CMS Releases Final to Update Medicare PPS Effective 2023

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.

MDHHS Releases Proposed Policy on Medicaid Rates for Dental Services

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.

MHA Monday Report Oct. 17, 2022

MHA Monday Report

Legislative Policy Panel Convenes for Program Year

The MHA Legislative Policy Panel convened Oct. 12 to develop recommendations for the MHA Board of Trustees on legislative initiatives impacting Michigan hospitals …

MDHHS Releases Medicaid Rate Increase Policies

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 …

MHA Keystone Center Presents Annual Health Equity Summit

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 …

ED MOUD Funding Available – Applications Due Dec. 16

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 …

Webinar Prepares for The Joint Commission and CMS Health Equity Requirements

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 …

MHA Podcast Explores Program Year Priorities with Michigan Medicine

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 …

MHA Race of the Week – Michigan Supreme Court

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 Keckley Report

Paul KeckleyIs the Honeymoon Over for Medicare Advantage?

“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.”

Paul Keckley, Oct. 10, 2022

Logo for MI Vote Matters, Tuesday Nov. 8News to Know

  • The last day to register online to vote in the Nov. 8 election is Oct. 24, 2022.
  • Early in-person voting by absentee ballot at a clerk’s office remains available.
  • Complimentary MI Vote Matters informational posters and the 2022 Candidate Guide are still available for MHA members.

MHA Monday Report Oct. 10, 2022

MHA Monday Report

DIFS Publishes Bulletin on No-fault Reimbursement Following Andary Decision

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 …

MDHHS Releases Proposed Policy to Resume Required Enrollment Activities

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) …

CMS Announces 2023 Medicare Premiums and Deductibles

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 …

MHA Creates Workforce Sustainability Communications Toolkit

As hospitals and health systems across Michigan continue to face workforce challenges, the MHA has developed a downloadable communications toolkit focused on workforce sustainability …

Michigan Harvest GatheringsMichigan Harvest Gathering Launches Oct. 10

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 …

Opportunities for Immunization Grants – Applications Due Nov. 1

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 …

Webinar Dispels Misinformation About Unionization and Outline Legal Guidelines

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 …

MHA Race of the Week – Michigan Secretary of State

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 …

Paul KeckleyThe Keckley Report

The White House Strategy for Nutrition and Hunger: Three Glaring Oversights

“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.”

Paul Keckley, Oct. 3, 2022

Logo for MI Vote Matters, Tuesday Nov. 8News to Know

  • 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.

Laura AppelMHA in the News

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 …

CMS Announces 2023 Medicare Premiums and Deductibles

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.

MHA CEO Report — Michigan Hospitals: Benefitting Communities in Significant Ways

MHA Rounds Report - Brian Peters, MHA CEO

Life’s most persistent and urgent question is, ‘What are you doing for others?”  Martin Luther King, Jr.

MHA Rounds Report - Brian Peters, MHA CEOFall 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.

As always, I welcome your thoughts.

MHA Monday Report Sept. 12, 2022

MHA Monday Report

Healthcare Remains Michigan’s Largest Private-sector Employer Despite Pandemic Losses

The Partnership for Michigan’s Health reports healthcare directly employed nearly 572,000 Michigan residents in 2020, demonstrating that healthcare continues to be the largest private-sector employer in the state despite staffing losses attributed to the COVID-19 pandemic. The 2022 release …

Lt. Gov. Hosted at Capitol Advocacy Center

MHA Drafts Comments on 340B Provisions and REH Payment Policies

MHA Offering Basics of Case Management Boot Camp

Implicit Bias Trainings Available to Meet LARA Requirement

Webinar Explores Guidelines for Strategic Planning

Virtual Nurse Preceptor Academy Supports New Employee Training and Retention

MHA CEO Report – Time to Focus on Cybersecurity

AHA Trustee Insights Outlines Financial Turnaround and Succession Planning

Paul KeckleyThe Keckley Report

In Campaign 2022, Healthcare Voters Will Matter More

“Today begins the countdown to election day November 8: in 63 days, voters will elect 36 Governors, 30 State Attorneys General, 27 Secretaries of State, 35 US Senators, 435 US House of Representatives and State Legislators in 46 states. It’s a consequential election for the country and for its healthcare industry…

Campaigns will avoid healthcare issues other than abortion. Conceding that healthcare is expensive and access uneven, most midterm campaigns will default to partisan themes…”

Paul Keckley, Sept. 6, 2022

News to Know

  • The deadline to provide contact information in preparation for the state’s anticipated grant program to implement an Emergency Department Medication for Opioid Use Disorder program has been extended to Sept. 23.

