Critical Access Hospitals (CAHs) that accept Medicare and Medicaid payments must follow the Centers for Medicare & Medicaid Services (CMS) Conditions of Participation (CoP). The CMS CAH Manual has seen multiple changes to regulations and interpretive guidelines. The MHA Health Foundation five-part webinar series Critical Access Hospitals’ Conditions of Participation: Ensuring Compliance will review in detail the guidelines that serve as a basis for determining compliance.
Topics that will be covered in detail include:
CMS requirements of the board’s duty to enter into a written agreement if the hospital wants to provide telemedicine services.
CMS list of emergency drugs and equipment that every CAH must have.
Requirements for pharmacists, including development, supervision and coordination of pharmacy activities.
Requirements for security and storage of medications, medication carts and anesthesia carts.
CMS infection control worksheet and how it may be helpful to CAHs.
Hospital visitation and patient information policies.
The webinars are scheduled from 10 a.m. to noon Jan. 17, Jan. 24, Jan. 31, Feb. 7 and Feb. 14. Members can register for a connection fee of $780 for the series. Individual webinars are $195 per session.
Members with questions should contact Erica Leyko at the MHA.
After the MHA’s recent visits to Capitol Hill to advocate for year-end member priorities, Congress has reached a major deal on a year-end omnibus legislative package. The package includes health policy measures related to Medicare and Medicaid provisions, telehealth and hospital-at-home programs.
Lawmakers are blocking the implementation of the Statutory Pay-As-You-Go (PAYGO) sequester which would have required a 4% cut to Medicare payments. In addition, both the Medicare Dependent Hospital and enhanced low-volume adjustment programs are extended for two years. The Medicare hospital-at-home program and pandemic-era telehealth flexibilities are also extended for two years. There is a one-year delay in lab payment changes stemming from the Protecting Access to Medicare Act of 2014.
Regarding Medicaid, the package separates the enhanced federal medical assistance percentage (FMAP) and the Medicaid eligibility maintenance of effort from the declaration of the Public Health Emergency. Beginning in April, states may remove those who no longer qualify for Medicaid, regardless of when the COVID-19 public health emergency ends. The enhanced FMAP, currently a 6.2% addition to state Medicaid matching rates, is gradually phased out through 2023. These changes help fund a year of continuous coverage provisions for children at risk of losing health insurance and standardizing 12 months of postpartum coverage.
Passage of the final legislation is likely to happen by midnight on Dec. 23, 2022. The bill text is public, giving high likelihood to the healthcare provisions outlined above. However, there is a possibility for last-minute changes.
For more information about the year-end omnibus legislation contact Laura Appel at the MHA.
DataGen is hosting a national webinar to review the 2023 Medicare fee-for-service outpatient prospective payment system final rule and hospital impact analysis at 3 p.m. on Nov. 30, 2022. This webinar is available free of charge but registration is required. The MHA will provide hospitals with an impact analysis of the final rule within the next few weeks. Members with questions should contact Vickie Kunz the MHA.
MHA Endorsed Business Partner NextJob is hosting a free webinar on Actionable Neuroscience Insights for Improved Workplace Performance at noon ET Dec. 7, 2022 to educate employees about the brain processes of perception, cognition and neuro-linguistics and share tips to help improve performance at work. MHA members are invited to register and share information about the webinar with their colleagues. To learn more, visit the business partner profile page for NextJob or contact Paul Dzurec at NextJob.
The Centers for Medicare and Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service (FFS) outpatient prospective payment system (OPPS) effective Jan. 1, 2023.
The rule restores 340B drug payments to the default rate, generally average sales price (ASP) plus 6%, up from the previous ASP minus 22.5%, in response to the recent federal Supreme Court (SC) ruling. The CMS notes that the agency is still evaluating how to apply the SC’s decision in the American Hospital Association (AHA) v Becerra case which ordered the CMS to restore payments. The CMS will address this in future rulemaking prior to the 2024 OPPS proposed rule.
The MHA, along with the AHA and others, continue to urge the Court to order the CMS to promptly repay hospitals harmed by the unlawful cuts implemented in 2018 and ensure that no hospitals are not penalized. Other provisions of the final rule include:
Increasing the conversion factor by a net 1.7% after budget neutrality adjustments from $84.18 to $85.59 for hospitals that comply with the CMS outpatient quality reporting (OQR) program requirements.
Establishing the new rural emergency hospital provider type to allow critical access hospitals and rural hospitals with less than 50 beds to continue providing essential outpatient services while eliminating inpatient services.
Exempting rural sole community hospitals from the site neutral clinic visit cuts and instead paying the full OPPS rate for visits provided at grandfathered off-campus hospital outpatient departments.
