Tag: PHE

Webinar Outlines Considerations for the End of the Public Health Emergency

Member News

The Department of Health and Human Services (DHHS) COVID-19 public health emergency expires May 11, 2023, which may significantly decrease the flexibility providers have become accustomed to.

The MHA will host The End of the COVID-19 Public Health Emergency (PHE) and Preparing for the New Regulatory Environment webinar from 4 to 5 p.m. March 30, 2023, providing practical guidance on unwinding reliance on the COVID-19 public health emergency flexibilities. The webinar will identify the steps hospitals should take to prepare for the end of the federal and state public health emergency, review the status of waivers and extensions of PHE-oriented flexibilities and outline how the Michigan Department of Health & Human Services will work with providers in determining which COVID-19 response policies will end, be modified or remain permanently. Experts from Jones Day and the MHA staff will present and answer questions.

Chief executives, financial, medical and nursing executives, legal counsel, patient account and revenue cycle directors, government relations officers, public relations directors and human resources directors are encouraged to register. The webinar is free of charge and open to MHA member organizations only.

Members with questions should contact Brenda Carr at the MHA.

MDHHS Releases Proposed Policy to Resume Required Enrollment Activities

Member News

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 MDHHS proposes to reinstate the following processes beginning Dec. 1, 2022:

  • Community Health Automated Medicaid Processing System (CHAMPS) enrollment revalidations with MDHHS notifying providers beginning November 2022 of their rescheduled validation date, which will be assigned on a rolling basis starting with providers who have had the longest revalidation pause. Providers may view their rescheduled revalidation date in CHAMPS.
  • Site visits for prospective and current providers which will be performed following all state and federal public health guidelines, such as masking and social distancing.
  • Fingerprint-based criminal background checks associated with providers in the high-risk category.
  • Enrollment application fees for providers who had their fees waived under MSA 20-28. Providers may still request a hardship waiver per the Centers for Medicare and Medicaid Services (CMS) guidelines which will only be granted after the MDHHS receives approval from the CMS.

Members are encouraged to review the proposed policy and submit comments to the MDHHS by Oct. 28. Members with questions should contact Renée Smiddy at the MHA.

Member Feedback Requested on Proposed Telemedicine Policy

Member News

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.

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

Member News

The Centers for Medicare and Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service (FFS) prospective payment system (PPS) for skilled nursing facilities (SNF) for fiscal year (FY) 2023. Key updates include:

  • A negative 2.3% parity adjustment to the Patient Driven Payment Model (PDPM) case mix indices following implementation of the PDPM to maintain budget neutrality with the prior RUG-IV case-mix system. The CMS finalized a 2-year phase-in of the proposed 4.6% negative adjustment despite opposition from the MHA, the American Hospital Association and others.
  • A 5.1% net rate increase after the market basket update and other adjustments, up from the proposed 4% net increase. SNFs that fail to comply with CMS quality reporting program (QRP) requirements are subject to a 2%-point reduction to the federal rate update. Facilities should note that the 5.1% increase will be offset by the negative 2.3% parity adjustment described above.
  • Adopting one new quality measure in the SNF quality reporting program (QRP) beginning in FY 2024: The Influenza Vaccination Coverage among Healthcare Personnel (HCP) (NQF # 0431) measure.
  • Revising the compliance date for certain measures and data reporting that were delayed due to the COVID-19 public health emergency (PHE). Specifically, beginning Oct. 1, 2023, SNFs will be required to collect data on certain standardized patient assessment data elements (SPADEs) and two new quality measures, which are:
    • Transfer of Health Information to the Patient
    • Transfer of Health Information to the Provider
  • Updating the SNF value-based purchasing (VBP) program including continued suppression of the SNF 30-day all-cause readmission measure for the FY 2023 SNF VBP program year for scoring and payment adjustment purposes.
  • Adding new measures to the SNF VBP program starting with the “Skilled Nursing Facility Healthcare Associated Infections Requiring Hospitalizations and “Total Hours per Resident Day Staffing” measures in FY 2026 and the “Discharge to Community” measure in FY 2027.
  • Establishing a permanent policy to limit annual wage index decreases to 5%.
  • Implementing a slight increase in the labor-related share of the federal rate from the current 70.4% to 70.8% which will result in a slight payment increase for SNFs with a wage index greater than 1.0.

The MHA will provide members with an updated impact analysis and additional detail on the final rule in the near future. Members with questions should contact Vickie Kunz at the MHA.