NASH Comments on Proposed Changes in S-10 Uncompensated Care Reporting

NASH has expressed support for several new federal proposals on hospital uncompensated care data reporting and conveyed its opposition to other proposed changes in federal data collection requirements in a new letter to the Centers for Medicare & Medicaid Services.

In response to changes CMS has proposed in the uncompensated care data hospitals must submit to the federal government, NASH expressed:

  • Support for CMS’s proposal to clarify aspects of how hospitals must report data on the uncompensated care they provide on the Medicare cost report’s S-10 form.
  • Expressed concern that some of the new data reporting requirements violate current HIPAA requirements.
  • Asked CMS to defer reporting on the rates hospitals negotiate with Medicare Advantage plans until after the end of the COVID-19 public health emergency.

NASH is especially interested in proposed changes in uncompensated care data reporting on the S-10 form because that form is used in the calculation of private safety-net hospitals’ Medicare disproportionate share payments (Medicare DSH).  Those Medicare DSH payments are a vital tool in helping these hospitals serve the low-income and uninsured residents of the communities in which they are located.

Learn more about NASH’s response to CMS’s proposed new information collection activities in this NASH letter to CMS.

MedPAC Meets

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

MedPAC’s proposed Medicare 2021 payment recommendations dominated the December agenda, including:

  • hospital inpatient and outpatient payments
  • ambulatory surgical center payments
  • physician and health professional payments
  • hospice payments
  • home health care payments
  • inpatient rehabilitation facility payments
  • long-term care hospital payments

In addition, MedPAC discussed Medicare’s policy for transfers between post-acute-care facilities and hospice and received a staff update on the Medicare Advantage program.

MedPAC is an independent congressional agency that advises Congress on issues involving Medicare.  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 for a transcript of the two days of meetings.

MedPAC Meets

Earlier this 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 November agenda were:

  • expansion of telehealth in Medicare
  • report on Medicare beneficiaries’ access to care in rural areas
  • effects of pharmaceutical rebates on Part D’s risk adjustment
  • improving competition among Medicare Part D’s benchmark plans
  • separately payable drugs in the hospital outpatient prospective payment system
  • Medicare Advantage payment and access for enrollees with end-stage renal disease

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.

Most Hospitals Fined by Medicare Over Readmissions

More than 80 percent of all hospitals subject to Medicare’s hospital readmissions reduction program, and half of all of hospitals in the country, will be penalized in FY 2021 under that program because they have what Medicare considers to be too many avoidable readmissions.

In all, 2556 of the 3080 hospitals subject to the Centers for Medicare & Medicaid Services program will be penalized.  More than 600 will see their inpatient payments cut one percent as a result and the average cut will be 0.69 percent.

The penalties are based on hospital performance with patients experiencing congestive heart failure, heart attacks, chronic obstructive pulmonary disease, coronary artery bypass graft surgery, pneumonia, and knee and hip replacement.  Such patients are considered readmitted if they return to the hospital within 30 days of their discharge for these conditions unless their return to the hospital was planned as part of their treatment.

Learn more about hospital performance under Medicare’s hospital readmissions reduction program and find links to tools to look up individual hospitals and download nation-wide hospital 2021 readmissions data in the Kaiser Health News article “Medicare Fines Half of Hospitals for Readmitting Too Many Patients.”

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.