CMS Releases FY 25 Hospital IPPS Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service (FFS) hospital inpatient prospective payment system (IPPS) for fiscal year (FY) 2025.

The rule proposes to:

  • Increase the standard operating rate by a net 2.6%, after budget neutrality adjustments, from $6,497.77 to $6,666.10, for hospitals that successfully comply with the CMS quality reporting program and electronic health record requirements. Hospitals that do not meet requirements for these programs are subject to a lower annual update.
  • Increase the federal capital rate by 2.5%, from $503.83 to $516.41.
  • Increase the cost outlier threshold by 15%, from $42,750, to $49,237, to maintain the target of paying 5.1% of aggregate IPPS payments as outlier. This will result in fewer cases qualifying for an outlier payment.
  • Update core based statistical areas as a result of the new Office of Management and Budget labor market delineations based on the 2020 Decennial Census.
  • Implement a separate IPPS payment for small, independent hospitals, defined as those with 100 or fewer beds that are not part of a chain organization, to voluntarily establish and maintain a six-month buffer stock of one or more of 86 essential medicines.
  • Create 10 new Medicare Severity Diagnosis Related Groups (MS-DRGs) and delete three MS-DRGs, most of which are within Major Diagnostic Category 08 (Diseases of the Musculoskeletal System and Connective Tissue) and specific to interbody spinal fusion devices.
  • Establish a new mandatory CMS Innovation Center model that would provide bundled payment for certain surgical procedures.
  • Use FY 2019, 2020 and 2021 Worksheet S-10 uncompensated care cost (UCC) data for the UCC pool allocation, which comprises 75% of Medicare disproportionate share hospital payments.
  • Add seven new measures, primarily focused on patient safety-related practices and outcomes, to the inpatient quality reporting program. Also remove five measures and modify two existing measures, including the Hospital Consumer Assessment for Healthcare Providers and Systems survey measure.
  • Increase the number of mandatory electronic clinical quality measures that hospitals must report for both the IQR and the Promoting Interoperability programs.
  • Require weekly reporting by hospitals, including critical access hospitals, of acute respiratory illness data beginning Oct. 1, 2024, on confirmed infection of COVID-19, influenza and respiratory syntactical virus among hospitalized patients, hospital capacity and limited patient demographic information, including age.
  • Change severity level designation for Z codes describing inadequate housing and housing instability from non-complication or comorbidity to complication or comorbidity for FY 2025.
  • Solicit input through requests for Information on:
    • Hospital resource usage for providing inpatient pregnancy and childbirth services to Medicare patients compared to non-Medicare patients.
    • Requirements and structure should be for a possible future obstetrical services conditions of participation.

The MHA continues its review of the proposed rule and will provide hospitals with an estimated impact analysis in the next few weeks. The MHA encourages hospitals to review the rule and submit comments to the CMS by June 10 and to notify the MHA regarding issues identified by May 24.

Members with questions should contact Vickie Kunz at the MHA.

CMS Releases FY 2025 Proposed Rule for Inpatient Psychiatric Facilities

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service (FFS) prospective payment system (PPS) for inpatient psychiatric facilities (IPFs) for federal fiscal year (FY) 2025.

Key provisions of the proposed rule include:

  • Increasing the Electroconvulsive Therapy (ECT) payment per treatment by 71% from $385.58 to $660.30 for IPFs that comply with IPF quality reporting program (QRP) requirements and $647.45 for IPFs that fail to report data.
  • Decreasing the IPF PPS federal per diem base rate by a net 2.3% after all adjustments, from $895.63 to $874.93. IPFs that fail to comply with the CMS IPF Quality Reporting Program (QRP) requirements would be paid using a base rate of $857.89.
  • Updating the wage index using the most recent Office of Management and Budget (OMB) statistical area delineations based on the 2020 Decennial Census.
  • Increasing the labor-related share from the current 78.7% to 78.8%.
  • Increasing the cost outlier threshold by 6% from the current $33,470, to $35,590 to achieve the 2% target for outlier payments as compared to aggregate IPF payments, decreasing the number of cases that qualify for outlier payments.
  • Maintaining the existing facility-level adjustment factors for rural location, teaching status and emergency department.
  • Changes to the IPFQR Program:
    • Adopting the 30-Day Risk-Standardized All-Cause Emergency Department (ED) Visit Following an IPF Discharge measure beginning with the FY 2027 payment determination.
    • Modifying reporting requirements to require IPFs to submit patient-level data on a quarterly basis.
  • Requesting comments on future revisions to the IPF PPS facility-level adjustment factors and development of the new standardized IPF Patient Assessment Instrument (IPF-PAI), required by the Consolidated Appropriations Act, 2023, for rate year 2028.

