The MHA recently submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the proposed rule to update the Medicare fee-for-service (FFS) inpatient rehabilitation facility (IRF) prospective payment system (PPS) for fiscal year (FY) 2024. These comments were due to the CMS June 2.
The CMS is expected to release final rules to update the IRF, IPF and SNF PPS around Aug. 1, for the Oct. 1, 2023, effective date. The MHA will provide members with an updated Medicare FFS impact analysis following release of the final rules.
Members with questions should contact Vickie Kunz at the MHA.
The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service prospective payment system (PPS) for inpatient rehabilitation facilities (IRF) for federal fiscal year (FY) 2024. Key provisions of the proposal include:
Rebasing the IRF market basket using data from cost reports beginning in FY 2021, instead of FY 2016 data.
Increasing the IRF PPS payment rate by 3.3% from $17,878 to $18,471 for IRFs that comply with the CMS IRF Quality Reporting Program (QRP) requirements. IRFs that fail to comply are subject to a two percentage point reduction.
Increasing the labor-related share from the current 72.9% to 74.1%.
Using the FY 2024 pre-floor, pre-reclassification inpatient PPS hospital wage index, with a 5% cap on any decrease to a provider’s wage index from its prior year wage index.
Decreasing the cost outlier threshold by nearly 23% from the current $12,526 to $9,690, to achieve the 3% target for outlier payments as compared to aggregate IRF payments, which will increase the number of cases that qualify for outlier payments.
Updating the IRF QRP by:
Modifying the COVID-19 Vaccination Coverage among Healthcare Personnel measure.
Adopting one new measure: The Discharge Function Score measure.
Removal of three existing measures:
The Application of Percent of Long-Term Care Hospital Patients with an Admission and Discharge Functional Assessment and a Care Plan That Addresses Function measure (NQF #2631).
The IRF Functional Outcome Measure: Change in Self-Care Score for Medical Rehabilitation Patients measure (NQF #2633.
The IRF Functional Outcome Measure: Change in Mobility Score for Medical Rehabilitation Patients measure (NQF #2634).
Modifying the excluded unit regulation to allow a hospital to open a new IRF unit and begin being paid under the IRF PPS at any time during the cost reporting period if the hospital meets certain requirements rather than the current limit that only allows for payment under the IRF PPS at the beginning of a cost reporting period.
The MHA will provide IRFs with a facility-specific impact analysis and additional details on the proposed rule in the near future. The MHA also encourages members with IRF operations to review the proposed rule, provide comments toVickie Kunz at the MHAby May 25 and submit comments to the CMS by June 2. The CMS is expected to release a final rule around Aug. 1, for an Oct. 1, 2023, effective date.
Members with questions should contact Vickie Kunz at the MHA.
The MHA Board of Trustees began their Nov. 2 meeting with a review of key communication strategies to assist hospitals and health systems to “tell their stories” about the unprecedented financial and workforce challenges they currently face and how they are adapting to meet the critical healthcare and economic development needs of their communities …
The MHA encourages its staff, members and other stakeholders in the healthcare community to vote in the state’s general election Nov. 8.- Polls will be open from 7 a.m. to 8 p.m. …
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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 Michigan Department of Health and Human Services (MDHHS) issued MMP 22-38 COVID-19 Response: Termination of Bulletin MSA 20-28, which reinstates provider enrollment requirements …
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 …
The MHA, along with stakeholders across diverse fields, supported record state investment in Michigan’s future workforce. On October 11th, the Governor signed Public Act 212 of 2022 establishing the Michigan Achievement Scholarship, and applications starting with students in the high school class of 2023 will now be eligible for increased state financial aid …
The webinar Dispelling Misinformation About Unionization and Legal Guidelines 8:30 – 10 a.m. ET Nov. 11 has been approved by HR Certification Institute® (HRCI®) for 1.5 hours …
At the MHA, we often say that politics is not a spectator sport. It requires continual engagement and relationship building so that when you are in a crisis and need assistance, you have trusted friends you can turn to …
The Keckley Report
The Three Blind Spots in Hospital Strategic Plans
“For 40 years, I have facilitated Board Retreats for hospitals, health systems, insurance plans and medical groups. At no time has the level of uncertainty about the future for hospitals been as intense nor the importance of a forward-looking strategic vision and planning been as necessary as now. The issues are complicated: lag indicators about demand, clinical innovations, reimbursement, costs et al are a foreboding backdrop for these discussions. And three issues have surfaced as blind spots in the environmental assessments and deliberations preceding the plan …”
Many Michigan hospitals are underway with their Michigan Harvest Gathering campaign which runs through Nov. 18. Online donations by hospital employees and community members to the Michigan Harvest Gathering program can be made through the Food Bank Council of Michigan’s website …
The MHA received media coverage on the surge of RSV cases across Michigan’s pediatric hospitals during the week of Oct. 31. The coverage included several comments provided to news outlets and the distribution of a press release Nov. 4 to statewide media …
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.
