HHS Webinar Thursday

The Department of Health and Human Services will hold a webinar on Thursday, October 22 at 1:00 (eastern) about the Centers for Medicare & Medicaid Services’ recent guidance explaining how it will implement an interim final rule that makes the collection and reporting of COVID-19 data a condition of participation in Medicare for hospitals.

On August 24 CMS published an interim final rule establishing new requirements in the hospital conditions of participation in Medicare and on October 6 HHS published the updated document “COVID-19 Guidance for Hospital Reporting and FAQs For Hospitals, Hospital Laboratory, and Acute Care Facility Reporting.”  Among the data elements hospitals are required to report are their current count of lab-confirmed COVID-19 patients, number of staffed beds, number of occupied ICU beds, and information about personal protective equipment and ventilators.

The purpose of the webinar is to explain to providers how HHS will implement these requirements.

Go here to register for the webinar.

MedPAC Meets

Last week the Medicare Payment Advisory Commission met in Washington, D.C. to discuss a number of Medicare payment issues.

Among the issues on MedPAC’s October agenda were:

  • Medicare Advantage benchmark policy
  • indirect medical education:  current Medicare policy, concerns, and principles for revising
  • the evolution of Medicare’s advanced alternative payment models
  • vertical integration and Medicare payment policy

MedPAC is an independent congressional agency that advises Congress on issues involving the Medicare program.  While its recommendations are not binding on either Congress or the administration, MedPAC is highly influential in governing circles and its recommendations often find their way into legislation, regulations, and new public policy.  Because so many patients of private safety-net hospitals are insured by Medicare, MedPAC’s deliberations are especially important to those hospitals.

Go here for links to the policy briefs and presentations that supported MedPAC’s discussion of these issues and here for a transcript of the proceedings.

NASH Submits Comments on Proposed Medicare Outpatient Regulation

NASH has submitted formal comments to the Centers for Medicare & Medicaid Services in response to that agency’s proposed 2021 Medicare outpatient prospective payment system rule.

That rule describes how CMS proposes paying hospitals for Medicare-covered fee-for-service outpatient care in 2021.

Writing on behalf of private safety-net hospitals, NASH addressed the following aspects of the proposed rule:

  • Proposed rate increase.   NASH endorsed CMS’s proposal to raise Medicare fee-for-service rates for outpatient care.
  • The 340B program.  NASH expressed strong opposition to CMS’s proposal to reduce  reimbursement for prescription drugs to 340B-eligible hospitals.
  • Phase-out of the inpatient-only services list.  NASH asked CMS not to phase out the inpatient-only services list.
  • Changes in the level of supervision for selected outpatient therapeutic services.  NASH conveyed its support for proposed reductions in such supervision.
  • The physician-owned hospital exception.  NASH opposed CMS’s proposal to ease the current limit on the expansion of high-Medicaid physician-owned hospitals.

Learn more about NASH’s reasoning behind each of these positions in its letter to CMS on the proposed 2021 Medicare outpatient prospective payment system regulation.

MedPAC Talks Telehealth

Expanded telehealth is here to stay, members of the Medicare Payment Advisory Commission agreed at their September public meeting.

What they do not yet know is in what form.

Among the issues that need to be addressed in any post-COVID-19 expansion of Medicare-covered telehealth services are:

  • Whether affording access to telehealth services would exacerbate the digital divide and leave some Medicare beneficiaries with less access to care than others.
  • Whether audio-only coverage, temporarily permitted during the pandemic, should be continued.
  • Whether greater use of telehealth might foster greater use of low-value services.
  • Whether use of non-HIPAA-compliant video technology should continue to be permitted.

Learn more about MedPAC’s deliberations on telehealth in the Healthcare Dive article “MedPAC commissioners hint at telehealth policies that may stick post-COVID-19” and see the presentation that formed the basis for the discussion of this issue at MedPAC’s recent public meeting.

 

MedPAC Meets

Last week the Medicare Payment Advisory Commission met in Washington, D.C. to discuss a number of Medicare payment issues.

The issues on MedPAC’s September agenda were:

  • the coronavirus pandemic and Medicare
  • context for Medicare payment policy
  • report on the Protecting Access to Medicare Act of 2014’s changes to the Medicare clinical laboratory fee schedule
  • expansion of telehealth in Medicare
  • Medicare coverage for vaccines

MedPAC is an independent congressional agency that advises Congress on issues involving the Medicare program.  While its recommendations are not binding on either Congress or the administration, MedPAC is highly influential in governing circles and its recommendations often find their way into legislation, regulations, and new public policy.  Because so many patients of private safety-net hospitals are insured by Medicare, MedPAC’s deliberations are especially important to those hospitals.

Go here for links to the policy briefs and presentations that supported MedPAC’s discussion of these issues.