Increasing the cost outlier threshold by 40% from $6,175 to $8,625, to maintain outlier payments at the targeted 1% of total OPPS payments, resulting in fewer cases qualifying for an outlier payment.
Removing 11 services from the inpatient only list and adding 8 services that were newly created by the American Medical Association Common Procedural Terminology Editorial Panel.
Implementing a permanent 5% cap on wage index decreases.
Adding four procedures to the Ambulatory Surgical Center covered procedures list.
Requiring prior authorization for an additional service category, facet joint interventions, beginning dates of service on or after July 1, 2023.
Continuing payment for virtual behavioral health services with an in-person service required within six months prior to the initiation of the virtual service and then annually thereafter, with exceptions made based on beneficiary circumstances. The CMS clarified that the requirement for an in-person visit within six months prior to the initial services is not required for patients who began receiving services during the public health emergency (PHE) or during the 151-day period following the end of the PHE.
Maintaining the current policy of providing separate payment for non-opioid pain management drugs and biologicals that function as supplies in the ASC setting.
Implementing a payment adjustment for costs incurred for domestically manufactured National Institute for Occupational Safety and Health (NIOSH)-approved surgical N95 respirators with payments provided biweekly as interim lump-sum payments and reconciled at cost report settlement for cost reporting periods beginning on or after Jan. 1, 2023.
Creating a new G-code for dental rehabilitation services that require monitored anesthesia and the use of an operating room and assigning it to APC 5871 (Dental Procedures), effectively increasing the payment from roughly $200 to approximately $2,000.
Changes to the hospital OQR program including:
Making the Cataracts: Improvement in Patient’s Visual Function within 90 Days Following Cataract Surgery (OP-31) measure voluntary rather than mandatory beginning with the 2025 reporting period and 2027 payment determination.
Aligning the patient encounter quarters for chart-abstracted measures to the calendar year for annual payment update determinations.
Adding a targeting criterion for measure data validation.
The MHA will provide hospitals with an updated impact analysis and additional details of the rule in the coming weeks.
Members with questions should contact Vickie Kunz at the MHA.
The Centers for Medicare and Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service home health (HH) prospective payment system (PPS) effective Jan. 1, 2023. Key provisions include:
A net 1.0% decrease in the national 30-day standardized payment amount from $2,031.64 to $2,010.69 after budget neutrality adjustments, compared to the proposed 6.25% decrease. HHs that fail to comply with HH quality reporting program requirements are subject to a two percentage point reduction and are subject to a rate of $1,972.02.
A seven percentage point cut to all payments to achieve budget-neutrality for the Patient-Driven Groupings Model phased in over two years, with a 3.5 percentage point cut in 2023 and 2024.
A permanent 5% cap on wage index decreases.
Required submission of patient assessment data on all patients, regardless of payer, with a phased approach beginning Jan. 1, 2025, instead of 2024 as proposed.
Changes to the Expanded HH value-based purchasing model, including definitions for the baseline and model year and changing the baseline year for the 2023 program year to 2022 to use the most recently available data.
The MHA will provide members with an updated impact analysis and additional details of the final rule within the next few weeks. Members that have not received impact analyses in the past for affiliated, free-standing HH agencies are encouraged to provide the agency’s CMS certification number (also known as Medicare provider number), agency name and federal information processing standards code in order to receive an estimated impact analysis in the future.
Members with questions should contact Vickie Kunz at the MHA.
The Michigan Department of Health and Human Services (MDHHS) recently released a proposed policy to increase Medicaid payment rates to $2,300 for dental services provided at outpatient hospitals and $1,495 for services provided in an ambulatory surgical center (ASC).
Pending approval by the Centers for Medicare and Medicaid Services, the policy would go into effect Oct. 1, 2022. The proposal states that services would move from the current outpatient prospective payment system to a Medicaid fee schedule. Services should be billed using dental surgery procedure code 41899 with payment based on the Medicaid fee schedule in effect on the date of service for the procedure code(s) billed. Outpatient hospital and ASC fee schedules are available on the MDHHS website under the billing and reimbursement and provider specific information tab.
Hospitals are encouraged to review the proposed policy and submit comments to the MDHHS by Nov. 23, 2022. Members with questions should contact Vickie Kunz at the MHA.
