MHA Monday Report June 2, 2025

MHA and DataGen to Host Upcoming Medicare Quality-Based Program Webinars

The MHA has partnered with DataGen to host two upcoming webinars focused on the Medicare fee-for-service (FFS) quality-based programs which can reduce hospital inpatient FFS payments by up to 6% based on performance. The webinars …


MHA Releases Executive Summary of Recent MDHHS Blood Lead Testing Mandate Rules

The MHA recently released an executive summary regarding the Michigan Department of Health and Human Services’ (MDHHS) adoption of new administrative rules establishing universal blood lead testing requirements for minors across the state. The goal of …


CMS Issues New Guidance on Hospital Price Transparency Requirements

The Centers for Medicare & Medicaid Services (CMS) released updated guidance May 22 related to hospital price transparency requirements under Executive Order 14221, “Making America Healthy Again by Empowering Patients with Clear, Accurate and Actionable …


Language, Trust and Care: Reflections from the AHA Behavioral Health Workshop

I had the opportunity to attend at the end of April a Behavioral Health Workshop in New Orleans hosted by the American Hospital Association. This interactive event brought together hospital leaders, clinical teams and behavioral health professionals to co-design care


Keckley Report

The Summer of 2025 for U.S. Healthcare: What Organizations should Expect

“Last Thursday, the Make America Healthy Again Commission released its 68-page report “Making America’s Children Healthy Again Assessment” featuring familiar themes—the inadequacy of attention to chronic disease by the health system, the “over-medicalization” of patient care vis a vis prescription medicines et al, the contamination of the food-supply by harmful ingredients, and more. HHS Secretary Kennedy, EPA Administrator Zeldin and Agriculture Secretary Rollins pledged war on the corporate healthcare system ‘that has failed the public’ and an all-of-government approach to remedies for burgeoning chronic care needs. …

As MAHA promotes its agenda, Congress passes a budget and MAGA advances its anti-establishment agenda vis a vis DOGE et al, healthcare operators will be in limbo. The dust will settle somewhat this summer, but longer-term bets will be modified for most organizations as compliance risks change, state responsibilities expand, capital markets react and Campaign 2026 unfolds.

And in most households, concern about the affordability of medical care will elevate as federal and state funding cuts force higher out of pocket costs on consumers and demand for lower prices.

The summer will be busy for everyone in healthcare.”

Paul Keckley, May 27, 2025


Laura AppelMHA in the News

WLUC TV6 in Michigan’s Upper Peninsula published a story May 29 on the shortage of inpatient psychiatric beds in Michigan, placing a heavy focus on the testimony the MHA delivered May 20 before the House …

MHA Monday Report May 26, 2025

MHA Testifies in House Oversight Subcommittee, IMLC and AOT Legislation Passes Senate

The MHA provided testimony May 21 to the House Oversight Subcommittee on Public Health & Food Security on certain challenges related to behavioral health patients and the need for inpatient psychiatric beds across the state. …


Medical Residents Highlight Workforce Needs During 2025 GME Capitol Day

The MHA Graduate Medical Education (GME) Capitol Day welcomed more than 40 physician residents from a dozen member hospitals to the MHA Capitol Advocacy Center offices May 21 for a day of meetings with members …


MHA Keystone Center PSO to Hosts Two Safe Tables in June

The MHA Keystone Center Patient Safety Organization (PSO) will host two upcoming safe table events in June focused on cybersecurity risk management and regulatory inspections. These events offer healthcare leaders an opportunity to engage in …


Federal Agencies Pause Enforcement of 2024 Mental Health Parity Rule

The Department of Labor, Health and Human Services, and the Treasury recently announced that the 2024 final rule on the Mental Health Parity and Addiction Equity Act will not be enforced, following a legal …


MHA and DataGen to Host Upcoming Medicare Quality-Based Program Webinars

The MHA has partnered with DataGen to host two upcoming webinars focused on the Medicare fee-for-service (FFS) quality-based programs which can reduce hospital inpatient FFS payments by up to 6% based on performance. The webinars …


Today’s Students Are Tomorrow’s Workforce

The healthcare workforce has been a top priority for MHA’s members, an active pillar in the annual strategic action plan for several years. The healthcare profession is arguably one of the most rewarding career fields, leaving lasting impacts on communities. …


