CMS Releases Updated Guidance During Federal Government Shutdown

The Centers for Medicare & Medicaid Services (CMS) recently instructed all Medicare Administrative Contractors (MACs) to lift the hold and begin processing fee-for-service claims dated Oct. 1 and after. The action follows the hold on services impacted by select expired Medicare legislative payment provisions, including those paid under the Medicare physician fee schedule, ground ambulance transport claims and Federally Qualified Health Center claims.

The updated guidance also instructs MACs to process telehealth claims that the CMS can confirm are for behavioral and mental health services. The CMS directed all MACs to continue holding claims for other telehealth services (non-behavioral/mental health claims) due to the Sept. 30 expiration of telehealth flexibilities put in place during the COVID-19 public health emergency and for the acute Hospital Care at Home Program, which also expired Sept. 30.

CMS also released an updated FAQ document Oct. 15 to provide additional guidance to providers.

Members with questions may contact Vickie Kunz at the MHA.

CMS Shares Updates for Medicare Operations During Federal Shutdown

The Centers for Medicare and Medicaid Services (CMS) recently directed Medicare Administrative Contractors (MACs) to hold Medicare fee-for-service (FFS) claims for ten business days, due to the expiration of several Medicare payment provisions and the Oct. 1 federal government shutdown. This action is to prevent the need to reprocess large volumes of claims if congressional action extends payment provisions such as the low volume adjustment and the Medicare dependent hospital program. The CMS believes the temporary hold will have minimal impact on providers due to the 14-day payment floor. Providers may continue submitting claims, but payment will not be released until the hold is lifted.

The MHA confirmed that this does not impact bi-weekly Medicare FFS periodic interim payments and that Medicare Advantage payments to hospitals should not be impacted.

Several temporary telehealth waivers expired Sept. 30, resulting in statutory limitations that were in place for Medicare telehealth services prior to the COVID-19 Public Health Emergency taking effect Oct. 1 for services other than behavioral and mental health services. These include prohibition of many services provided to beneficiaries in their homes and outside of rural areas and hospice recertifications that require a face-to-face encounter. In some cases, these restrictions can impact requirements for meeting continued eligibility for other Medicare benefits.

The acute hospital-at-home program also expired on Sept. 30. The CMS instructed all hospitals with active waivers to discharge all patients or return them to the “brick and mortar” inpatient hospital setting.

The MHA will continue working with congressional delegation to minimize the impact of the shutdown on providers and will provide additional information as it becomes available.  AHA members can access the latest AHA advisory for additional details.  Members with questions may contact Vickie Kunz at the MHA.

MHA Monday Report Aug. 25, 2025

CMS Releases FY 2026 Final Rule for Skilled Nursing Facilities

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service prospective payment system for skilled nursing facilities for fiscal year (FY) 2026. Key provisions include: Increasing the per-diem federal rate …


MHA Community Benefits Survey for FY 2024 Now Open

The MHA is now accepting submissions for the fiscal year (FY) 2024 Community Benefits Survey. Member hospitals are encouraged to participate, as the survey results are vital to demonstrating the value of hospital community benefit …


Trustee Webinar Outlines the OBBBA Impact

The MHA will host the webinar Understanding the One Big Beautiful Bill Act (OBBBA) and Board Planning for the Impact from 8 to 9 a.m. Sept. 24. The session is designed for trustees and hospital leaders and will highlight considerations …


MHA EBP care.ai Shares Case Study on Virtual Care Expansion

MHA Endorsed Business Partner (EBP) care.ai recently shared an insightful case study on how a 22-bed virtual care pilot with Henry Ford Health is expanding across 13-acute care hospitals, including a chief nursing informatics …


Keckley Report

The Medical Profession at a Crossroad

“When I was a grad student at Ohio State in the ‘70’s, one of the most challenging courses I took was “Primary Research Methods in Analyzing Public Data” –an elective. …

The data show the majority of physicians are unhappy and uncertain about the future of the profession. The data show they’re working harder and doing more with less. The data show they’re concerned about the future of the health system and think it’s heading in the wrong direction. The data show employed physicians are increasingly dissatisfied in their hospital and private equity relationships. The data show that physicians share of the growing health spending pie is shrinking: from 21.1% in 2000, to 20.1% in 2023 and projected to 19.9% in 2025 and 19.5% in 2033. And data show the profession, along with nurses and pharmacists, enjoys the public’s trust to figure things out. …

Might defining a vision for a transformed ‘U.S. System of Health’ be the focus for the medical profession? There’s plenty of data to digest to deliberate objectively. Its willingness and ability to set aside its factionalism for the greater good is the biggest question facing the profession. And the widely-recognized dysfunction of the current U.S. health system presents the urgent opportunity for the profession to step forward. That’s the cross facing the profession.”