The MHA will provide IPFs with a facility-specific impact analysis and additional details on the proposed rule in the near future. The MHA also encourages members to submit comments to the CMS by May 28 and to contact the MHA with issues identified by May 21.

Members with questions should contact Vickie Kunz at the MHA.

CMS Releases FY 2025 Proposed Rule for Skilled Nursing Facilities

The Centers for Medicare & Medicaid Services (CMS) released a proposed rule April 3 to update the Medicare fee-for-service (FFS) prospective payment system (PPS) for skilled nursing facilities (SNFs) for federal fiscal year (FY) 2025.

Key provisions of the proposed rule include:

  • Increasing the per diem federal rate by a net 4.1% after the market basket update, productivity adjustment and other adjustments.
  • Updating the base year data used to determine the SNF market basket from 2018 to 2022.
  • Updating the wage index used under the SNF PPS to reflect data from the 2020 decennial census.
  • Increasing the labor-related share of the per diem rate from 71.1% to 71.9%.
  • Making technical revisions to the code mappings used to classify patients under the Patient Driven Payment Model (PDPM) that assigns patients to clinical categories.
  • Revising the CMS nursing home enforcement authority to allow the agency to impose multiple financial penalties on facilities with safety deficiencies.
  • Adopting four new patient assessment items related to health-related social needs with SNFs required to collect and report specific data elements related to living situation, food and utilities beginning with the FY 2027 SNF quality reporting program (QRP).
  • Modifying the patient assessment item on transportation to simplify the response options and revise the look-back period.
  • Adopting a data validation process for the SNF QRP beginning with the FY 2027 program.
  • Proposing operational updates to the SNF Value-Based Purchasing program, including policies regarding measure removal and review and corrections.
  • Updating the case mix methodology used to calculate the Total Nurse Staffing measure.
  • A Request for Information (RFI) on potential updates to the Non-Therapy Ancillary component of the PDPM.

The MHA will provide SNFs with a facility-specific impact analysis and additional details on the proposed rule in the near future. The MHA also encourages members to submit comments to the CMS by May 28 and to contact the MHA with issues identified by May 22.

Members with questions should contact Vickie Kunz at the MHA.

CMS Releases Inpatient Rehabilitation Facilities FY 2025 Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) released a proposed rule March 29 to update the Medicare fee-for-service prospective payment system (PPS) for inpatient rehabilitation facilities (IRFs) for federal fiscal year (FY) 2025.

Key provisions of the proposed rule include:

  • Increasing the IRF PPS payment rate by a net 1.8% after all adjustments, from $18,541 to $18,872. IRFs that fail to comply with the CMS IRF Quality Reporting Program (QRP) requirements are subject to a two-percentage point reduction.
  • Updating the wage index using the most recent Office of Management and Budget statistical area delineations based on the 2020 Decennial Census.
  • Increasing the labor-related share from the current 74.1% to 74.2%.
  • Increasing the cost outlier threshold by 17% from the current $10,423, to $12,158 to achieve the 3% target for outlier payments as compared to aggregate IRF payments, decreasing the number of cases that qualify for outlier payments.
  • Updating the case mix group relative weights and average length of stay values using FY 2023 IRF claims and FY 2022 IRF cost report data.
  • Requiring IRFs to report four new items using the IRF-Patient Assessment Instrument (PAI) as standardized patient assessment data elements under the social determinants of health category beginning with the FY 2028 IRF quality reporting program (QRP) including:
    • One item for Living Situation.
    • Two items for Food.
    • One item for Utilities
  • Modifying the Transportation item collected in the IRF-PAI.
  • Requesting information on quality measure concepts for the IRF QRP in future years and an IRF star rating system.

