encourages hospitals to review the proposed rule and submit comments to the CMS, which is expected to release a final rule by the beginning of August for the Oct. 1 effective date. Members with questions should contact Vickie Kunz at the MHA.