MHA Monday Report Jan. 10, 2022

MHA Covid-19 update

Combating the Novel Coronavirus (COVID-19): Weeks of Dec. 20, Dec. 27 and Jan. 3

According to the Centers for Disease Control and Prevention (CDC) COVID Data Tracker, the omicron variant of COVID-19 is now the dominant strain across the U.S. The CDC’s model indicates that more than 95% of cases in the nation as of Jan. 1 may be due to omicron. …


Governor Signs Bill to Codify Licensure Exemptionscapitol building

On Dec. 27, Gov. Gretchen Whitmer signed into law Senate Bill 759, which codifies a licensure exemption provision that has given hospitals regulatory flexibility to appropriately respond to the pandemic, specifically staffing challenges. …


Virtual BreakthroughPandemic and Workforce Challenges Topics at MHA Breakthrough

At the close of 2021, the COVID-19 pandemic situation confronting Michigan hospitals was dire. A prolonged fourth surge drove intensive care unit occupancy rates to nearly 90 percent. Additionally, significant workforce challenges that predated the pandemic became worse and the increasing rates of …


Webinar Will Help Boards Analyze Strategic Plan

Innovation in medicine and service delivery, new competitors, payer upheaval, renewed scrutiny on the social determinants of health, and more are creating instability. There is much work ahead for hospital and health system boards as organizations reassess their strategic plans, community …


Medicaid to Cover Dialysis Services for ESO Beneficiaries in Dialysis Facilities

The Michigan Department of Health and Human Services recently released concurrent proposed and final policies to clarify Medicaid policy for the treatment of End Stage Renal Disease for beneficiaries covered under Medicaid Emergency Services Only. …


Virtual Events Focus on Active Shooter, Workplace Violence Prevention and Response

Aggressive behavior and violence are becoming a too frequent reality, whether it is expressed as violence against caregivers or gun violence in the community. The MHA is holding two virtual events to assist members with these challenges. …


WELL-B Program Starting March 1

Well-being Essentials for Learning Life-Balance is a behavioral health training program for the healthcare workforce that delivers weekly webinars on evidence-based well-being topics, including prevalence and severity of burnout, relationship resilience and being present. Compared to …


MHA CEO Brian Peters appears on CNN on Jan. 3, 2022.

Headline Roundup: Weeks of Dec. 20, Dec. 27 and Jan. 3 for COVID-19 in Michigan

The MHA has been actively fielding and responding to media requests related to the surge of COVID-19 cases and hospitalizations, the omicron variant and increasing rates of violence against healthcare workers. …


The Keckley Report

Paul Keckley

The No Surprise Act Means Plenty of Surprises

“Effective last Sunday, the No Surprises Act (NSA) passed by Congress in December 2020, became law. It protects consumers against surprise bills from out-of-network hospitals and physicians which apply to 10 million patient encounters including 1 in 5 emergency room visits and 1 in 6 in-network hospitalizations.”

Paul Keckley, Jan. 3, 2022


News to Know

Hospital staff are encouraged to participate in a national webinar hosted by DataGen to review the Medicare fee-for-service outpatient prospective payment system final rule and impact analysis for calendar year 2022.


Medicare Outpatient Payment Final Rule Makes Changes for 2022

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service outpatient prospective payment system (OPPS) effective Jan. 1, 2022. Provisions of the rule will:

