Final Medicaid Bulletin on Continuous Glucose Monitoring Systems

The Michigan Department of Health and Human Services issued a final Medicaid Policy Bulletin May 1 with revisions to the Continuous Glucose Monitoring Systems (CGMS) Policy.

In response to the proposed policy issued April 1, the MHA submitted a comment letter, offering seven recommended changes. Three of the seven changes the MHA suggested were adopted in the final policy:

  • Removal of a daily blood glucose testing requirement.
  • Removal of provider documentation requirements for the daily number of finger-stick tests prescribed.
  • Changing the requirement for diabetes self-management education from annual to bi-annual. This requirement became optional.

The additional suggestions not adopted include:

  • Removal of the provider documentation requirement for daily frequency of insulin administered.
  • Removal of the provider documentation requirement for beneficiary treatment plan and compliance.
  • Update the 90-day provider documentation requirement to align with the bi-annual monitoring requirement for CGMS.
  • Add Type II diabetes as a condition where prior authorization is not required.

This policy will go into effect June 1, 2023.

Members with questions may contact Kelsey Ostergren at the MHA.

New State Psychiatric Hospital to Replace Hawthorn Center

The Michigan Department of Health and Human Services and the Department of Technology, Management & Budget announced the state will construct a new $325 million psychiatric hospital located at the current site of Hawthorn Center in Northville.

The new facility will provide care for patients currently housed at both Hawthorn Center and Walter P. Reuther Psychiatric Hospital in Westland. These two facilities, which are among the state’s five inpatient psychiatric hospitals for individuals who have severe mental illness or intellectual and developmental disabilities, have aging infrastructure driving the new construction.

Staff and patients currently receiving care at Hawthorn Center will be moved to a separate unit at Walter Reuther to allow for the demolition of the current Hawthorn facility until the project’s anticipated completion in 2026.

The new facility will serve all ages with distinct facilities that separates living and programmatic spaces for children and adults while including spaces for administration and food service.

Members with questions may contact Lauren LaPine at the MHA.

FAQs Released for Michigan Physician Order for Scope of Treatment

The Michigan Physician Order for Scope of Treatment (MI-POST) is an optional advance care planning form for adult patients with advanced illness or frailty for whom, based on their current medical condition, death would occur within one year. The MI-POST form includes choices about cardiopulmonary resuscitation, critical care and other wanted care that is intended to guide care only if the person cannot tell others what to do at that time. The Michigan Department of Health and Human Services (MDHHS) recently released a frequently asked questions document and additional questions can be sent to the MDHHS MI-POST staff.

All other questions can be sent to Renée Smiddy at the MHA.

MDHHS Releases Proposed Policy on REH Reimbursement

The Michigan Department of Health and Human Services (MDHHS) recently released a proposed policy to establish Medicaid reimbursement methodology for hospitals that convert to the new rural emergency hospital (REH) provider type. Critical access hospitals and rural hospitals with 50 or fewer beds are eligible to apply for the Medicare REH designation effective Jan. 1, 2023.

Hospitals that convert to the REH designation are required to update their enrollment and subspeciality with the MDHHS and must end date their inpatient services. Providers must notify the MDHHS via the Community Health Automated Medicaid Processing System within 35 days of any change to their enrollment information.

The MDHHS will reimburse REHs using existing Outpatient Prospective Payment System (OPPS) methodology. Critical access hospitals that convert to the REH designation will continue being paid based on the higher OPPS payment factor while others will be paid based on their current payment factor. The MDHHS updates the outpatient payment factors annually effective Jan. 1 to maintain budget neutrality following the Medicare update.

Hospitals are encouraged to review existing supplemental payment program policy to evaluate the potential impact. While the proposed policy does not provide specifics, the MHA anticipates that REHs will continue to receive outpatient Medicaid Access to Care Initiative and Hospital Rate Adjustment payments. The MHA will ask the MDHHS to clarify how the REH conversion will impact supplemental payment programs in the final policy. Hospitals are encouraged to review the proposed policy and submit comments to the MDHHS by May 10.

Members that are evaluating REH conversion are encouraged to contact Lauren LaPine at the MHA and  members with questions regarding the proposed reimbursement policy should contact Vickie Kunz at the MHA.