Michigan’s primary election was held Tuesday, Aug. 2, finalizing the November general election ballot. The 2022 midterm election is critical to Michigan’s healthcare future given the number of key elected positions up for election …
The Centers for Medicare and Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service (FFS) hospital inpatient prospective payment system (IPPS) for fiscal year (FY) 2023. The rule will: Reduce disproportionate …
The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service prospective payment system for inpatient psychiatric facilities for fiscal year (FY) 2023, which begins …
The Centers for Medicare & Medicaid Services recently released a final rule to update the Medicare fee-for-service prospective payment system for inpatient rehabilitation facilities for fiscal year (FY) 2023, which begins …
The Centers for Medicare and Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service long-term care hospital prospective payment system (PPS) for fiscal year (FY) 2023, which begins Oct. …
In preparation for the state’s anticipated grant program to implement an Emergency Department Medication for Opioid Use Disorder (ED MOUD) program, the MHA is asking all members to fill out …
Medicare Advantage (MA) enrollment in Michigan totaled approximately 1.20 million in July, an increase of 15,000 beneficiaries since April. The July MA enrollment is spread across 47 MA plans that are currently operating in the …
It’s well known within the healthcare industry that issues of employee turnover, lack of applicants and salary compression were exacerbated in 2020 and 2021. Unfortunately, these trends have continued throughout …
The Keckley Report
Solving Healthcare Workforce Shortages Requires Taking Self-care More Seriously
“The Labor Department reported that the U.S. added 528,000 jobs in July including 69,600 in healthcare. The unemployment rate fell to 3.5%, June job openings were down to 10.7 million from 11.3 million in May and government officials announced that the economy has now recouped the 22 million jobs lost in the pandemic.
But the more sobering news is that inflation has negated the workforce’ 5.1% wage gain in the last year and 1 in 5 workers is looking for employment elsewhere for higher pay and better benefits. And it’s even worse in the healthcare delivery workforce—the hospitals, long-term care facilities, clinics and ancillary service providers where 12 million work. During the COVID-19 pandemic, hospital employee turnover increased to 19.5%–five times higher than the general workforce. And today, 45% of physicians report burnout—double the rate pre-pandemic.”
Members are reminded to review their preliminary wage and occupational mix data released May 23 by the Centers for Medicare and Medicaid Services and submit any requests for changes to their Medicare Administrative Contractor by Sept. 2 since no new requests for changes will be accepted after that date.
The MHA received media coverage on a variety of topics during the weeks of Aug. 1 and Aug. 8. Areas of focus included health insurance tax credits from the American Rescue Plan Act (ARPA), healthcare benefits in the Inflation Reduction Act, growing demand for healthcare careers and more.
The Centers for Medicare and Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service (FFS) long-term care hospital (LTCH) prospective payment system (PPS) for fiscal year (FY) 2023, which begins Oct. 1, 2022. The rule will:
Increase the standard federal rate by a net 3.8% for cases that meet LTCH criteria for services provided by LTCHs in compliance with CMS quality program reporting requirements.
Continue paying cases that fail to meet the required LTCH criteria (diagnosis-related group (DRG), intensive care unit, or ventilator criteria) at the site-neutral rate under the dual-rate payment system implemented in FY 2016.
Establish a high-cost outlier (HCO) threshold of $38,518 for cases paid based on the LTCH standard rate, up 17% from the current $33,015 threshold, resulting in fewer cases qualifying for an outlier payment. The CMS adjusts this threshold annually to maintain outlier payments at the targeted 8% of aggregate LTCH payments. Cases paid at the site neutral rate are subject to the inpatient PPS HCO, finalized at $38,859 for FY 2023.
Set a permanent cap to limit annual wage index decreases at 5%.
Calculate Medicare Severity-Long Term Care-DRG relative weights using an averaging approach, with COVID-19 cases included and excluded and then averaging the two sets of relative weights.
Set a permanent cap on annual decreases at 10% for MS-LTC-DRG relative weights to mitigate negative impacts of significant weight decreases.
The MHA is continuing to review the final rule and will provide hospitals with an updated impact analysis in the near future. Members with questions should contact Vickie Kunz at the MHA.
Healthcare Community Urged to Vote in Nov. 8 General Election
MHA CEO Report — Your Vote Matters 
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