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 to submit comments to the CMS by May 28 and to contact the MHA with issues identified by May 21. Members with questions should contact Vickie Kunz at the MHA.

MHA Monday Report Feb. 12, 2024

MHA Monday Report

capitol buildingExecutive Budget Supports Healthcare, Other Legislative Action

Governor Whitmer and Budget Director Jen Flood released the executive budget recommendation Feb. 7 for fiscal year 2025. The MHA is pleased to see that the Governor’s budget continues vital funding for Medicaid, rural and …


MDHHS Director Hertel Presents at MHA Board Meeting

Michigan Department of Health and Human Services (MDHHS) Director Elizabeth Hertel presented an overview of her department’s key priorities to the MHA Board of Trustees at their Feb. 7 meeting. Hertel shared ongoing efforts to …


MHA Behavioral Health Learning Series Begins Feb. 14

The MHA is hosting a five-part webinar series to provide hospital staff with a deeper understanding of Michigan’s behavioral health system and the hospital’s role in connecting patients with care. These webinars are part of …


Healthcare Remains Key Piece of Executive Budget Recommendation

The following statement can be attributed to Brian Peters, CEO of the Michigan Health & Hospital Association. Healthcare access is vital for the physical and economic health of our local economies. This budget proposal presented …


Virtual Training Offered Feb. 22 for FY 2021 Medicaid DSH Audit

Myers and Stauffer LC, Michigan’s contractor for the federally mandated Medicaid disproportionate share hospitals (DSH) audits, encourages hospital staff to participate in the upcoming virtual training Feb. 22 at 10 a.m. Hospital staff are encouraged …


MHA CEO Report — The State of Healthcare

The new year always brings two traditional speeches from lawmakers: Gov. Whitmer just recently delivered her annual State of the State address, while President Biden will share the annual State of the Union address on March 7. While the economy …


The Keckley Report

Is the Tax Exemption for Not-for-Profit Hospitals at Risk?

“Last Thursday, Seattle-based Providence Health System announced it is refunding nearly $21 million in medical bills paid by low-income residents of Washington and erasing $137 million more in outstanding debt for others. Other systems are likely to follow as pressure con mounts on large, not-for-profit systems to modify their business practices in sensitive areas like patient debt collection, price transparency, executive compensation, investment activities and others.

I believe not-for-profit hospital systems are engines for modernizing health delivery in communities and a lightening rod for critics who think their efforts more self-serving than for the public good. Most consumers (55%) think they earn their tax exemption but 34% have mixed feelings and 10% disagree. (Keckley Poll November 20, 2023). That’s less than a convincing defense.”

Paul Keckley, Feb. 5, 2024


 

News to Know

The Michigan Society of Healthcare Risk Management is now accepting nominations for the Paul Venzke Award for Outstanding Performance in the field of Healthcare Risk Management.

Virtual Training Offered Feb. 22 for FY 2021 Medicaid DSH Audit

Myers and Stauffer LC, Michigan’s contractor for the federally mandated Medicaid disproportionate share hospitals (DSH) audits, encourages hospital staff to participate in the upcoming virtual training Feb. 22 at 10 a.m. Hospital staff are encouraged to watch a pre-recorded general DSH training prior to the webinar. The pre-recorded training covers general DSH survey instructions and updates, while the Feb. 22 training will focus on Michigan-specific requirements, followed by a question-and-answer session.

Myers and Stauffer plans to distribute the initial fiscal year (FY) 2021 data request to hospitals Feb. 12, with hospitals having until March 11 to return the completed survey. All hospitals that received Medicaid DSH payments for FY 2021 are required to participate in the audit.

Members with questions should contact Vickie Kunz at the MHA.

