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Safety-Net Hospitals Gird for Loss of Medicaid DSH Money

Safety-net hospitals and others will lose a significant portion of their Medicaid disproportionate share (Medicaid DSH) payments on November 22 unless Congress delays implementation of the cut in those payments that was mandated by the Affordable Care Act.

And hospitals that receive these payments are now preparing for the worst.

The Medicaid DSH cut was included in the 2010 health care reform law in anticipation of a great reduction in the number of uninsured people leaving hospitals providing much less uncompensated care and therefore not in need of as much DSH money.  The law’s reach has not proven to be as great as anticipated, however, and two developments since the law’s passage have put a damper on the expected rise in the number of insured Americans:  a court decision that made it optional for states to expand their Medicaid program and the repeal of the requirement that everyone purchase health insurance.

Four times Congress has voted to delay the Medicaid DSH cut because so many people remained uninsured.  Now, however, the most recent delay in implementation of the cut, via a provision in the continuing resolution currently funding the federal government, expires on November 21, and hospitals – many of them already with razor-thin margins – are preparing for the worst:  a major reduction of their federal Medicaid DSH money.

NASH has asked Congress to delay the implementation of Medicaid DSH cuts on numerous occasions, citing their potential impact on the ability of private-safety-net hospitals to serve their communities.  NASH most recently made this request in September, urging members of Congress to support the continuing bipartisan effort to delay the cut.

Learn more about the prospect of a major Medicaid DSH cut later this month, how it might affect safety-net hospitals – including the kinds of private safety-net hospitals represented by NASH – and what some hospitals are doing to prepare for the possibility in the Stateline article “Rural and Safety Net Hospitals Prepare for Cut in Federal Support.”

Safety-Net Hospitals, Others Benefit From Changes in Medicare Readmissions Program

Safety-net hospitals are among the leading beneficiaries of changes implemented this year in Medicare’s  hospital readmissions reduction program.

According to a new study, safety-net, academic, and rural hospitals have enjoyed improved performance under the program since Medicare began organizing hospitals into peer groups based on the proportion of low-income patients they serve rather than simply comparing individual hospital performance to that of all other hospitals.

While the current fiscal year is still under way, it appears that safety-net hospitals will enjoy a collective decline of $22 million in Medicare readmissions penalties while 44.1 percent of teaching hospitals and 43.7 percent of rural hospitals will face smaller penalties than last year.

NASH was one of the leading and most outspoken proponents of leveling the playing field in the readmissions reduction program, encouraging policy-makers to reform the program so it would compare hospital readmission rates among similar hospitals instead of to those of all hospitals.  NASH’s multi-year effort proved successful and private safety-net hospitals are now benefiting from that success.

Learn more about the readmissions reduction program and how changes in that program have significantly altered its outcomes in the JAMA Internal Medicine study “Association of Stratification by Dual Enrollment Status With Financial Penalties in the Hospital Readmissions Reduction Program.”

Safety-Net Hospitals Struggle in Medicare Joint Replacement Model

Non-safety-net hospitals are outperforming safety-net hospitals in the Comprehensive Care for Joint Replacement model introduced in 2016.

According to a new study published in Health Affairs,

…in comparison to non-safety-net hospitals, 42 percent fewer safety-net hospitals qualified for rewards based on their quality and spending performance (33 percent of safety-net hospitals qualified, compared to 57 percent of non-safety-net hospitals), and safety-net hospitals’ rewards per episode were 39 percent smaller ($456 compared to $743). Continuation of this performance trend could place safety-net hospitals at increased risk of penalties in future years.

What might be done to address this disparity?  The study suggests that

Medicare and hospital strategies such as those that reward high-quality care for vulnerable patients could enable safety-net hospitals to compete effectively in CJR.

Learn more in the Health Affairs article Performance of Safety-Net Hospitals in Year 1 of the Comprehensive Care for Joint Replacement Model.