Keckley Report

The Winners and Losers in One Big Beautiful Bill

“This week, Republicans in the House will pass “One Big Beautiful Bill” they can forward to the Senate ahead of their self-imposed Memorial Day deadline. Its fate in the GOP controlled Senate is likely to be less partisan with a similar outcome: in some form, it will pass setting the stage for Campaign 2026 partisan posturing and continued chaos for most industries especially healthcare.  …

What’s clear is this: healthcare is suspected of widespread waste, poor performance and putting profits above patient care by lawmakers in DC, state capitals, non-healthcare business leaders and the majority of the public who think a shake-up is needed. Each organization in healthcare believes it operates for the greater good and delivers optimal value for funds received. The budgeting process prompts questions about who’s right.”

Paul Keckley, May 19, 2025


New to KnowNews to Know

  • MHA offices will be closed and no formal meetings will be scheduled May 26 in honor of Memorial Day.
  • The MHA is seeking dedicated leaders to serve on its committees, councils and task forces, with the call for participation open through June 2, 2025.

Lauren LaPineMHA in the News

The MHA received news coverage during the week of May 19 highlighted by stories related to Mental Health Awareness Month and the need to expand state psychiatric bed capacity. Lauren LaPine, senior director, legislative and …

MHA and DataGen to Host Upcoming Medicare Quality-Based Program Webinars

The MHA has partnered with DataGen to host two upcoming webinars focused on the Medicare fee-for-service (FFS) quality-based programs which can reduce hospital inpatient FFS payments by up to 6% based on performance. The webinars are free to attend, but registration is required.

DataGen Overview of Medicare’s Value-Based Purchasing Program & Analyses for MHA

This session, scheduled for 1:30 p.m. June 11, will review the Medicare value-based purchasing program, which evaluates hospital performance on measures across four domains. The CMS withholds 2% from Medicare FFS inpatient claims, totaling approximately $1.7 billion nationally, and redistributes these funds based on performance.

DataGen Overview of Medicare’s RRP/HAC Programs & Analyses for MHA

This session, scheduled for 1:30 p.m. June 17, will review the Medicare readmissions reduction (RRP) and hospital acquired conditions (HAC) reduction programs. The RRP evaluates readmissions for six medical conditions, with hospitals subject to penalties of up to 3% on Medicare inpatient payments for all FFS discharges. The HAC program assesses hospital performance using Medicare claims and Centers for Disease Control measures and imposes a 1% payment reduction to Medicare FFS payments for 25% of hospitals nationally.

Hospital quality department and finance staff are encouraged to register. The webinars will be recorded and available for future reference. Members with questions should contact Vickie Kunz at the MHA.

MHA Shares Medicare and Medicaid Enrollment Analysis

The MHA recently updated its analysis of Medicaid and Medicare enrollment based on February 2025 data. The analysis includes program enrollment as a percentage of each county’s total population and the split between fee-for-service and managed care organization. Just over 27% of Michigan’s total population is enrolled in Medicaid and 23% is enrolled in Medicare.

Roughly two-thirds of Michigan’s 2.66 million Medicaid beneficiaries are enrolled in one of nine managed care plans.

Total Medicare enrollment is 2.26 million with 63% of beneficiaries enrolled in a Medicaid Advantage (MA) plan with only two counties having less than 50% of total Medicare enrollment in MA plans. MA enrollment by county ranges from 46% to 78%, with 72 counties having 55% or more of their Medicare population enrolled in an MA plan.

February enrollment is spread across 47 MA plans with up to 26 plans covering beneficiaries in several Michigan counties, with a minimum of six plans available in each county.

Members with enrollment questions should contact the Health Finance team at the MHA.

How Could Medicaid Cuts Impact Michigan?

MiCare Champion Cast Header Photo

The MHA released a new episode of the MiCare Champion Cast exploring how proposed reductions to Medicaid could disrupt access to care and harm Michigan hospitals, patients and communities.

Laura Appel, executive vice president of government relations & public policy, MHA, first explored the history and purpose of Medicaid and the Healthy Michigan Plan, which has been hailed a success for improving access to care, reducing the uninsured rate and supporting economic stability for families across the state.

Appel explained the potential impact of recent federal proposals, which include instructions to cut Medicaid by at least $880 billion over 10 years. Changes like block grants, per capita caps and reduced federal matching rates could lead to a staggering $1.73 billion shortfall in the state budget, jeopardizing access to healthcare for millions.

