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 Critical Access Hospital conditions include revisions to the Conditions of Participation for infection prevention and control programs and antibiotic stewardship programs.

Part of the proposed rule aims to extend the current COVID-19 and influenza reporting requirements to include respiratory syncytial virus, with a new mandate for weekly reporting by hospitals. The MHA, with insights from the Association for Professionals in Infection Control & Epidemiology and feedback from member hospitals, expressed strong opposition about this proposal. The primary concern is the potential administrative burden it places on hospital’s infection prevention departments. During the COVID-19 public health emergency (PHE), hospitals faced significant challenges in meeting reporting requirements, often having to divert resources from direct patient care to data collection and reporting.

MHA members also voiced concerns about the utility and transparency of the data collected. Despite the vast amounts of information submitted during the COVID-19 PHE, hospitals have yet to receive actionable insights or reports summarizing the data. Without clear evidence that the data will be used effectively, the added burden of reporting seems unjustified, particularly when hospitals can analyze and use their data at the facility level, as needed.

Despite the MHA’s feedback, the CMS has finalized these new requirements. Members are encouraged to stay informed and prepare for these upcoming changes, effective Oct. 1, 2024.

Members with questions may contact Kelsey Ostergren at the MHA.

MDHHS Release Medicaid Reimbursement Proposed Policy

The Michigan Department of Health and Human Services (MDHHS) recently released a proposed policy to establish additional Medicaid reimbursement for certain medically necessary drugs and therapeutics when provided in the inpatient hospital setting. The policy, pending approval by the Centers for Medicare & Medicaid Services, proposes to establish separate payment for drugs and therapeutics that are carved out of the diagnosis related group (DRG) in addition to providing the inpatient DRG payment. Payment would be made under Medicaid fee-for-service (FFS) for beneficiaries covered under both FFS and managed care plans with no beneficiary copayment.

The MDHHS publishes and maintains a list of applicable drugs and therapeutics. The payment rates for drug and therapeutic reimbursement are outlined in the Michigan Medicaid State Plan with these drugs and therapeutics covered as either professional claims or pharmacy claims as specified in the policy.

The provider must request prior authorization (PA) if the drug or therapeutic is purchased directly through a pharmacy, distributor or wholesaler. PA requests may be submitted either via Direct Data Entry through the Community Health Automated Medicaid Processing System or via fax.

Hospitals are encouraged to review the proposed policy and submit comments to MDHHS by March 5, 2024. Members with questions should contact Vickie Kunz at the MHA.