 

Ambulances Respond Slower to Low-Income Communities

People living in low-income communities wait about four minutes longer for ambulances to respond to their call for help when they are having a heart attack, a new study has found.

In communities with annual median incomes between $57,000 and $113,000, the study found that ambulances arrive in an average of 37.5 minutes – faster than in communities where the annual median income is between $20,250 and $42,642, where the typical wait time is 43 minutes.

Neither result is anywhere near industry benchmarks of 4, 8, and 15 minutes for delivering specific services in response to heart attack symptoms.

Among the possible reasons for the difference in response times, the study’s authors suggest, are hospital closures in and around low-income areas, EMS protocols that call for emergency response from facilities that specialize in cardiac care that may be farther from low-income communities, and a reduced number of private ambulance services serving lower-income areas.

Such findings have important implications for the communities served by private safety-net hospitals.

Learn more about the study, its methodology, and its findings in the report “A US National Study of the Association Between Income and Ambulance Response Time in Cardiac Arrest,” which can be found here, on the JAMA Open Network web site.

MACPAC: Let’s “hit the pause button” on Medicaid Work Requirements

The non-partisan legislative branch agency that advises Congress and the administration on Medicaid issues will ask the administration to delay approving any more state Medicaid work requirements.

That was the decision reached by the Medicaid and CHIP Payment and Access Commission when it met last week.

MACPAC warned that the work requirement currently being implemented in Arkansas, the first state to introduce such a requirement, is flawed and needs further work before moving forward.  The agency also believes the federal government should increase its oversight of new Medicaid work requirements before additional states begin implementing similar, already-approved Medicaid work requirements.

MACPAC plans to convey its concerns in a letter to Department of Health and Human Services Secretary Alex Azar.

Medicaid work requirements pose a potential challenge for private safety-net hospitals because they could leave meaningful numbers of low-income residents of the communities those hospitals serve without health insurance.

Learn more about MACPAC’s objections to the manner in which Medicaid work requirements are being introduced in this Bloomberg Law article.

 

New Report Looks at Medicaid Buy-In

While there has been a great deal of public discussion of late about “Medicare for all,” less attention has been paid to the concept of permitting people to buy into their state’s Medicaid program.

Now, the Rockefeller Institute of Government has published a new report that presents the different approaches to the concept of Medicaid buy-in.

It also seeks to address six major questions of potential Medicaid buy-in efforts:

  • How large is the intended population of new enrollees?
  • What kind of coverage would be offered?
  • How would enrollment be financed?
  • How would rates be set?
  • Would the program use standard Medicaid rate and would there be enough participating providers to meet enrollee demand?
  • How would such a program fit into individual states’ regulatory structure?

Medicaid buy-in would be of great interest to private safety-net hospitals because they serve communities in which many residents remain uninsured.

Learn more about how the concept of Medicaid buy-in and how it might work by reading the Rockefeller Institute of Government report “Medicaid Buy-In: Questions of Design and Purpose,” which can be found here.

“Public Charge” Proposal Raises Potential Issues for Safety-Net Hospitals

A proposal by the Department of Homeland Security could make it more difficult for some immigrants to stay in the U.S. permanently by scrutinizing more closely whether they might become a “public charge” if they remain in the country and rejecting those who appear likely to do so.

By “public charge” the draft Homeland Security regulation refers to people who might depend or come to depend heavily on government assistance if they remain in the country.

If implemented, such a regulation might discourage immigrants from enrolling in government health care programs, which could endanger their health and make it more difficult for urban safety-net hospitals to serve their communities, many of which have large numbers of immigrants.  The regulation also might encourage some people to drop out of government programs that provide services they need.

NASH is concerned about the potential impact of this regulation on private safety-net hospitals and intends to submit formal comments about the proposal.  Comments are due by mid-December.

To learn more about the proposed regulation, see this Washington Post article or go here to see proposed regulation itself.

New Approach to Readmissions Program Takes Effect

Medicare’s hospital readmissions reduction program is moving in a new direction beginning in FY 2019 after Congress directed the Centers of Medicare & Medicaid Services to compare hospitals’ performance on readmissions to similar hospitals instead of to all hospitals.