Public Health Emergency Michigan Provider Licensing Guidance

The U.S. Department of Health and Human Services is set to end the federal Public Health Emergency May 11. At that time, the special privileges and exemptions Michigan extended to licensed healthcare facilities and providers during the pandemic will be discontinued. Beginning May 12, all healthcare providers and health facilities operating in Michigan must have the appropriate license(s) and permit(s) required under Michigan and federal law.

Impacted by this notice are emergency certificate of need approvals granted to hospitals and health systems for additional licensed beds.

The Michigan Department of Licensing and Regulatory Affairs (LARA) expressed to the MHA a willingness to work with healthcare providers to minimize any interruptions in the delivery of care by healthcare providers and within their facilities.

LARA’s Bureau of Community and Health Systems (BCHS) issues state licenses for various health facilities, agencies and programs. The BCHS webpage contains information on how to apply for a State of Michigan health facility license or permit. Members with questions about health facility license may contact the BCHS.

LARA’s Bureau of Professional Licensing (BPL) issues state licenses for health professionals. The BPL webpage contains information on how to apply for a State of Michigan health professional license. Members with questions about health professional licensure may contact the BPL.

Members with further questions about licensure and the ending of the PHE may contact Laura Appel at the MHA.

MHA CEO Report — A Healthy Michigan is an Insured Michigan

MHA Rounds Report - Brian Peters, MHA CEO

“Life is what happens while you are busy making other plans.” — John Lennon

MHA Rounds Report - Brian Peters, MHA CEOThe United States celebrated last month the 13th anniversary of the signing of the Affordable Care Act (ACA). Simply put, when then-President Obama signed the legislation March 23, 2010, it was one of the most monumental healthcare policy changes in our lifetime. Since its passage, it has provided millions of Americans with health insurance, provided access to care for millions of residents with preexisting conditions and incentivized the launch of innovative models of care that have improved patients’ lives and saved billions of healthcare dollars.

The MHA was pleased to celebrate the anniversary by having MHA Executive Vice President Laura Appel join U.S. Rep. Elissa Slotkin and others in a virtual press conference discussing the positive impact the ACA has had on Michiganders.

The mission of the MHA is to “advance the health of individuals and communities.”  We have long supported the ACA, as the availability of robust health insurance coverage is crucial to achieving this mission. The benefits of the ACA can be measured by the more than one million Michiganders now covered by our Medicaid expansion program – the Healthy Michigan Plan – and more than 320,000 Michiganders who now receive coverage through the Health Insurance Marketplace created simultaneously by the act. Combined, these new developments have helped to significantly reduce the number of uninsured individuals in Michigan, which consistently numbered well over one million people in the years prior to the ACA’s passage.

The history of health insurance coverage in America is interesting and complex, and there were two major turning points in the 20th century that preceded the ACA. First, to combat inflation amid World War II, Congress passed the 1942 Stabilization Act. Designed to limit the ability to raise wages, the act led employers to instead offer health benefits for the very first time. Because health benefits did not count as income, they were not taxable to the employees. With a flip of the proverbial switch, employers were in the health insurance business and have never looked back. Second, in 1965 then-President Lyndon B. Johnson signed into law the enabling legislation to create the Medicare and Medicaid programs, which have provided coverage to important populations including seniors, those with disabilities, low-income and more.

Today the majority of Michiganders – over six million – are covered by employer-sponsored private insurance. But both Medicare and Medicaid have grown, accounting for approximately two million enrollees in each program respectively.  This growth is driven by different factors: for Medicare, we obviously have an aging population, increasingly fueled by the baby-boom generation. And for Medicaid, we have seen both organic growth in the traditional program, as well as significant growth in the Medicaid expansion program.

Whether public or private, we celebrate health insurance coverage because it directly benefits people, as they are more likely to see a primary care practitioner, seek recommended tests and screenings, receive appropriate prenatal care and generally access a wide array of healthcare services in such a way that their issues can be identified and resolved as early as possible. Not only does this mean better outcomes, but it also saves healthcare costs in the long run. And of course, having insurance coverage provides financial peace of mind for families when an unanticipated serious illness or catastrophic injury occurs.