MHA Monday Report Feb. 5, 2024

MHA Monday Report

Registration Open for 2024 Healthcare Leadership Academy

Registration is open for the popular MHA Healthcare Leadership Academy program scheduled for March 13-15 and May 1-2. Delivered in partnership with Executive Core and Grand Valley State University for the past 11 years, two …


MDHHS Issues RFP for Peer Navigator Pilot Project

The Michigan Department for Health and Human Services (MDHHS) issued a Request for Proposal (RFP) to enhance support for pregnant and postpartum individuals facing substance use disorder. The Peer Navigator Pilot Project aims to …


Michigan State Loan Repayment Program Application Period Opens

The Michigan State Loan Repayment Program is now accepting applications through April 30. MSLRP assists employers in attracting and retaining medical, dental and mental healthcare providers in underserved communities by providing loan repayment. Healthcare …


Paxlovid Emergency Use Authorization Ends March 8

The U.S. Food and Drug Administration updated the Paxlovid Emergency Use Authorization, allowing Paxlovid that is currently in U.S. distribution to remain authorized for use through the labeled or extended expiration date, or …


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, …


SAMHSA Issues Final Rule on OUD Treatment

The Substance Abuse and Mental Health Services Administration (SAMHSA) issued a final rule Jan. 31 updating regulations for Opioid Treatment Programs and standards for treatment of opioid use disorder (OUD). These rules make permanent …


The Keckley Report

Paul KeckleyThe Three In-bound Truth Bombs set to Explode in U.S. Healthcare

“Truth bombs are falling in U.S. healthcare. They’re well-documented and financed. They take no prisoners and exact mass casualties.

Most healthcare organizations default to comfortable defenses. That’s not enough. Cyberwarfare, precision-guided drones and dirty bombs require a modernized defense. Lacking that, the system will be a commoditized public utility for most in 15 years.”

Paul Keckley, Jan. 29, 2024


News to Know

  • MHA-member physician residents are encouraged to save the date for GME Capitol Day, scheduled from 8:30 a.m. to 3:30 p.m. Wednesday, May 1, at the MHA Capital Advocacy Center.
  • MHA-member communications professionals are encouraged to save the date for this year’s MHA Communications Retreat, scheduled from 8:30 a.m. to 4 p.m. Tuesday, May 7, at the Henry Center for Executive Development in Lansing.

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.

Outpatient Prospective Payment System Final Rule Includes Behavioral Health Additions

The Centers for Medicare & Medicaid Services (CMS) recently finalized several policies in the 2024 Medicare fee-for-service final rules for the outpatient prospective payment system (OPPS) and physician fee schedule final rule. These provisions, effective Jan. 1, 2024, will expand and improve access to behavioral health services.

Highlights include:

  • Establishing coverage for Intensive Outpatient Program services provided by hospital outpatient departments, community mental health centers and federally qualified health centers (FQHCs) and rural health clinics (RHCs) for beneficiaries who have an acute mental illness and meet certain criteria.
  • Covering services provided by marriage and family therapists and mental health counselors at RHCs and FQHCs.
  • Allowing required certifications for opioid treatment programs to be performed by non-physician practitioners.
  • Establishing three new HCPCS codes in the OPPS final rule for diagnosis, evaluation or treatment of a mental health or substance use disorder performed by hospital clinical staff for patients in their homes.
  • Delaying the in-person service requirements for mental health services provided remotely until Jan. 1, 2025.

Members can review additional information in the detailed summary.

Members with questions on the OPPS rule should contact Vickie Kunz at the MHA. Questions regarding the MHA’s behavioral health strategy should be directed to Lauren LaPine at the MHA.

MDHHS Releases Outpatient Hospital 340B Billing Final Policy

The Michigan Department of Health and Human Services (MDHHS) recently released a final policy to modify hospital outpatient billing requirements for drugs purchased through the 340B drug pricing program. Existing policy requires 340B hospitals to bill 340B drugs at acquisition cost. Effective for dates of service on or after Jan. 1, 2024, hospitals may bill up to usual and customary charges for 340B acquired physician-administered drugs or products when provided in the hospital outpatient setting. This policy also revises the hospital outpatient 340B acquisition cost reporting and discontinues the 340B final settlement adjustment process. The MDHHS expects this change will have no reimbursement impact.

In addition, the policy revises 340B hospital cost reporting requirements. Annually, starting by December 2024, hospitals will be required to report 340B cost data for all Medicaid outpatient fee-for-service claims paid during the prior fiscal year.

Questions regarding this process should forwarded to the MDHHS Drug Rebate Specialist.

Members with questions should contact Vickie Kunz at the MHA.