CMS Finalizes FY 2021 Payments to Hospitals

Medicare has announced how it will pay hospitals for inpatient care in FY 2021 with publication of its annual inpatient prospective payment system regulation last week.

Among the changes announced by the Centers for Medicare & Medicaid Services:

  • A 2.9 percent increase in fee-for-service inpatient rates.
  • A compromise on its proposal to require hospitals to report their payer-specific negotiated rates with Medicare Advantage plans.
  • Changes in how Medicare will calculate Medicare disproportionate share (Medicare DSH) uncompensated care payments.
  • A much smaller cut than originally proposed in the pool of funds for Medicare DSH uncompensated care payments.  Medicare DSH uncompensated care payments are especially important to private safety-net hospitals.
  • Minor adjustments in the Medicare area wage index system.
  • Refinements in the Medicare graduate medical education program.
  • A new DRG for CAR T-cell payments and a new pathway to Medicare add-on payments for FDA-approved antimicrobial products.

Learn more from CMS’s fact sheet or see the final regulation itself.

Feds Propose Changing Medicare DSH Calculation

Medicare DSH payments would reflect hospitals’ Medicare Advantage inpatient days under a new regulation proposed by the Centers for Medicare & Medicaid Services.

Under the newly proposed rule, the formula for calculating Medicare disproportionate share payments would incorporate hospitals’ Medicare Advantage inpatient days and not just their fee-for-service inpatient days.

Medicare DSH payments are made to hospitals that serve especially high proportions of low-income and uninsured patients and are intended to help them with the cost of providing those services.  All private safety-net hospitals qualify for Medicare DSH payments and consider the program an essential tool in their efforts to serve their communities.

The National Alliance of Safety-Net Hospitals will review the proposed regulation and model its potential impact on private safety-net hospitals.  As appropriate, NASH also will submit formal comments to CMS.

Go here to see the proposed regulation.

 

NASH Comments on Proposed Changes in Medicare Payments

NASH has submitted formal comments to the Centers for Medicare & Medicaid Services in response to CMS’s proposed FY 2021 Medicare inpatient prospective payment system regulation.

In its letter, NASH addressed six specific aspects of the proposed rule:

  • Medicare disproportionate share (Medicare DSH) proposals
  • The Medicare area wage index
  • Negotiated rate reporting
  • Medicare bad debt policy
  • Medicare graduate medical education policy
  • CAR-T cell therapy payments

Of particular note, NASH maintained that instead of decreasing the size of the pool of money for Medicare DSH uncompensated care payments, CMS should actually increase that pool in anticipation of increased hospital inpatient volume in FY 2021 – and increased hospital uncompensated care – as people return to hospitals for non-emergency procedures delayed by the COVID-19 emergency.

NASH also conveyed its opposition to the methodology CMS proposes using to calculate Medicare DSH uncompensated care payments, suggesting an alternative approach that makes better use of more current, more accurate data in that calculation.

Medicare DSH and Medicare DSH uncompensated care payments are especially important to private safety-net hospitals because those hospitals care for so many low-income, low-income elderly, and uninsured patients.

Read NASH’s comment letter to CMS here.

NASH Applauds HHS Movement Toward Extending Public Health Emergency

NASH has thanked Health and Human Services Secretary Alex Azar for his department’s public indication that it intends to extend the COVID-19 public health emergency.

With the declaration of a public health emergency has become regulatory flexibilities that have enabled private safety-net hospitals and other providers to do a better job serving their patients and their communities in the current, challenging environment.

See NASH’s letter here.

Coronavirus Update for Tuesday, June 2

Coronavirus update for Tuesday, June 2, 2020 as of 2:45 p.m.

NASH Advocacy

On Tuesday, the National Alliance of Safety-Net Hospitals wrote to Senate leaders and asked them to advance legislation with five major COVID-19-related policy initiatives:

  1. An additional $100 billion for hospitals.
  2. A 14-point increase in the federal medical assistance percentage (FMAP).
  3. A 2.5 percent increase in states’ Medicaid disproportionate share (Medicaid DSH) allotments and another delay in implementation of Affordable Care Act-mandated cuts in those allotments.
  4. Reduced interest rates and a longer payback period for Medicare payments advanced to hospitals through the CARES Act’s Accelerated and Advance Payment Program.
  5. Prevention of implementation of the Medicare fiscal accountability regulation (MFAR).

Learn more from NASH’s letter to Senate majority leader Mitch McConnell and Senate minority leader Chuck Schumer.

On Monday NASH submitted formal comments to CMS on an interim final rule published in April to help health care providers respond to the COVID-19 emergency.  NASH expressed support for the changes CMS introduced.

Centers for Medicare & Medicaid Services

Food and Drug Administration

The Joint Commission

Federal Funding Opportunities for Hospitals

  • NASH has prepared a document that collects and presents in one place the various new federal funding opportunities for hospital resulting from legislation addressing the COVID-19 public health emergency.  Find that document here.

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