Tag: Vickie Kunz

CMS Releases Final to Update Medicare PPS Effective 2023

Member News

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

Member News

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

Monday Report
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.

MDHHS Releases Medicaid Rate Increase Policies

Member News

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. These include:

  • 2235-Practitioner proposes to update rates for physician neonatal and pediatric critical and intensive care services for certain current procedural terminology (CPT) codes from 95% to 100% of Medicare rates. Members are encouraged to review the proposed policy and submit comments to the MDHHS by Nov. 7, 2022.
  • 2234-Practitioner proposes to increase Medicaid rates for primary care services for CPT codes 99421 through 99423 and 99441 through 99443. The MDHHS indicates rates for the applicable CPT codes will increase from roughly 75% of Medicare to 88% of Medicare. These CPT codes include:
    • Established patient office or outpatient evaluation and management (E/M) visits.
    • Initial subsequent, discharge and other nursing facility E/M visits.
    • New and established patient domiciliary, rest home or custodial care E/M services.
    • New and established patient home E/M visits.
    • New and established patient preventive medicine services.
    • Online digital E/M services and E/M services provided via telephone.

Members are encouraged to review the proposed policy and submit comments to the MDHHS by Nov. 9, 2022.

Members with questions should contact Vickie Kunz at the MHA.

CMS Announces 2023 Medicare Premiums and Deductibles

Member News

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.

Revised Doula Services Policy Released by MDHHS

Member News

The Michigan Department of Health and Human Services recently released a second proposed policy to establish coverage for doula services effective Jan. 1, 2023. The MHA supports this proposal and agrees with the MDHHS statement that the policy will improve birth outcomes, address social determinants of health and decrease health and racial disparities for Medicaid beneficiaries. Changes from the previous proposal include:

  • Specifying a per visit payment rate of $75 for prenatal and postnatal visits which must be at least 20 minutes in duration.
  • Allowing prenatal and postnatal services to be provided via telehealth without documenting barriers to in-person services.
  • Covering a maximum of six visits as initially proposed with potential coverage of additional visits through prior authorization.
  • Increasing the payment rate for the labor and delivery visit from $350 to $700.
  • Clarifying that services will be reimbursed through the MDHHS for Medicaid fee-for-service beneficiaries and the Medicaid Health Plans (MHPs) for beneficiaries enrolled in an MHP.
  • Clarifying that Medicaid covers childbirth education and lactation support and counseling separately from doula services.

The initial list of training programs within the proposed policy was compiled during policy development with the assistance of doulas. The MDHHS will continue to review doula training programs, including those created for specific populations such as community-based doula programs, to support cultural and community needs. The MDHHS will also continue to research pathways for legacy certification, or certification of doulas by providing proof of experience in lieu of training, within the confines of state and federal regulations. Opportunities to assist doula providers in navigating the Medicaid program is also being explored.

The MDHHS welcomes feedback will accept comments until Nov. 1. Members with questions should contact Vickie Kunz at the MHA.

MDHHS Releases Proposed Policy for Attending Physician Claims

Member News

The Michigan Department of Health and Human Services (MDHHS) released a proposed policy to update existing policy for the attending provider field on institutional hospital inpatient and outpatient claims. This update is in response to concerns raised by the MHA and hospitals regarding the claim edits implemented Jan. 1, 2022, which resulted in claim denials. The MDHHS proposes to align claim editing policy and update the definition of attending provider to mirror current federal and state laws and regulations as follows:

  • The attending provider is the individual who has the primary responsibility for the treatment and care of the beneficiary.

The following providers can be reported in the attending provider field for hospital inpatient claims based on Michigan professional licensure and scope of practice statute:

  • Certified Nurse Midwives.
  • Dentists.
  • Oral/Maxillofacial Surgeons.
  • Physicians (MD/DO).
  • Podiatrists.

The allowed attending provider type varies in the outpatient setting depending upon the service provided. The provider with the primary responsibility for the treatment and care of the beneficiary in the outpatient setting, including nurse practitioners and physician assistants, should be reported as the Attending Provider.

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

MHA Drafts Comments on 340B Provisions and REH Payment Policies

Member News

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.

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.

CMS Releases FY 2023 Final Rule to Update Long-term Care Hospital PPS

Member News

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.