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.

MHA Monday Report June 14, 2021

MHA Monday Report logo

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

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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

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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.

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.

CMS Releases Final Rules for Medicare Post-acute Care Services in FY 2021

The Centers for Medicare & Medicaid Services (CMS) made minor changes in the recently released final rules to update the Medicare fee-for-service inpatient psychiatric facility (IPF), inpatient rehabilitation facility (IRF) and skilled nursing facility (SNF) prospective payment systems for fiscal year (FY) 2021. The CMS made minimal changes in the rules for 2021, recognizing that resources are dedicated to the current health pandemic. Each of the rules takes effect Oct. 1.

Key provisions of the IPF final rule include:

  • A net 2.1% rate increase in the federal per diem base rate, increasing it from $798.55 to $815.22. The electroconvulsive therapy payment per treatment will also increase by 2.1% from $343.79 to $350.97.
  • A slight increase in the labor-related share from 76.9% to 77.3% based on the revised marketbasket.
  • A 5% cap on any wage index decreases, which ensures that each facility’s wage index is at least 95% of its current wage index.
  • Removal of “independent” from “licensed independent practitioner(s),” which will allow advanced practice providers such as physician assistants, nurse practitioners, psychologists and clinical nurse specialists the authority to practice at the top of their licenses, including the authority to record progress notes for patients.
  • Retention of the existing facility and patient-level adjustments for qualifying emergency departments, teaching programs, rural locations and use of the Medicare-Severity Diagnosis-related Group adjustment factor, with additional adjustments for patient comorbidities, age and length of stay.

In the IRF final rule, the CMS finalized a net rate increase of 2.2%, increasing the federal base rate from $16,489 to $16,856.  As proposed, the CMS finalized the permanent removal of the post-admission physician evaluation requirement that was temporarily eliminated due to the public health emergency; the removal of this requirement will reduce the unnecessary burden on IRF providers and physicians beginning in FY 2021.

The CMS also finalized a change in the IRF final rule allowing a nonphysician practitioner to perform one of the three required visits in lieu of the physician beginning the second week of patient care, when consistent with the practitioner’s scope of practice. The CMS made no changes to the IRF quality reporting program.

In the SNF final rule, the CMS finalized a net rate increase of 2.1% compared to FY 2020. The CMS made no changes to the redesigned SNF payment model known as the Patient Driven Payment Model (PDPM) implemented in FY 2020; instead, it is maintaining the current model weights and budget-neutrality adjustment. The CMS will continue to monitor provider behavior under the PDPM, including the impact of COVID-19, as well as patient outcomes and aggregate SNF prospective payment system payments. The agency also notes that it may consider future PDPM-related behavioral offsets. The final rule includes only nominal updates to the SNF value-based purchasing program.

In the next few weeks, the MHA will provide facilities with updated impact analyses of each of the final rules. Members with questions should contact Vickie Kunz at the MHA.