MDHHS Releases Outpatient Hospital 340B Billing Final Policy

The Michigan Department of Health and Human Services (MDHHS) recently released a final policy to modify hospital outpatient billing requirements for drugs purchased through the 340B drug pricing program. Existing policy requires 340B hospitals to bill 340B drugs at acquisition cost. Effective for dates of service on or after Jan. 1, 2024, hospitals may bill up to usual and customary charges for 340B acquired physician-administered drugs or products when provided in the hospital outpatient setting. This policy also revises the hospital outpatient 340B acquisition cost reporting and discontinues the 340B final settlement adjustment process. The MDHHS expects this change will have no reimbursement impact.

In addition, the policy revises 340B hospital cost reporting requirements. Annually, starting by December 2024, hospitals will be required to report 340B cost data for all Medicaid outpatient fee-for-service claims paid during the prior fiscal year.

Questions regarding this process should forwarded to the MDHHS Drug Rebate Specialist.

Members with questions should contact Vickie Kunz at the MHA.

 

Psychiatric Residential Treatment Facility Final Policy in Effect

The Michigan Department of Health & Human Services (MDHHS) recent policy for Psychiatric Residential Treatment Facilities (PRTF) went into effect Dec. 1, 2023.

Initially released for comment in May 2023, the MHA provided feedback on the proposed rule to ensure that a final policy adequately captured clinical workflow, while balancing access, service availability, insurance coverage and evidence-based clinical care.

The proposed rule was adopted as written and outlines essential elements of a PRTF program, including:

  • Certification and Certificate of Need.
  • Provider certification criteria.
  • Patient eligibility requirements.
  • Service authorization.
  • Responsibilities of prepaid inpatient health plans, PRTF and referring providers.
  • Provider requirements, including reimbursement and staff education.
  • Coverage of out-of-state services.

Members with questions about the PRTF model may contact Lauren LaPine at the MHA.

MDHHS Launches Opioid Settlement Spending Webpage

The Michigan Department of Health and Human Services (MDHHS) recently published a webpage to track the allocation of $800 million received for opioid settlement investments. MDHHS Chief Medical Executive Dr. Natasha Baghdasarian indicated the website will allow for transparent sharing of how funds are utilized to combat the opioid crisis, highlighting Michigan’s progress in reducing overdose rates to below the national average.

The webpage categorizes spending into areas such as prevention, treatment, harm reduction, criminal justice, parenting, equity, data analysis and more. It also provides opportunities for various organizations to apply for funding as well.

Members with questions may contact Lauren LaPine at the MHA.

MHA Monday Report Oct. 30, 2023

MHA Monday Report

capitol buildingHealthcare Worker Protections Pass State Senate

Legislation increasing penalties for violence committed against healthcare workers was approved by the Michigan Senate in a bipartisan vote during the week of Oct. 23. The MHA-supported bills increase fines for assaulting a healthcare professional …


Strategic Action Planning Session with MHA Service Corporation Board

The MHA Service Corporation board focused on supporting MHA Strategic Action Plan priorities to address workforce support and innovation, viability, behavioral health improvement, health equity and more during their Oct. 18 planning session. The …


MDHHS Proposes 340B Billing and Reporting Changes

The Michigan Department of Health and Human Services (MDHHS) recently released a proposed policy to modify hospital outpatient billing requirements for drugs purchased through the 340B drug pricing program. Existing policy requires 340B hospitals to …


Clinician Q & A: Pregnancy and Infant Loss

Pregnancy and infant loss tragically impacts individuals and families at all walks of life across the state and country. While every case is different, this is often a result of miscarriage, ectopic pregnancy, stillbirth, neonatal …


Patient Safety: A Case-based Innovative Playbook for Safer Care Published

Patient Safety: A Case-based Innovative Playbook for Safer Care (Second Edition) is a recently published book that serves as a must-read resource for those seeking to enhance patient care and create a culture of safety …


MHA Strategic Action Plan to be Reviewed Nov. 9

In the new program year, the MHA is focused on several critical issues like viability, workforce resilience and wellbeing, behavioral health and health equity.   The MHA will host a virtual member from 2 to …


The Keckley Report

Paul KeckleyAre Employers Ready to Engage the Health Industry Head On?