  • Increase the civil monetary penalty (CMP) for hospitals that fail to comply with the price transparency requirements that took effect Jan. 1, 2021. The CMS is setting a minimum CMP of $300/day that will apply to smaller hospitals with a bed count of 30 or fewer and a penalty of $10/bed/day for hospitals with a bed count greater than 30, up to a maximum daily penalty of $5,500.
  • Increase the standard outpatient conversion factor by 1.7%, from $82.80 to $84.18, for hospitals that comply with the outpatient quality reporting program (QRP) requirements.
  • Implement a cost outlier threshold of $6,175, a 16.5% increase from the current threshold of $5,300.
  • Halt the elimination of the inpatient only list and add back to the list the services removed in 2021 except for CPT codes 22630 (Lumbar spine fusion), 23472 (Reconstruct shoulder joint), 27702 (Reconstruct ankle joint) and their corresponding anesthesia codes.
  • Reinstate the ambulatory surgical center (ASC) covered procedures list (CPL) criteria that were in effect in 2020 and prior years and adopt a process, beginning in March 2022, to allow an external party to nominate a surgical procedure to be added to the ASC CPL.
  • Continue the current policy of paying a reduced amount of average sales price minus 22.5% for drugs and biologicals purchased under the 340B drug discount program. The CMS will continue to exempt rural sole community hospitals, prospective payment-exempt cancer hospitals and children’s hospitals from the reduced payment policy implemented for most hospitals in 2018.
  • Make non-opioid pain management drugs and biologicals that function as a surgical supply in the ASC setting eligible for separate payment when such product is approved by the Food and Drug Administration, indicated for pain management or as an analgesic, and has a per-day cost above the OPPS drug packaging threshold.
  • Modify the hospital outpatient QRP by adopting three new measures, including the COVID-19 Vaccination Coverage Among Health Care Personnel measure in the OPPS and ASC settings, and removing two measures:
  • OP-02: Fibrinolytic Therapy Received Within 30 Minutes of Emergency Department Arrival measure.
  • OP-03: Median Time to Transfer to Another Facility for Acute Coronary Intervention measure.
  • Require mandatory reporting of the outpatient and ASC consumer assessment of healthcare providers and systems patient experience survey beginning in 2024.
  • Make several modifications to the Radiation Oncology Model and officially launch the model Jan. 1, 2022.

The CMS received input on the new Rural Emergency Hospital designation and continues to review comments; the agency will respond to the comments in future rulemaking. The CMS also received input on making reporting of health disparities based on social risk factors and race and ethnicity more comprehensive and actionable by including additional demographic data points.

The MHA will provide hospitals with an estimated impact analysis of the final rule soon. Members with questions should contact Vickie Kunz at the MHA.

Combating the Novel Coronavirus (COVID-19): Week of Oct. 18

MHA Covid-19 update

MHA Covid-19 updateThe MHA continues to keep members apprised of pandemic-related developments affecting hospitals through email updates and the MHA Coronavirus webpage. Important updates are outlined below.

CDC, FDA Approve Moderna and J&J Boosters, Mix and Match Strategy

The director of the Centers for Disease Control and Prevention (CDC) Oct. 21 formally endorsed the use of COVID-19 booster shots from Moderna and Johnson & Johnson (J&J) for some adults. This comes on the heels of the Oct. 20 approval from the Food and Drug Administration (FDA).

The actions authorize a Moderna booster for people 65 and older and for all adults who either have underlying conditions or work in settings where they’re more likely to be exposed to the virus. Those people may obtain the Moderna booster, which is half the size of each dose used for initial vaccination, six months after completing the primary vaccine series.

The agencies also recommended all adults who received the J&J single-shot vaccine get a booster at least two months post-immunization. In addition, the agencies agreed that people who are eligible can choose any type of booster, regardless of whether they initially received the Pfizer, Moderna or J&J version. This decision may help individuals who have a higher risk of side effects with a particular brand of vaccine.

Healthcare providers are encouraged to continue monitoring for email updates from the Michigan Department of Health and Human Services (MDHHS) and Health Alert Network for details regarding booster dose administration. The MDHHS has also posted updated fact sheets for the vaccines on its website for vaccinating providers.

The MHA continues to promote both factual and anecdotal messaging about the safety and effectiveness of COVID-19 vaccines. The association is also using messaging on flu vaccines, urging people to get vaccinated and practice smart preventive measures to help avoid “twindemic” status and add to the stress on the healthcare system.

Members with vaccine questions may contact Ruthanne Sudderth at the MHA.

MHA Urges Medicaid to Cover Merck COVID-19 Treatment Pill

The MHA submitted comments Oct. 18 to state Medical Services Administration officials, urging them to add molnupiravir, Merck’s new COVID-19 treatment pill, to the Medicaid Health Plan Common Formulary if it is approved by the FDA. The medication has been shown to effectively treat COVID-19 and reduce death and hospitalization. Importantly, it comes in pill form that the patient takes at home, unlike current antibody treatments that must be administered by health and hospital professionals, using time and resources that are currently scarce. The association will keep members apprised of the FDA’s review of the treatment and any action by the state to add it to the Common Formulary.

Additional information on the COVID-19 pandemic is available to members on the MHA Community Site and the MHA COVID-19 webpage. Questions on COVID-19 and infectious disease response strategies may be directed to the MDHHS Community Health Emergency Coordination Center (CHECC).

News to Know – Week of Oct. 18

Gov. Gretchen Whitmer signed an executive order Oct. 14 that creates the Health and Aging Services Administration within the Michigan Department of Health and Human Services. As noted in the governor’s news release, the change was made to better coordinate services for the state’s growing aging population. The new state agency combines the Aging and Adult Services Agency and the Medical Services Administration — the state’s Medicaid agency. Medicaid Director Kate Massey will serve as the senior deputy director of the new administration.

