Tag: Vickie Kunz

2025 Medicare Fee-for-Service Home Health Proposed Rule Released

Member News

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the home health (HH) prospective payment system (PPS) for calendar year (CY) 2025. The rule includes updates to the Medicare fee-for-service HH PPS payment rates based on changes by the CMS and those previously adopted by Congress.

Highlights of the proposed rule, which takes effect Jan. 1, 2025, include:

  • A negative 4% adjustment to base payment rates to achieve budget neutrality following the transition to the Patient-driven Groupings Model (PDGM).
  • A 30-day standard payment rate of $2,008.12 ,down 1.5% from the current $2,038.13, for HH agencies that submit the required quality data.
  • Updating core-based statistical areas for wage index purposes, consistent with recent fiscal year 2025 proposed rules.
  • Recalibrating the PDGM case-mix weights, low utilization payment adjustment thresholds, functional levels and comorbidity adjustment subgroups.
  • Revising the fixed dollar loss ratio from 0.27 to 0.38, reducing outlier payments.
  • Requiring HH agencies to report four new patient assessment items in the HH agency Outcome and Assessment Information Set under the social determinants of health category, beginning CY 2027.
  • Adding a new standard within the Medicare Conditions of Participation requiring HH agencies to develop, implement and maintain a patient acceptance to service policy that is applied consistently to each prospective patient referred for HH care.
  • Requiring long-term care facilities to report respiratory illness data as part of their infection prevention and control programs. The CMS proposes that facilities would electronically report weekly data on COVID-19, influenza and RSV in a standardized format through the National Healthcare Safety Network.
  • Requesting information on:
    • HH quality reporting program measure concepts under consideration for future years.
    • Future performance measure concepts for the expanded HH value-based purchasing model.
    • Rehabilitative therapists conducting the initial and comprehensive assessment.
    • Plan of care development and scope of services HH patient receive.

Members are encouraged to review the proposed rule and contact Vickie Kunz by Aug. 19 regarding issues. Comments are due to the CMS Aug. 26, 2024, and can be submitted electronically. The MHA will provide an estimated impact analysis in the near future.

Members with questions should contact Vickie Kunz at the MHA.

CMS Releases FY 2025 LTCH PPS Proposed Rule

Member News

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule to update the Medicare fee-for-service (FFS) long-term care hospital (LTCH) prospective payment system (PPS) for fiscal year 2025.

Specifically, the rule proposes:

  • Increasing the standard LTCH PPS rate by a net 2.4% from $48,117 to $49,263 for LTCHs that meet the CMS quality program reporting (QPR) requirements. LTCHs that fail to meet these requirements are subject to a two percentage point reduction to the annual update.
  • Rebasing the market basket from 2017 to 2022 base year.
  • Increasing the high-cost outlier (HCO) threshold by 52% for standard LTCH cases from the current $59,873 to $90,921 to achieve the target of paying roughly 8% of aggregate LTCH payments as HCO payments. This increase will result in a decrease in the number of cases qualifying for an outlier payment.
  • Continuing to pay cases at the site neutral rate if they fail to meet LTCH criteria.
  • Updating the cost outlier threshold for site-neutral cases to the inpatient PPS threshold proposed at $49,237, up from $42,750.
  • Revising core based statistical areas as a result of the new Office of Management and Budget labor market delineations based on the 2020 Decennial Census.
  • Updating the LTCH QRP to require reporting of four new items to the LTCH Continuity Assessment Record and Evaluation (CARE) Data Set, (LCDC) social determinant of health category.
  • Modifying the Transportation assessment item.
  • Seeking responses on two requests for information:
    • Quality measure concepts for future years.
    • Future LTCH Star rating.

The MHA continues to review the proposed rule and will provide LTCHs 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 Vickie Kunz regarding issues identified by May 28.

Members with questions should contact Vickie Kunz at the MHA.

CMS Seeks Comments on Proposed Transforming Episode Accountability Model

Member News

The Centers for Medicare & Medicaid Services (CMS) included a proposal to create a new mandatory alternative payment model, the Transforming Episode Accountability Model (TEAM), in the fiscal year 2025 hospital inpatient prospective payment system (IPPS) proposed rule. 

The CMS proposes to mandate participation of all IPPS hospitals in selected core based statistical areas (CBSAs). The CMS proposes to randomly select 25% of 803 eligible CBSAs.

The CMS proposes to test the mandatory TEAM model for five years, beginning Jan. 1, 2026, and ending Dec. 31, 2030. Hospitals would be required to participate in all five surgical episodes and would be the episode initiators and bear financial risk if the model is finalized as proposed.

The model proposed to include five surgical episode categories for Medicare fee-for-service (FFS) beneficiaries:

 

chart that details the model proposed to include five surgical episode categories for Medicare fee-for-service (FFS) beneficiaries.

An episode would begin with a Medicare FFS beneficiary’s acute care hospital stay or a hospital outpatient procedure visit. The episode would end 30 days after hospital discharge and would include the surgical procedure and inpatient stay, and all related care covered under Medicare Parts A and B within 30 days of discharge. The episode would exclude unrelated services.

The CMS would evaluate hospitals by comparing a participating hospitals’ actual Medicare FFS spending to their target price. The CMS would also evaluate performance on quality measures:

  • Hospital readmission
  • Patient Safety
  • Patient-reported outcomes

The proposed model would not include Medicare Advantage plans, which currently cover 59% of Michigan Medicare beneficiaries. The CMS will accept comments until June 10 and anticipates release of a final rule Fall 2024.

Members with questions should contact Vickie Kunz at the MHA.

CMS Releases FY 25 Hospital IPPS Proposed Rule

Member News

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.