“Last week, Kaiser Family Foundation (KFF) released its Annual Employer Health Benefits Survey which included a surprise:

The average annual single premium and the average annual family premium each increased by 7% over the last year. …

My take: these findings show that employers are not prone to drastic changes in health benefits for their employees despite recognition it is expensive and unaffordable to small companies and for many of their own employees.  But many large self-insured employers (except those in government, education and healthcare) are poised to make significant changes next year. They recognize themselves as the primary source of profits enjoyed by insurers, hospitals, physicians, drug companies and others.  They’re developing multi-year at risk direct contracts, value-based purchasing arrangements, primary care gatekeeping, narrow networks, restricted formularies, alternative care models and more to that leverage their clout. They’re going on offense. …”

Paul Keckley, Oct. 23, 2023


News to Know

  • The Centers for Medicare & Medicaid Services recently announced the 2024 Medicare Parts A & B amount for deductibles, coinsurance, premiums and the Part D income-related monthly adjustments.
  • The National Commission to Address Racism in Nursing is accepting requests for funding proposals for new or ongoing programs and interventions that work to eliminate racism in nursing.

MHA in the News

MDHHS Proposes 340B Billing and Reporting Changes

The Michigan Department of Health and Human Services (MDHHS) recently released a proposed policy to modify hospital outpatient billing requirements for drugs purchased through the 340B drug pricing program. Existing policy requires 340B hospitals to bill 340B drugs at acquisition cost. Effective for dates of service on or after Jan. 1, 2024, hospitals may bill up to usual and customary charges for 340B acquired physician-administered drugs or products when provided in the hospital outpatient setting. This policy proposes to revise the hospital outpatient 340B acquisition cost reporting and discontinues the 340B final settlement adjustment process. The MDHHS expects this change will have no reimbursement impact.

The policy also proposes to revise 340B hospital cost reporting requirements. Annually, starting by December 2024, hospitals will be required to report 340B cost data for all Medicaid outpatient fee-for-service claims paid during the prior fiscal year.

340B hospitals are encouraged to review the proposal and submit comments to the MDHHS by Nov. 28, 2023. Hospitals are also encouraged to contact Vickie Kunz regarding issues identified by Nov. 20.  Questions regarding this process should forwarded to the MDHHS Drug Rebate Specialist.

Members with questions should contact Vickie Kunz at the MHA.

MiCARE Project Discontinued

The Michigan Care Access Referral Exchange (MiCARE), hosted by Bamboo Health’s OpenBeds solution, will be discontinued effective Oct. 31, 2023.

The goal of MiCARE was to create a comprehensive network of behavioral health treatment providers, referrers and social support resources to connect individuals in need of care with the appropriate resources. The Michigan Department of Licensing and Regulatory Affairs (LARA) identified lack of engagement and cost as two contributing factors to this decision, following a recent assessment of the program.

By law, the Michigan Department of Health & Human Services (MDHHS) is required to have a psychiatric bed registry and will share more information about next steps in the coming weeks.

Members should refer to the announcement from LARA for more information.

Members with questions about the Psychiatric Bed Registry may contact Krista Hausermann at MDHHS. All other questions may be directed to Lauren LaPine at the MHA.

News to Know – Oct. 2, 2023

The Michigan Department of Health and Human Services will implement a wage increase beginning Oct. 1 for direct care workers in MI Choice Waiver, MI Health Link and Behavioral Health programs. This will provide an additional $0.85 per hour increase in direct care worker (DCW) base wages, supplementing the $2.35 per hour increase previously appropriated. The total increase of $3.20 per hour must be applied to DCW wages, including administrative time and overtime. Members may refer to L 23-64 for more information. Members with questions may contact Kelsey Ostergren at the MHA.

MDHHS Releases FY 2024 Medicaid Program Rate Updates

The Michigan Department of Health and Human Services (MDHHS) recently released concurrent proposed and final policies to implement Medicaid rate increases included in the fiscal year (FY) 2024 budget. These increases, contingent upon approval by the Centers for Medicare & Medicaid Services (CMS), are effective for dates of service on and after Oct. 1, 2023.