The truth is that better insurance coverage is a positive for hospitals as well, as it helps to reduce the amount of uncompensated care that we must absorb. However, simply having an insurance card is no guarantee that an individual will have the appropriate level of coverage, as the rise in high-deductible and “skinny” insurance plans still result in significant and growing out-of-pocket expenses for consumers. These plans in turn have created more bad debt and uncompensated care for hospitals because consumers often purchase these plans based strictly on price without full knowledge of their co-pays, deductibles, which providers are considered in-network and what care may not be covered at all. On this note, the subject of surprise medical bills has been in the spotlight in recent years, culminating with the implementation of the federal No Surprises Act in January 2022. There is no doubt hospitals own our share of this issue – and we are committed to doing all we can to improve. But as a wise health policy observer commented to me at the time, the situation for far too many Americans can be summarized as “surprise, your health insurance stinks.” The total unpaid costs of patient care for Michigan hospitals in 2020 exceeded $3.4 billion, and the anecdotal evidence points to this challenge continuing ever since.

Back to the public policy front, one key issue on our radar screen now is the pending expiration of the COVID-19 public health emergency (PHE). Michigan has an additional 355,000 residents enrolled in traditional Medicaid and 367,000 additional Healthy Michigan Plan enrollees since the PHE began, and many of them will be at risk of losing coverage when the PHE ends and the Medicaid “redetermination” process begins.

In many Michigan counties, more than 30% of the population uses Medicaid for its healthcare benefit. The goal of the MHA and our partner stakeholder groups is to work with the Michigan Department of Health and Human Services (MDHHS) to ensure as many people as possible either maintain their Medicaid coverage or transition to an appropriate plan on the insurance exchange if they do not now have employer-sponsored coverage. This will continue to ensure that community members avoid interruptions in their care and will allow us to maintain many of the health outcome gains achieved over the past 13 years.

The MDHHS has created tools and resources for providers and partners aimed at educating their patients about the need to ensure their contact information is updated so they properly process their redetermination paperwork. The MHA has worked closely with our member hospitals and health systems to share these resources. This may be the first time for many beneficiaries that they must renew their coverage, and some may not even be aware they’re on Medicaid. Hospitals are the main touchpoint for many beneficiaries and hence play a very significant role in helping to facilitate this process for vulnerable patients.

The ACA, like any other major public policy change, has been far from perfect. But reflecting on the success in providing coverage to more Michiganders, we must express our gratitude for those at both the federal and state levels for the gains we’ve made over the past 13 years. In Michigan, we’ve received bipartisan support over the years for expanded coverage. Despite all the challenges hospitals and health systems have experienced in recent years, the gains made from the ACA have been a big reason why Michigan hospitals can continue to serve their communities throughout all areas of the state.

And on the broader issue of health insurance coverage, we would be remiss if we did not acknowledge that insurance is only one element that contributes to – but does not on its own ensure – access to care. Our efforts in the health equity domain have shown clearly that language and cultural barriers, transportation, housing, food insecurity and many other factors contribute to the ability of many Michiganders to get the care they need. But at the end of the day, having insurance is a critically important first step. No one plans to get sick or injured – but when “life” happens, that coverage is nothing short of a blessing.

As always, I welcome your thoughts.

Student Debt Relief Offered to Behavioral Health Providers

The MI Kids Now Loan Repayment Program will offer educational loan repayment for eligible behavioral health medical providers in Michigan. The program is available to behavioral health providers, including psychiatrists, psychologists, social workers, counselors, therapists, case managers and certified behavioral analysts.

In an effort to recruit and retain behavioral health workers in Michigan, the program will assist those selected with up to $300,000 to repay educational debt over a period of up to 10 years. Providing debt relief to those who serve children is the main priority for the loan repayment program, however, the program is open to providers of services to both children and adults.

Those eligible must provide in-person, outpatient behavioral health services through eligible non-profit practice sites, including public school-based systems and community mental health organizations. Eligible providers will be selected to enter into consecutive two-year agreements.

The MI Kids Now Loan Repayment Program application cycle is June 12 – June 23. Behavioral health providers are encouraged to review the materials in advance and submit applications when the cycle begins.