Legislature Passes State Budget That Protects Healthcare Funding

capitol building

Michigan CapitolThe Michigan Legislature approved Sept. 22 the fiscal year (FY) 2022 state budget. The governor has indicated support for the budget that goes into effect Oct. 1, and the agreement protects vital funding sources for patient care in Michigan hospitals and expands access to healthcare services. The MHA published a statement on the passage of the budget Sept. 22.

Specifically, the budget reflects the protection or enhancement of many MHA priorities:

  • Continues enhanced outpatient Medicaid rates. For FY 2022, the increase in rates is projected to result in the continuation of funding that translates to $270 million in net revenue for hospitals.
  • Protects funding for the rural access pool and obstetrical stabilization fund.
  • Continues to maintain funding for disproportionate share hospitals (DSH) and graduate medical education (GME), pursuant to the MHA board-supported multiyear budget agreement.
  • Fully funds the Healthy Michigan Plan.
  • Continues the additional $2.35 hourly wage increase for direct care workers at skilled nursing facilities and enhanced reimbursement for ground ambulance services to reimburse at 100% of the Medicare rate.
  • Continues expanded Medicaid coverage for women up to 12 months postpartum.
  • Adds $3 million in new funding to set up a statewide system of care for stroke and ST-elevated myocardial infarction (STEMI) emergencies within the existing statewide trauma system.

In addition, nearly $10 billion in state and federal funding is still available that will be allocated through a supplemental budget process. The MHA will advocate the state use portions of the funding to address the association’s behavioral health priorities and workforce issues.

Members with questions on the state budget may contact Adam Carlson at the MHA.

Rapid Whole Genome Sequencing Explored in Project Baby Deer Case Review

Project Baby Deer logo

The MHA Keystone Center, through Project Baby Deer, is hosting a call from noon to 1 p.m. Sept. 16 to discuss rapid Whole Genome Sequencing (rWGS).

The first half of the call will be dedicated to an organization’s case review, which will share testing, results and key takeaways. The second half will serve as a “town hall” discussion, sharing program achievements and clinical or economic outcomes. All birthing and children’s hospitals are welcome to participate. Contact the MHA Keystone Center for event information.

Project Baby Deer is an rWGS project to improve pediatric intensive care units and outcomes in Michigan. With genetic disorders being a leading cause of morbidity and mortality in infants, early diagnosis of genetic disease has the potential to change clinical management in many meaningful ways: initiating lifesaving treatments, avoiding unnecessary tests and procedures, shortening hospital stays and empowering families with real-time diagnoses to help with their understanding and decision-making.

Additionally, separate Medicaid payment will be available for rWGS when clinical and authorization criteria are met effective Sept. 1, pending Centers for Medicare & Medicaid Services approval. Learn more about covered and noncovered rWGS criteria in the Aug. 17 Medical Services Administration bulletin.

Medicaid Proposal Would Standardize Lab Billing for Testing of Multiple Genes

The Michigan Department of Health and Human Services (MDHHS) recently released a proposed policy to standardize the billing and coding of next generation sequencing multigene panel laboratory tests across laboratory providers. The proposed changes would result in aligning Michigan Medicaid claim submission requirements with the Centers for Medicare & Medicaid Services requirements when multiple genes are tested. The proposed policy applies to Medicaid fee-for-service and indicates that Medicaid health plans and integrated care organizations would be required, at a minimum, to provide the full range of covered services described in the policy and may choose to provide additional services beyond those specified. Providers would be required to check with the beneficiary’s health plan for applicable coding, billing and authorization instructions.

Under the proposed policy, effective for dates of service on and after July 1, 2021, if a laboratory simultaneously assays multiple genes in parallel for an individual beneficiary, those genes would be considered part of the same panel, requiring submission of one procedure code. The laboratory would be directed not to report multiple individual procedures codes describing the gene component test results.

Providers are encouraged to review the proposal and submit comments to the MDHHS by May 19. Members with questions should contact Vickie Kunz at the MHA. 

Michigan’s Medicaid Work Requirement Rescinded

The Biden administration informed the state of Michigan April 6 it had withdrawn approval of the state’s community engagement requirement for some adult beneficiaries of the Healthy Michigan Plan, also known as the work requirement. In a 64-page letter, the Centers for Medicare & Medicaid Services (CMS) issued a finding that the requirement to work, job train, attend certain types of education or participate in substance use disorder treatment “risks significant coverage loss and harm to beneficiaries.”