The MDHHS will modify Medicaid reimbursement rates for specified services to provide:

  • A hospital Diagnosis Related Group rate increase for level I and II designated trauma facilities. The increase will apply to Medicaid fee-for-service and Medicaid Health Plan hospital payments. The level of rate increase is not specified. The MHA successfully advocated for these funds in the FY 2024 budget.
  • A 260% increase for transitional residential brain injury services (BIS) with these services reimbursed through a single bundled payment per day that covers both a daily rate for traditional residential care and case management services and a minimum of 15 hours of weekly therapy. BIS outpatient rates remain unchanged.
  • A 7.5% increase for professional services provided by physicians, physician assistants, advanced practice nurses, psychologists, clinical social workers, professional counselors and others. This increase would not apply for professional services that received a previous rate increase such as neonatal, obstetrical and other services listed. The increase would apply to Maternal Infant Health Program professional services.
  • A 10% increase for Anesthesia Professional Services represented by CPT codes 00100-01999.
  • A 10% increase for home health services billed with HCPCS codes G0151-G0496.
  • An increase to 100% of Medicare base rates for ground ambulance services for Locality 01 when reimbursement from the Medicaid ambulance provider assurance assessment is included.

Hospitals are encouraged to review the proposed policy and submit comments to MDHHS by Oct. 31 and should include “Medicaid Program Rate Updates FY 2024” in the subject line.

Members with questions should contact Vickie Kunz at the MHA.

MDHHS Notifies Home Help Agency Providers in Recent Proposed Policy

The Michigan Department of Health and Human Services (MDHHS) recently released a proposed policy notifying Home Help Agency providers that the National Provider Identifier (NPI) field in the Community Health Automated Medicaid Processing System (CHAMPS) will open Dec. 18, 2023. Home Help agency providers can begin entering an NPI into CHAMPS on that date. The change will result in:

  • CHAMPS Modifications: A Home Help agency provider will only be able to save changes made in its CHAMPS enrollment if its NPI is entered in the NPI field as of Dec.18, 2023.
  • CHAMPS Revalidation: Home Help agency providers must revalidate their CHAMPS enrollment information at minimum once every five years. The MDHHS end-dates the enrollment and stops payment to any agency provider that does not revalidate. The MDHHS will notify agency providers when revalidation is due. Effective Dec. 18, 2023, Home Help agency providers must have an NPI in the NPI field of the CHAMPS enrollment to complete revalidation.
  • Electronic Visit Verification: Per Final Bulletin MMP-23-42 issued June 30, 2023, Home Help agency providers must obtain an NPI and add it to their CHAMPS enrollment in preparation for electronic visit verification (EVV). Home help payments may be impacted if an agency provider has not entered an NPI in CHAMPS.

Providers should complete the online application at the National Plan and Provider Enumeration System website to obtain an NPI. Home Help agency providers should enroll as a Type 2 (Organization) NPI. Comments are due to the MDHHS Oct. 31, 2023.

Members with questions should contact Vickie Kunz at the MHA.

Gov. Whitmer Announces Grant Recipients for Enhanced Mental Health Support

As part of Gov. Whitmer’s commitment to ensuring access to behavioral health services, the Michigan Department of Health and Human Services recently awarded more than $900,000 to five Community Mental Health Service Programs (CMHSP). The mobile response grant program will bolster Michigan’s mental health resources and increase availability of intensive crisis stabilization services, particularly for children and families.

The five CMHSPs receiving grant funds, include:

  1. Community Mental Health Authority of Clinton, Eaton, and Ingham Counties.
  2. Detroit Wayne Integrated Health Network.
  3. Genesee Health System.
  4. Gratiot Integrated Health Network.
  5. Saginaw County Community Mental Health Authority.

MHA-member hospitals and health systems should be aware of this added capacity in their areas for behavioral health support. If challenges in accessing these services arise, contact Lauren LaPine at the MHA.