The MHA Legislative Policy Panel convened Oct. 12 to develop recommendations for the MHA Board of Trustees on legislative initiatives impacting Michigan hospitals …
The Michigan Department of Health and Human Services (MDHHS) recently released two concurrent final and proposed policies to implement Medicaid rate increases included in the fiscal year (FY) 2023 budget for dates of service on and after Oct. 1, 2022 …
Registration is now open for the Michigan Health Equity Summit that will take place in-person at Lansing Community College West Campus and virtually from 9 a.m. to 3:30 p.m. ET on Nov. 3 …
The Community Foundation for Southeast Michigan (CFSEM) is partnering with the MHA Keystone Center, the Michigan Opioid Partnership (MOP) and the Michigan Department of Health and Human Services (MDHHS) to provide …
Recently, The Joint Commission (TJC) and the Centers for Medicare & Medicaid Services (CMS) announced their commitment in driving the next decade of health equity for people who are underserved. The commitment to advancing health equity …
The MHA released another episode of the MiCare Champion Cast, which features interviews with healthcare policy experts in Michigan on key issues that impact healthcare and the health of communities …
The MHA’s Race of the Week series highlights the most pivotal statewide races and ballot questions for Election 2022. The series will provide hospitals and healthcare advocates with the resources they need to make informed decisions on Election Day, including candidates’ views and background …
“The bottom line: in the next 2-3 years, regulatory scrutiny of Medicare Advantage will increase and funding by Medicare will decrease. Congress will press for a clear correlation between Medicare’s solvency and MA cost-savings. Thus, it’s likely Medicare Advantage plans will charge higher premiums, limit benefits, intensify medical management activities, share more financial risk with high-performing provider organizations and offer services to new populations. Their margins will shrink, access to capital and enrollment growth will be imperatives, and innovation in holistic cost-effective care management and affordability key differentiators.”
The Michigan Department of Insurance and Financial Services (DIFS) issued Bulletin 2022-17-INS Oct. 5 in the matter of payment and billing guidance for no-fault automobile insurers and healthcare providers following an order from the Michigan Supreme Court in the Andary v. USAA lawsuit …
The Michigan Department of Health and Human Services (MDHHS) released a proposed policy to rescind remaining waived provider enrollment (PE) requirements implemented by MSA 20-28 and resume required enrollment activities that were waived during the federal COVID-19 Public Health Emergency (PHE) …
The Centers for Medicare & Medicaid Services (CMS) recently announced the calendar year 2023 Medicare fee-for-service Part A deductible for inpatient hospital services will increase by $44 to a new total of $1,600 …
As hospitals and health systems across Michigan continue to face workforce challenges, the MHA has developed a downloadable communications toolkit focused on workforce sustainability …
Food insecurity and health outcomes go hand in hand, as those who struggle to put food on the table are at a higher risk of conditions like diabetes, hypertension and heart disease. In 2020, more than one million Michiganders faced food insecurity – including 300,000 children …
The American Academy of Pediatrics (AAP) recently announced multiple grant opportunities for health organizations and AAP Chapters to improve community confidence in vaccines and to support pediatricians in the delivery of on-time vaccinations …
Healthcare workforce shortages, particularly nursing shortages, are severely hindering the ability to provide patient-centered care. Unionizing to negotiate for policies like staffing ratios is popular but does not consider the complexity of significant workforce shortages …
The MHA’s Race of the Week series highlights the most pivotal statewide races and ballot questions for Election 2022. The series will provide hospitals and healthcare advocates with the resources they need to make informed decisions on Election Day, including candidates’ views and background …
“Last Wednesday, the White House hosted the White House Conference on Hunger, Nutrition, and Health in DC—the first since the Nixon administration’s conference in 1969. Noting that food insecurity is an issue in one in four US households and the eroding nutritional value of the food supply chain, the Administration laid out its strategy in a 44-page document featuring 5 pillars of its attention…
The White House Strategy is a great start but the issues of food insecurity and nutritional deficiency require urgent, comprehensive and dedicated attention. The White House says it has secured pledges of $8 billion from the private sector to advance the strategy: that’s a good start, but only a fraction of what’s needed.”
A second gubernatorial debate is scheduled for 7 p.m. Oct. 25 on the Oakland University campus between Gov. Gretchen Whitmer and Republican candidate Tudor Dixon.
Early in-person voting by absentee ballot at a clerk’s office is currently available.
Complimentary MI Vote Matters informational posters and the 2022 Candidate Guide remain available for MHA members.
Bridge Michigan published an article Oct. 4 which focuses on the staffing challenges impacting behavioral health providers that limit bed capacity. The article begins by reviewing the number of reduced beds at state psychiatric facilities …
The Centers for Medicare & Medicaid Services (CMS) recently announced the calendar year 2023 Medicare fee-for-service Part A deductible for inpatient hospital services will increase by $44 to a new total of $1,600. The Part A daily coinsurance amounts will be:
$400 for days 61-90 of hospitalization in a benefit period.