Paul Keckley, August 17, 2025


New to KnowNews to Know

The MHA is developing its 2025-2026 events and education calendar, featuring professional development opportunities, networking events and timely, relevant offerings for members.


MHA in the News

The MHA received media coverage during the week of Aug. 18 that continued to focus on the impact the One Big Beautiful Bill Act will have on Medicaid as well as comments related to …

CMS Releases FY 2026 Final Rule for Skilled Nursing Facilities

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service (FFS) prospective payment system (PPS) for skilled nursing facilities (SNFs) for fiscal year (FY) 2026. Key provisions include:

  • Increasing the per-diem federal rate by a net 3.4% after the market basket update, productivity adjustment and other adjustments. SNFs that fail to satisfy Quality Reporting Program requirements will be subject to a 2-percentage point reduction to the market basket update.
  • Updating the labor-related share of the per diem rate from 72% to 71.9%.
  • Making technical changes to the Patient-Driven Payment Model ICD-10 code mapping that assigns patients to clinical categories.
  • Removing four elements recently adopted as standardized patient assessment data elements under the social determinants of health category, including:
    • One item for living situation, two items for food and one item for utilities.
  • Removing the health equity adjustment from the SNF Value-Based Purchasing program scoring methodology beginning for the FY 2027 program year.

The MHA will provide SNFs with an updated facility-specific impact analysis and additional details on the final rule in the coming weeks. Members with questions should contact Vickie Kunz at the MHA.

MHA Monday Report Aug. 18, 2025

CMS Releases FY 2026 LTCH Prospective Payment System Final Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service long-term care hospital (LTCH) prospective payment system for fiscal year (FY) 2026. Specifically, the …


MHA Keystone Center and MI AIM Announce Recipients of Maternal Health Education Grant

The MHA Keystone Center, in collaboration with the Michigan Alliance for Innovation on Maternal Health (MI AIM), recently announced a partnership with UnitedHealthcare to offer $25,000 grants to birthing hospitals in Michigan to purchase equipment …


CMS Releases FY 2026 Final Rule for Inpatient Rehabilitation Facilities

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service prospective payment system for inpatient rehabilitation facilities for fiscal year (FY) 2026. Key provisions include: …


Keckley Report

Health Industry Notoriety is a Two-Edged Sword: Four Considerations as the Mid-Term Elections Near

“Keeping track of all things healthcare is a formidable task.  Last week’s news is no exception: …

These events and actions illustrate the administration’s “flood the zone” strategy and its propensity to dictate news cycles in media coverage. They also reflect the ubiquitous role played by healthcare in our society as an employer and economic engine.

Collectively, they appear to cast the industry in a negative light reinforcing populist’ suspicions about affordability, price transparency, corporatization and cost-containment. And they lend to growing disfavor among lawmakers, employers and critics. …”

Paul Keckley, Aug. 10, 2025


New to KnowNews to Know

  • Registration is open for the 2025 MHA Communications Retreat from 8 a.m. to 4 p.m. on Wednesday, Oct. 1 at the Henry Center for Executive Development in Lansing.
  • In the latest episode of the MiCare Champion Cast, MHA CEO Brian Peters and MHA Board Chair Bill Manns, president and CEO, Bronson Healthcare, explore what’s top of mind in healthcare as the 2025-2026 program year kicks off.

CMS Releases FY 2026 LTCH Prospective Payment System Final Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service (FFS) long-term care hospital (LTCH) prospective payment system (IPPS) for fiscal year (FY) 2026.

Specifically, the rule will:

  • Increase the standard LTCH PPS rate by a net 2.9% after the 0.7% productivity adjustment and budget neutrality adjustments from $49,383 to $50,824 for LTCHs that meet the CMS quality program reporting requirements. LTCHs that fail to meet these requirements are subject to a 2-percentage point reduction to the annual update.
  • Continue paying cases at the site-neutral rate if they fail to meet LTCH criteria.
  • Increase the high-cost outlier (HCO) threshold by 2.5% for standard LTCH cases from the current $77,048 to $78,936 to achieve the target of paying roughly 8% of aggregate LTCH payments as HCO payments.
  • Use the inpatient PPS cost outlier threshold finalized at $43,397 for site-neutral cases.
  • Increase the labor-related share of the rate from 72.8% to 72.9%.
  • Update the LTCH Quality Reporting Program to remove four standardized patient assessment data elements focused on social determinants of health and modifying the COVID-19 vaccine among patients and residents measure to exclude patients who expire.

The MHA continues to review the final rule and will provide LTCHs with an estimated impact analysis in the coming weeks. Members with questions should contact Vickie Kunz at the MHA.