Michigan’s work requirement began in January 2020 but was halted by court order in March 2020. The Families First Coronavirus Response Act, which grants states an additional 6.2 percent federal match for the Medicaid program during the COVID-19 pandemic, prohibits reducing the enrollment of Medicaid beneficiaries effective March 2020. Michigan continues to accept the additional 6.2 percent funding, which is in force at least through the end of calendar year 2021, depending on the end of the declaration of the federal public health emergency.

Even without the requirements related to the extra federal Medicaid funding, the CMS determined that requiring work or other community engagement as a condition of eligibility for Medicaid is not likely to promote the objectives of the Medicaid statute. The authority to impose a work requirement is withdrawn immediately and applies beyond the time frame of the public health emergency. For more information about the CMS action to end Michigan’s Medicaid work requirement or the Healthy Michigan Plan, contact Laura Appel at the MHA.

Combating the Novel Coronavirus (COVID-19): Week of March 22

MHA Covid-19 update

MHA COVID-19 UpdateThe MHA continues to keep members apprised of pandemic-related developments affecting hospitals through email updates and the MHA Coronavirus webpage. Important updates are outlined below.

MHA News Release Urges Vigilance as COVID-19 Cases, Hospitalizations Rise

The MHA issued a news release March 24 regarding the increase in hospitalization rates across Michigan and the positive impact vaccines are having on preventing hospitalization in older adults. The MHA urged residents to help prevent a spring surge of COVID-19 by ensuring they follow recommended preventive measures.

The news release generated significant statewide and national media coverage (see related article), including social media. Members may receive additional inquiries about the surgeRuthanne Sudderth at the MHA.

Vaccine Allocation to Increase

The state indicated March 26 that approximately 600,000 vaccines will come into Michigan during the week of March 29, marking an increase over the previous two weeks. That number includes the state’s supply and those vaccines being sent directly by the federal government to retail pharmacies, federally qualified health centers and the Ford Field mass vaccination site that opened March 24. As of March 25, Michigan providers had administered more than 3.8 million vaccine doses and fully vaccinated more than 1.4 million Michigan residents — or nearly 18% of the eligible adult population. Members with vaccine questions may contact Ruthanne Sudderth at the MHA.

Medicaid Payment for Vaccine Administration to Increase to Medicare Rates

As previously reported, the Biden administration March 15 updated Medicare rates for vaccine administration, increasing them to $40 per dose of each of the currently available vaccines.

A final policy issued by the Medical Services Administration in December stipulates that Medicaid fee-for-service (FFS) and managed care payment rates for COVID-19 vaccine administration services will equal the Medicare rates for equivalent services. All Medicaid reimbursement rates will be reviewed and updated as applicable and are available on the MDHHS webpage for Medicaid providers by clicking on Billing & Reimbursement and Provider Specific Information.

The MSA also issued concurrent proposed and final policies indicating that the vaccine cost for MI Health Link beneficiaries will be covered by the Medicare FFS program during calendar years 2020 and 2021. Members with questions should contact Vickie Kunz at the MHA.

Additional information on the COVID-19 pandemic is available to members on the MHA Community Site and the MHA COVID-19 webpage. Questions on COVID-19 and infectious disease response strategies may be directed to the MDHHS Community Health Emergency Coordination Center (CHECC).

Prepare to Post Hospital Charges, Rates by Jan. 1

The MHA will host a webinar from 1 to 2:15 p.m. EST Nov. 10 to discuss the Centers for Medicare & Medicaid Services (CMS) Hospital Price Transparency Final Rule.  Beginning Jan. 1, hospitals will be required to post online, in a machine-readable format, their standard charges for all items and services provided and payer-specific negotiated rates for 300 “shoppable” services.

Finance leaders have assumed the court was going to strike down the rule or advocates would succeed in delaying it, but the CMS has been clear that it is considering other reporting requirements tied to Medicare reimbursements to encourage hospitals to provide the requested information. Now is the time to plan for and identify the potential compliance concerns with price transparency.

Leading the webinar is Kathy Reep, senior manager with PYA, a healthcare financial consulting firm with more than 300 professionals across offices in the Midwest and South. Reep has more than three decades of experience in Medicare and Medicaid compliance, finance and reimbursement, and managed care.

For more information on the webinar, contact Erin Steward at the MHA.