“Cutting funding is cutting care,” said Appel. “Not every hospital is on the financial footing it wishes it were and there are a lot of hospitals across the country that are already in difficult financial straits…this could be the reason that they close all together.”

Michigan hospitals are asking members of Congress to protect the Medicaid program and oppose proposed reductions. Appel noted those interested in helping with this effort and reaching members of Congress are encouraged to visit the MHA Legislative Action Center.

Listeners can also expect to learn more about the impact proposed cuts would have on rural healthcare and Michigan’s economy. The episode is available to stream on Apple PodcastsSpotifySoundCloud and YouTube.

Medicare and Medicaid Enrollment Update

The MHA updated its analysis of Medicaid and Medicare enrollment based on December 2024 data. The analysis includes program enrollment as a percentage of each county’s total population and the split between fee-for-service (FFS) and managed care organization (MCO). Just over 27% of Michigan’s total population is enrolled in Medicaid and 22% is enrolled in Medicare.

Roughly two-thirds of Michigan’s 2.66 million Medicaid beneficiaries are enrolled in one of nine managed care plans.

Total Medicare enrollment is 2.25 million, with 62% of beneficiaries enrolled in a Medicaid Advantage (MA) plan and only three counties having less than 50% of total Medicare enrollment in MA plans. MA enrollment by county ranges from 45% to 77%, with 66 counties having 55% or more of their Medicare population enrolled in an MA plan, as highlighted below.

December enrollment is spread across 54 MA plans, with up to 29 plans covering beneficiaries in several Michigan counties and a minimum of 5 plans available in each county.

Members with enrollment questions should contact the MHA Health Finance team.

2025 Medicare Fee-for-Service Home Health Final Rule Released

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule for the home health (HH) prospective payment system (PPS) for calendar year (CY) 2025. The rule includes updates to the Medicare fee-for-service (FFS) HH PPS payment rates based on changes by the CMS and those previously adopted by the U.S. Congress.

Highlights of the final rule, which takes effect Jan. 1, 2025, include:

  • A negative 2% adjustment to base payment rates to achieve budget neutrality following the transition to the Patient-driven Groupings Model (PDGM).
  • A 30-day standard payment rate of $2,057.35, up 0.9% from the current $2,038.13, for HHs that submit the required quality data.
  • Updating core-based statistical areas for wage index purposes, consistent with recent fiscal year 2025 final rules.
  • Recalibrating the PDGM case-mix weights, low utilization payment adjustment thresholds, functional levels and comorbidity adjustment subgroups.
  • Revising the fixed dollar loss ratio from 0.27 to 0.35, reducing outlier payments.
  • Requiring HH agencies to report four new patient assessment items in the HH agency Outcome and Assessment Information Set under the social determinants of health category beginning with CY 2027.
  • Adding a new standard within the Medicare Conditions of Participation requiring HH agencies to develop, implement and maintain a patient acceptance to service policy that is applied consistently to each prospective patient referred for HH care.
  • Requiring long-term care facilities to electronically report information about COVID-19, influenza and respiratory syncytial virus in a standardized format weekly through National Healthcare Safety Network beginning Jan. 1, 2025. The CMS notes that the Secretary will have the discretion to revise the reporting frequency based on changing needs for data collection.

The MHA will provide an updated impact analysis in the near future. Members with questions should contact Vickie Kunz at the MHA.

MHA CEO Report — Site-Neutral Payment Policies: The Latest Threat to Patient Access

MHA Rounds graphic of Brian Peters

The worst form of inequality is to try to make unequal things equal.” Aristotle

MHA Rounds graphic of Brian PetersOperating a hospital has never been more challenging than it is today. At the most fundamental level, hospitals are small towns that operate 24/7, year-round, built around expert clinicians, as well as a wide variety of highly skilled employees in multiple disciplines. Collectively, they are tasked with the awesome responsibility of delivering a broad spectrum of high-quality healthcare services to everyone in their respective communities, regardless of their health or socio-economic status.

Our MHA Chief Medical Officer, Gary Roth, DO, often says “healthcare is everyone’s destiny.” He’s right: at some point, all of us – or our loved ones – will require the assistance of our healthcare system. And when that day comes, we as patients can and should expect that we have ready access to care. Michigan hospitals take that expectation very seriously, whether that comes in the form of physician recruitment, retention and call coverage, drug acquisition, facilities maintenance and expansion, or ensuring that the latest diagnostic and treatment technology is on-site.