MHA in the News

MHA CEO Brian Peters

MHA Drafts Comments on 340B Provisions and REH Payment Policies

The MHA has drafted comments in response to the Centers for Medicare and Medicaid Services (CMS) proposed rule to update the Medicare fee-for-service (FFS) outpatient prospective payment system (OPPS) for calendar year 2023. The MHA submitted comments regarding the 340B provisions in mid-August urging the CMS to:

  • Restore payment rates for 340B drugs to average sales price (ASP) plus 6%.
  • Hold all hospitals harmless for 2018-2022 claims.
  • Find new funds to restore 340B payments to ASP plus 6% with no reduction to the outpatient conversion factor.

The MHA also prepared comments in response to the proposed payment policies for rural emergency hospitals (REHs), a new hospital designation established by the Consolidated Appropriations Act, for critical access hospitals and rural prospective payment system hospitals with fewer than 50 beds.

The MHA recently posted hospital-specific estimated impact reports of the OPPS proposed rule on the hospital association reporting portal (HARP) for members to access and encourages hospitals to review the impact of the proposed rule on their operations and submit comments to the CMS by 5 p.m. Sept. 13. The CMS is expected to release a final rule to update the OPPS, including finalization of REH payment policies around Nov. 1 for the Jan. 1, 2023 effective date.

The MHA will provide an updated impact analysis following release of the final rule. Members with questions should contact Vickie Kunz at the MHA.

MHA Monday Report Aug. 29, 2022

MHA Monday Report

Behavioral Health Legislation Introduced in State House

capitol building

New legislation to make changes to the screening process for potential admission to inpatient psychiatric care for behavioral and mental health patients was introduced Aug. 17 in the Michigan House of Representatives. Rep. Graham Filler …

Court of Appeals Rules for Providers in ANF Case

CMS Releases FY 2023 Final Rule to Update Skilled Nursing Facilities PPS

CMS Wage Data Revisions Due Sept. 2

Member Feedback Requested on Proposed Telemedicine Policy

Paul KeckleyThe Keckley Report

Game On: FTC Takes on Hospital Consolidation via COPA Dismantling

“The Federal Trade Commission (FTC) issued a scathing 20-page report last Monday criticizing hospital Certificate of Public Advantage (COPA) agreements and urging state lawmakers to suspend their use. …

The FTC has its sights on hospital consolidation: it’s high on the list of industries where its activist’ muscle is likely to be flexed more frequently and effectively. … Like strong bipartisan support for the Hospital Price Transparency Rule, it reflects the FTC’s rejection of hospital claims about inadequate reimbursement by payers including Medicare and Medicaid, price gauging by device, drug and technology suppliers and unfair competition from insurers and niche providers often funded by private investment to optimize profits at the expense of hospitals.

And it offers a solution that’s strong on populist appeal but weak on practical implementation in the current hospital environment: competition vs. consolidation. Regulatory Constraints on hospitals like EMTALA and others are not applied to insurers and retailers who offer a widening range of care management services in direct competition with hospitals. The playing field is increasingly tilted against hospitals.

Paul Keckley, August 22, 2022

News to Know

MHA in the News

MHA CEO Brian Peters

Member Feedback Requested on Proposed Telemedicine Policy

The Michigan Department of Health and Human Services (MDHHS) recently released a proposed policy to update Medicaid coverage of telemedicine services after the conclusion of the federal COVID-19 public health emergency (PHE). The policy outlines several updates, including:

  • Making permanent policies established during the PHE through bulletins MSA 20-09 (General Telemedicine Policy Changes) and MSA 21-24 (Asynchronous telemedicine services). MSA 20-09 requires either direct or indirect patient consent for all telemedicine services and defines originating and distant sites. MSA 21-24 clarifies Medicaid coverage for asynchronous telemedicine services, including store and forward services, remote patient monitoring and interprofessional consultations.
  • Not requiring prior authorization unless the equivalent in-person service requires prior authorization. Authorization requirements for Medicaid health plans may vary.
  • Establishing payment rates for allowable telemedicine services at the same level as in-person services. To effectuate this policy, the provider must report the place of service as they would if they were providing the service in-person, along with modifier 95 – Synchronous Telemedicine Service. *MDHHS varies from Medicare telehealth billing by not using place of service 02 or 10 but aligns in the use of modifier 95.
  • Allowing audio-only telemedicine services only for select situations where the beneficiary does not have access to audio/visual capabilities. These codes are currently represented as CPT codes 99441-99443 and 98966-98968.

Members are encouraged to submit comments to the MDHHS by Sept. 20. Questions should be directed to Renée Smiddy at the MHA.