CMS Releases FY 2026 Final Rule for Inpatient Rehabilitation Facilities

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service prospective payment system (PPS) for inpatient rehabilitation facilities (IRFs) for fiscal year (FY) 2026.

Key provisions include:

  • Increasing the IRF PPS payment rate by a net 2.45% after all adjustments, from $18,907 to $19,371. IRFs that fail to comply with the CMS IRF Quality Reporting Program (QRP) requirements are subject to a two-percentage point reduction.
  • Using FY 2024 IRF claims and FY 2023 IRF cost report data to update case mix group weights and average lengths of stay.
  • Maintaining the labor-related share at the current 74.4%.
  • Decreasing the cost outlier threshold by 16.4% from the current $12,043 to $10,062 to achieve the 3% target for outlier payments as compared to aggregate IRF payments, decreasing the number of cases that qualify for outlier payments.
  • Changes to the IRF QRP to:
    • Remove the COVID-19 Vaccination Coverage Among Healthcare Personnel measure beginning with the FY 2026 payment year.
    • Remove the COVID-19 Vaccine: Percent of Patients/Residents Who Are Up to Date measure by making data reporting optional beginning Oct. 1, 2025, and removing it from the IRG patient assessment instrument effective Oct. 1, 2026, the earliest feasible date.
    • Remove four standardized patient assessment data elements related to social drivers of health, including one item on living situation, two items on food security and one item on utilities.

The MHA will provide IRFs with a facility-specific impact analysis and additional details on the final rule in the coming weeks. Members with questions should contact Vickie Kunz at the MHA.

CMS Releases FY 2026 Final Rule for Inpatient Psychiatric Facilities

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service (FFS) prospective payment system (PPS) for inpatient psychiatric facilities (IPFs) for fiscal year (FY) 2026.

Key provisions of the include:

  • Increasing the IPF PPS federal per diem base rate by a net 1.9% after all adjustments, from $876.53 to $892.87 for IPFs that comply with the CMS IPF quality reporting program (QRP) requirements. The rate for providers that failed to report quality data is $875.44.
  • Increasing the Electroconvulsive Therapy payment per treatment by a net 1.9% from $661.52 to $673.85 for IPFs that comply with IPF QRP requirements and $660.70 for IPFs that fail to report data.
  • Revising the labor-related share from the current 78.8% to 79%.
  • Increasing the cost outlier threshold by 3.3% from the current $38,110 to $39,360 to achieve the 2% target for outlier payments as compared to aggregate IPF payments, decreasing the number of cases that qualify for outlier payments.
  • Modifying the facility-level adjustment factors:
    • Rural adjustment from 1.17 to 1.18
    • Teaching adjustment from 0.5150 to 0.7957
  • Maintaining the 1.54 adjustment factor for IPFs with qualifying emergency departments.
  • Updating the IPFQR Program to:
    • Remove four measures beginning with the calendar year 2024 reporting period/FY 2026 payment determination:
      • Facility Commitment to Health Equity
      • COVID-19 Vaccination Coverage among Health Care Personnel
      • Screening for Social Drivers of Health
      • Screen Positive Rate for Social Drivers of Health
    • Modify the reporting period of the 30-day-Risk-Standardized All Cause Emergency Department Visit Following an Inpatient Psychiatric Facility Discharge measure (referred to as the IPF ED Visit measure) from a one year, calendar year to a two-year, fiscal year period.
  • Finalizing changes to the IPFQR program’s extraordinary circumstances exception (ECE) policy to include extensions as a type of relief that the agency may grant in response to an ECE request

The MHA will provide IPFs with an updated hospital-specific impact analysis and additional details on the final rule in the near future. Members with questions should contact Vickie Kunz at the MHA.

CMS Releases FY 2026 Hospital Inpatient Prospective Payment System Final Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a final rule to update the Medicare fee-for-service (FFS) inpatient prospective payment system (IPPS) for fiscal year (FY) 2026.

Highlights of the final rule include:

  • Increasing the standard operating rate by a net 1.9%, after the 0.7% productivity cut and budget neutrality adjustments, from $6,624.39 to $6,752.61, 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 reduced annual update.
  • Increase the federal capital rate by 2.3%, from $512.14 to $524.15.
  • Decrease the cost outlier threshold by 12.6% from $46,217 to $40,397 to maintain the target of paying 5.1% of aggregate IPPS payments as outlier.
  • Rebasing and revising the labor-related share of the standardized operating rate from 67.6% to 66% for hospitals with a wage index greater than 1.0.
  • Increasing disproportionate share hospital and uncompensated care (UCC) payments by approximately $2 billion nationally. UCC payments will be allocated using the average of three most recent years of audited Worksheet S-10 data.
  • Adding five new Medicare Severity Diagnosis Related Groups (MS-DRGs) while deleting six MS-DRGs, with most changes within Major Diagnostic Category 05, Diseases and Disorders of the Circulatory System.
  • Removing four measures from the Hospital Inpatient Quality Reporting Program effective with the 2024 reporting and FY 2026 payment period:
    • COVID-19 vaccination coverage among health care personnel.
    • Hospital commitment to health equity structural measure.
    • Screening for social drivers of health.
    • Screen positive rate for social drivers of health.
  • Modifying the Hybrid hospital-wide readmission and mortality measures and the stroke mortality and elective total hip and knee arthroplasty measures.
  • Updating and codifying the Extraordinary Circumstances Exception (ECE) policy to clarify that the CMS has discretion to grant an extension in response to an ECE request from a hospital.
  • Removing the health equity adjustment from the hospital value-based purchasing program scoring methodology beginning with the FY 2026 program.
  • Modifying the six measures in the Readmissions Reduction Program to include Medicare Advantage (MA) beneficiaries in the patient cohorts and shortening the applicable performance period from three years to two years. For example, FY 2027 HRRP penalties would be based on performance July 1, 2023, through June 30, 2025. The CMS did not finalize its proposal to include MA data in the calculations of aggregate payments for excess readmissions; as a result, aggregate penalties are expected to include 2% instead of 13% under the proposed update.
  • Making a technical update to the National Healthcare Safety Network healthcare associated infection measures baseline.

The MHA continues to review the final rule and will provide hospitals with an updated estimated impact analysis and rule brief in the next few weeks. Members with questions should contact Vickie Kunz at the MHA.

CMS Releases CY 26 PFS Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the physician fee schedule (PFS) for calendar year (CY) 2026.

Highlights of the proposal include:

  • Implementing the one-time 2.5% statutory increase included in the One Big Beautiful Bill Act.
  • Establishing two separate conversion factors: one for qualifying alternative payment model participants (QP) and another for non-qualifying physicians and practitioners.
    • The QP conversion factor would increase by 3.8% to $33.59.
    • The non-QP conversion factor would increase by 3.6% to $33.42.
  • Modifying several telehealth waivers, including:
    • Permanently removing the frequency limitations for subsequent inpatient visits, nursing facility visits and critical care consultations.
    • Permanently adopting a definition of direct supervision to include virtual presence via audio/video real-time communications technology.
      • Does not propose to continue allowing virtual supervision of residents when the service is performed virtually across all teaching settings; this would be allowed only for services provided in non-metropolitan statistical areas.
    • Extending the ability for federally qualified health centers and rural health clinics to bill telehealth services through Dec. 31, 2026.
  • Enhancing integration of behavioral health into primary care by:
    • Clarifying that marriage and family therapists and mental health counselors can bill Medicare directly for Community Health Integration and Principal Illness Navigation Services.
    • Creating add-on codes for Advanced Primary Care Management services that complement previously established Behavioral Health Integration or psychiatric Collaborative Care Model services.
    • Proposing deletion of the HCPCS code that describes social determinants of health risk assessment and altering language to refer to “upstream drivers” of health rather than “social determinants.”
  • Using new methodologies to calculate units of Medicare Part D drugs purchased under the 340B drug pricing program that must be excluded from the calculation of Medicare drug inflation rebates beginning Jan. 1, 2026, as required under the Inflation Reduction Act of 2022. The CMS proposes a claims-based methodology that would determine which Part D drug units are 340B eligible for exclusion. The CMS seeks comments on two methodologies: a prescriber-pharmacy methodology and a beneficiary-pharmacy methodology.
  • Implementing the Ambulatory Specialty Model, a mandatory payment model within selected core-based statistical areas, focused on specialists who frequently treat beneficiaries with congestive heart failure and low back pain, to begin Jan. 1, 2027, and run through Dec. 31, 2031.
  • Establishing a MIPS performance threshold of 75 points for the 2026 performance period through the 2028 performance period, as well as adopting six new MIPS Value Pathways (MVPs) and modifying performance categories under the Quality Payment Program. The new MVPs are proposed for the following:
    • Diagnostic radiology
    • Interventional radiology
    • Neuropsychology
    • Pathology
    • Podiatry
    • Vascular surgery
  • The CMS is seeking input on Executive Order 14192, “Unleashing Prosperity Through Deregulation.”

Hospitals are encouraged to contact Vickie Kunz by Sept. 2 regarding issues identified and submit comments to the CMS by Sept. 12. The MHA will provide an impact analysis in the coming weeks. A final rule is expected early November for the Jan. 1, 2026, effective date. Members with questions should contact Vickie Kunz at the MHA.