Here is an economic reality: being prepared to care for anyone, for any diagnosis, at any time, creates high fixed costs. In classic business terminology, hospitals are “price takers” when it comes to government payers, because Medicaid and Medicare effectively tell hospitals what they will receive in reimbursement.

Against this backdrop, our field is currently facing a strong push at the federal level to prevent hospitals from receiving Medicare reimbursement at a level that appropriately recognizes the higher fixed and operational costs referenced above. Referred to as “site-neutral payments,” this policy would force hospitals to accept the same rates as those paid at other sites of care. This ignores the fact that the cost structures between the two settings are very different because hospitals go to great lengths to have the infrastructure in place to save lives every day. Non-hospital settings serve a very valuable but different role, and the reimbursement they receive today reflects those differences. In addition to being open 24/7/365 to all patients – including those with multiple comorbidities, and little or no health insurance coverage, hospitals must have redundant systems for energy and water so surgeries and other patient care can continue uninterrupted when the power goes out or other systems are compromised. Physician offices have no such requirements and don’t bear these costs.

Hospital outpatient departments also provide convenient access to care for the most vulnerable and medically complex patients. These settings are more likely to treat Medicare patients who have more chronic and severe conditions, have been recently hospitalized or in an emergency department and are dually eligible for Medicare and Medicaid. These patients are more expensive to care for and rely on hospital outpatient departments for their increased healthcare needs.

Implementing site-neutral payment policies would be detrimental to access to care for patients across Michigan and the country. If reimbursement is slashed across the board, hospitals will be forced to reduce their costs, which will come in the form of reduced hospital beds, service lines or even potentially hospital closures. This plan for inadequate payment can be particularly harmful for hospitals serving a high percentage of vulnerable patients, including rural hospitals. When a hospital closes services due to site-neutral payment policy, they will close to everyone, not just people covered under Medicare.

I was recently honored to be appointed to the American Hospital Association Board of Trustees and this issue is clearly a key focus of their advocacy work on Capitol Hill. The MHA is joining that effort by advocating with Michigan’s members of Congress, and our message is unambiguous: comparing hospitals with other sites of care is not comparing apples and oranges – it’s comparing apples and space shuttles. More importantly, reducing healthcare costs can’t come at the expense of reduced access to care.

As always, I welcome your thoughts.

MHA Monday Report Aug. 19, 2024

MHA Submits Comments on Speech-Language Pathologist Proposed Policy

The MHA recently provided comments to the Michigan Department of Health and Human Services (MDHHS) regarding a proposed policy change for Medicaid enrollment of speech-language pathologists. The MHA supports MDHHS’s efforts to align Michigan licensure …


Registration Open for Safe Table on Just Culture

The MHA Keystone Center Patient Safety Organization is hosting a Just Culture Safe Table from noon to 4 p.m., Thursday, Sept. 19 at the MHA headquarters in Okemos, MI. The peer-led discussion about Just …


Special Pathogen Preparedness and the Revised Infection Control Joint Commission Standards Webinar

The National Emerging Special Pathogens Training & Education Center, in collaboration with the Association for Professionals in Infection Control and Epidemiology, are hosting the webinar Special Pathogen Preparedness and the Revised Infection Control Joint Commission Standards …


Kelley Cawthorne Ad


New CMS Requirements for Reporting of Hospital Respiratory Data

The MHA recently submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) on the proposed updates to the Medicare Inpatient Prospective Payment System for fiscal year 2025. Updates to the hospital and …


MHA Provides Comment on Proposed Medicaid Reimbursement for Group Prenatal Care

The MHA submitted a comment letter to the Michigan Department of Health and Human Services regarding the proposed Medicaid coverage of group prenatal care, set to begin in October 2024. The MHA expressed support for …


The Keckley Report

Healthcare’s Three Big Tents have Much in Common

“Arguably, three trade groups have emerged at the center of healthcare system transformation efforts in the U.S.: the American Hospital Association (AHA), America’s Health Insurance Plans (AHIP) and the Pharmaceutical Research and Manufacturers of America (PhRMA). Others weigh in—the American Medical Association, AdvaMed, the American Public Health Association and others—but this trio is widely regarded as the Big Tents under which policy changes are pursued. …

The Boards of the Big Tent trio weigh in, but senior staff in each of the Big Tents drive the organization’s strategy. They’re experienced in advocacy, well-paid and often heavy-handed in dealing with critics.