$800 for lifetime reserve days.
$200 for days 21-100 of extended care services in a skilled nursing facility in a benefit period.
The monthly Part A premium, paid by beneficiaries who have fewer than 40 quarters of Medicare-covered employment and certain people with disabilities, will increase by $7 in 2023 to a total of $506. Certain voluntary enrollees eligible for a 45% reduction in the monthly premium will pay $278.
The annual deductible for Medicare Part B will decrease by $7 to a total of $226, while the standard monthly premium for Medicare Part B will decrease by $5.20 to a total of $164.90.
Members with questions should contact Vickie Kunz at the MHA.
“Life’s most persistent and urgent question is, ‘What are you doing for others?” ― Martin Luther King, Jr.
Fall is officially upon us. At the MHA, that means a new program year is well underway, we have a new Strategic Action Plan in place and are preparing for the November election which is now just weeks away. This fall, we are also very proud to continue an annual tradition and publish two new reports documenting the critical role of our membership throughout the state: the 2022 Economic Impact of Healthcare in Michigan and the Healthy Futures, Health Communities community benefit report.
Fiscal year 2020 data (the most recently available) is shared in each report and it reinforces the position that hospitals are both economic drivers and community leaders. Healthcare remains the largest private sector employer in Michigan with nearly 572,000 total individuals directly employed, 224,000 of which are in hospitals. These direct healthcare workers earned $44.2 billion in wages, salaries and benefits and when combined with indirect, healthcare-supported jobs, contributed almost $15.2 billion in local, state and federal taxes. Hospitals provide mission-oriented work aimed at the health and wellness of their patients and communities, but the data is clear that hospitals clearly have a role in the economic health of our state as well.
We take our work towards improving community wellness seriously, which is demonstrated by the nearly $4.2 billion investment in community-based partnerships and programming. Hospitals invested more than $869 million in community and voluntary-based activities while providing $3.4 billion in uncompensated care. Hospitals are committed to not only caring for anyone who walks through their doors, but towards preventative care programs that can help reduce the need of inpatient hospital services. The costs of these efforts come directly out of a hospital’s bottom line but are vital towards ensuring vulnerable patients have the ability to receive needed care.
These reports are based on data from the first year of the pandemic. I do not have to tell you how trying and difficult those times were for hospitals. Despite the uncertainty and demand on hospitals and health systems during that time, they continued to support our communities in these important ways. Our healthcare system was stretched to new lengths, but we had over half a million individuals directly involved in providing care to patients. With a statewide population of 10 million, 40% of which are either under the age of 18 or aged 65 and older, healthcare either directly or indirectly employs over 18% of our workforce.
Yet the 2020 numbers also begin to provide evidence of the loss of healthcare workers that we anecdotally have shared for the last several years. For the first time in the history of the economic impact report, total direct jobs in Michigan from healthcare declined, including the loss of 7,000 jobs in hospitals. Despite those losses, total compensation for hospital workers remained the same, as contracted labor (e.g. those working for nurse staffing agencies) became a necessity for hospitals to maintain appropriate staffing levels.
But I do not want to lose sight of what the headline should be, and that is healthcare remains an economic engine and the largest private-sector employer in Michigan. At a time where every industry is struggling with having enough staff, healthcare remains a very significant employer. And the industry holds a tremendous amount of opportunity for new job growth moving forward: Michigan’s recent list of the top career fields with the highest projected growth is dominated by healthcare professions. Hospitals not only offer well-compensated careers with strong benefits, but in a rewarding field that truly makes a difference in the lives of our neighbors. Hospital careers also exist in communities large and small, helping to keep college graduates and young professionals in our state. Lastly, the skills of a healthcare professional are transferrable, regardless of region, and long-lasting. The training and education for a healthcare professional today will remain relevant over the next several decades.
Every year that goes by, hospitals seek to be more involved with individuals outside the walls of their facilities. They are helping to address the social determinants of health, including access to transportation and food insecurity. And they are intertwined in not only the individual health of community members, but in the success of local business and municipalities. Access to healthcare is at the top of any organization’s checklist wishing to expand their footprint into new markets. Our success depends on the success of community leaders and vice versa.
When we advocate for much-needed Medicaid and Medicare funding, for the 340B drug pricing program and for good health policy at the state and federal level, we do so because we know these are essential to maintaining access to quality healthcare in communities throughout Michigan. With the facts presented by our new reports on economic impact and community benefit, we believe there is more reason than ever for our elected officials – and all of us – to support our Michigan hospitals.
MHA Keystone Center Presents Annual Health Equity Summit
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MHA Race of the Week – Michigan Supreme Court
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