Detailed information regarding eligibility, selection criteria and application instructions can be found on the Michigan Department of Health and Human Services (MDHHS) website. Providers who have questions or need more information can email Reanna Kathawa with MDHHS.

Members with further questions may contact Lauren LaPine at the MHA.

Medicaid Eligibility Redetermination Webinar Recording Available

The Michigan Medicaid program has grown to nearly 3.2 million Michiganders, an increase of more than 700,000 when compared to pre-pandemic levels, due to federal statutory limitations on states’ abilities to remove people from the program during the public health emergency. The Michigan Department of Health and Human Services (MDHHS) recently released a final policy bulletin informing providers that Medicaid eligibility redeterminations will resume in June 2023 for the first time since early 2020, with some enrollees who no longer meet program eligibility criteria losing coverage as early as July.

The MHA, in partnership with the Michigan Primary Care Association, Michigan Association of Health Plans, Michigan State Medical Society and Michigan Osteopathic Association, hosted a member webinar March 20 to cover the Medicaid eligibility redetermination process, timelines and provider roles. A recording of this webinar is available.

Hospitals are encouraged to discuss the importance of updating Medicaid patient contact information in the state’s MI Bridges system and how to maintain Medicaid coverage or find new coverage on the federal marketplace.

Members with questions are encouraged to contact Jason Jorkasky at the MHA.

March 30 Webinar Outlines Considerations for the End of the Public Health Emergency

The Department of Health and Human Services (DHHS) COVID-19 public health emergency expires May 11, 2023, which may significantly decrease the flexibility providers have become accustomed to.

The MHA will host The End of the COVID-19 Public Health Emergency (PHE) and Preparing for the New Regulatory Environment webinar from 4 to 5 p.m. March 30, 2023, providing practical guidance on unwinding reliance on the COVID-19 public health emergency flexibilities. The webinar will identify the steps hospitals should take to prepare for the end of the federal and state public health emergency, review the status of waivers and extensions of PHE-oriented flexibilities and outline how the Michigan Department of Health & Human Services will work with providers in determining which COVID-19 response policies will end, be modified or remain permanently. Experts from Jones Day and the MHA staff will present and answer questions.

Chief executives, financial, medical and nursing executives, legal counsel, patient account and revenue cycle directors, government relations officers, public relations directors and human resources directors are encouraged to register. The webinar is free of charge and open to MHA member organizations only.

Members with questions should contact Brenda Carr at the MHA.

Changes to Telemedicine Policy Post-COVID-19 Public Health Emergency

The Michigan Department of Health and Human Services (MDHHS) will rescind certain COVID-19 telemedicine flexibilities beginning May 12, 2023, with the conclusion of the federal health public health emergency. Policy MMP 23-10 outlines flexibilities that will remain permanent and which flexibilities will be rescinded. Notable permanent flexibilities include:

  • Reimbursement: The telemedicine reimbursement rate for allowable services will be the same as the in-person reimbursement rate. Providers must report the place of service as they would if they were providing the service in-person.
  • Audio-Only: Audio-only services will be allowed for the procedure codes CPT/HCPCS 99441-99443 and 98955-98968. The MDHHS will create an audio-only database for providers to reference.
  • Prior Authorizations: There are no prior authorization (PA) requirements when providing telemedicine services for fee-for-service beneficiaries or those accessing behavioral health services through prepaid inpatient health plans/community mental health services programs unless the equivalent in-person service requires a PA. The PA requirements for Medicaid health plans (MHP) may vary and providers should refer to individual MHPs for any PA requirements.
  • MSA 20-09 General Telemedicine Policy Changes will be permanent and remain effective with the Facility Rate subsection redacted.
  • MSA 21-24 Asynchronous Telemedicine Services will be permanent and remain effect.

Rescinded telemedicine policies include:

  • MSA 20-13 COVID-19 Response: Telemedicine Policy Expansion.
  • MSA 20-15 COVID-19 Response: Behavioral Health Telepractice; Telephone (Audio Only) Services.
  • MSA 20-34 COVID-19 Response: Telemedicine Reimbursement for Federally Qualified Health Centers.
  • MSA 20-21 COVID-19 Response: Limited Oral Evaluation via Telemedicine.

Members with questions may contact Renée Smiddy at the MHA.