Operationally, the 3 Big Tents have much in common. Strategically, they’re far apart and the gap appears to be widening. Each blames the other for medical inflation and unnecessary cost. Each alleges the others use unfair business practices to gain market advantages. And each thinks their vision for the future of the U.S. health system is accurate, complete and in the best interest of the public good.

And none of the three has put-forth a vision for the long-term future of the U.S. health system.  Protecting the immediate interests of their members against unwelcome regulatory changes is their focus.”

Paul Keckley, Aug. 12, 2024


News to Know

The MHA Keystone Center is partnering with the Community Foundation of Southeast Michigan to host a two-part, virtual series about peer recovery services for substance and opioid use disorders from 10 a.m. to 12 p.m. on Sept. 17 and Sept. 23.


MHA CEO Brian Peters

MHA in the News

U.S. Representative Elissa Slotkin (D-MI) issued a press release Aug. 8 highlighting her introduction of the American Made Pharmaceuticals Acts that included a quote of support from MHA CEO Brian Peters. The bipartisan bill, introduced with U.S. Rep. Don …

MHA Monday Report Aug. 12, 2024

MHA Shares State Impacts and Insights at Regional 340B Roundtable

MHA staff attended the Regional 340B Roundtable Aug. 7 in Florence, IN to join colleagues from the Indiana Hospital Association, Ohio Hospital Association, Kentucky Hospital Association and endorsed business partner, SunRx, to share best practices …


MHA Keystone Center Offers Learning Collaboratives for Peer Recovery Services

The MHA Keystone Center is partnering with the Community Foundation of Southeast Michigan to host a two-part, virtual series about peer recovery services for substance and opioid use disorders from 10 a.m. to 12 p.m. …


CMS Releases FY 2025 Final Rule for Skilled Nursing Facilities

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service prospective payment system for skilled nursing facilities for federal fiscal year (FY) 2025. Key provisions …


Kelley Cawthorne Ad


MHA Webinar Tying Person and Family Engagement to Culture Performance Deadline Approaching

One week remains before the registration deadline for the MHA webinar Tying Person and Family Engagement to Culture and Performance. Scheduled from noon to 1 p.m. Aug. 20, the webinar provides an opportunity for hospitals to …


CMS Releases FY 2025 LTCH Prospective Payment System Final Rule

The Centers for Medicare & Medicaid Services (C recently released a final rule to update the Medicare fee-for-service long-term care hospital (LTCH) prospective payment system for fiscal year 2025. Specifically, the final rule: Increases …


CMS Releases FY 2025 Hospital Inpatient Prospective Payment System Final Rule

The Centers for Medicare & Medicaid Services recently released a final rule to update the Medicare fee-for-service hospital inpatient prospective payment system for fiscal year (FY) 2025. Highlights of the final rule include: …


The Keckley Report

Big Sky is Cloudy for Hospitals

“As state hospital association leaders assemble in Big Sky, Montana this week, the environment for hospital-friendly legislation is threatening at best:

The public’s trust in hospitals has eroded. Hospital financial performance is a mixed bag: some are profitable and many aren’t. Congress thinks hospitals need more regulation to increase price transparency, require ownership disclosure, verify community benefits that justify tax exemptions and impose restrictions on hospital private equity investments. And programs through which state and federal health policies are authorized—HHS, CMS, FTC, FDA, CMMI et al—are in limbo as a result of the June 28, 2024 Chevron ruling by the Supreme Court. …

For hospitals, effective advocacy is imperative: the reservoir of good will enjoyed for decades is evaporating. Advertising “we’re there for you” is timely as rural providers need a lifeline, and public castigation of “corporate insurers and billionaire critics” necessary to rally supporters. But beyond these, two things are clear:

  • The marketplace for “hospitals” is fundamentally different than the past requiring a clearer value proposition and fresh messaging.
  • And in states, hospitals will encounter unique opportunities and challenges in plotting strategies for their future. No two are alike.

Big Sky is a symbolic locale for this week’s meeting of state health executives: the Big Sky over hospitals is cloudy.”

Paul Keckley, Aug. 5, 2024