The policy change, driven by a belief that safety-net hospitals were harmed by the program and excessive penalties because their patients are more challenging to serve, results in all hospitals being divided into peer groups based on the proportion of low-income patients they serve.  The readmissions performance of hospitals is then compared only to other hospitals within each peer group.

As a result of this new approach, readmissions penalties against safety-net hospitals are expected to decline 25 percent in FY 2019 while the average penalty for hospitals serving the fewest low-income patients will rise.

NAUH was one of the leading proponents of this major change in how the readmissions reduction program treats hospitals.

Kaiser Health News has published a detailed story describing the policy change and its implications for hospitals, which face penalties of up to three percent of their Medicare revenue for what is considered “excessive” readmissions of Medicare patients within 30 days of their discharge from the hospital.  Included in the article is a searchable database of every hospital in the country that lists the peer group for each hospital, its FY 2018 and FY 2019 readmissions penalties by percentage of Medicare revenue, and the change in readmissions penalty expected from FY 2018 to FY 2019.  Go here to see the article “Medicare Eases Readmission Penalties Against Safety-Net Hospital.”

New Approach to Readmissions Program to Take Effect October 1

Medicare’s hospital readmissions reduction program will move in a new direction beginning in FY 2019 after Congress directed the Centers of Medicare & Medicaid Services to compare hospitals’ performance on readmissions to similar hospitals instead of to all hospitals.

The policy change, driven by a belief that safety-net hospitals were harmed by the program and excessive penalties because their patients are more challenging to serve, results in all hospitals being divided into peer groups based on the proportion of low-income patients they serve.  The readmissions performance of hospitals is then compared only to other hospitals within each peer group.

As a result of this new approach, readmissions penalties against safety-net hospitals are expected to decline 25 percent in FY 2019 while the average penalty for hospitals serving the fewest low-income patients will rise.

NAUH was among the loudest and most persistent voices calling for reform of the program to better reflect the special challenges private safety-net hospitals face in working to prevent the readmission of their low-income Medicare payments to the hospital.

Kaiser Health News has published a detailed story describing the policy change and its implications for hospitals, which face penalties of up to three percent of their Medicare revenue for what is considered “excessive” readmissions of Medicare patients within 30 days of their discharge from the hospital.  Included in the article is a searchable database of every hospital in the country that lists the peer group for each hospital, its FY 2018 and FY 2019 readmissions penalties by percentage of Medicare revenue, and the change in readmissions penalty expected from FY 2018 to FY 2019.  Go here to see the article “Medicare Eases Readmission Penalties Against Safety-Net Hospital.”

Helping Safety-Net Hospitals Help Their Patients

A new report published on the Health Affairs Blog describes the continuing challenges safety-net hospitals face and offers suggestions for helping them meet those challenges.

The challenges, according to the report, are the virtual elimination of the Affordable Care Act’s individual health insurance mandate; the continued decline in the amount of Medicare disproportionate share hospital money (Medicare DSH) provided to safety-net hospitals; and hospital closures that shift more of the burden for caring for uninsured patients onto a smaller pool of safety-net hospitals.  The result is under-served patients and new financial risks for the hospitals that remain after some safety-net hospitals close because of the large amounts of uncompensated care those hospitals continue to provide.

To address these challenges, the report offers three potential solutions:

  • Congress should revisit the Medicare DSH cuts.
  • States should target their DSH money to the hospitals providing the most uncompensated care.
  • Non-profit non-safety-net hospitals that stabilize uninsured emergency patients and then direct them to safety-net hospitals should be required to play a longer-term role in the care of such patients as part of their required community benefit or risk losing their tax-exempt status.

Learn more about the challenges safety-net hospitals continue to face and some of the possible solutions to those problems by going here, to the Health Affairs Blog, to see the report “Safety-Net Health Systems at Risk:  Who Bears The Burden Of Uncompensated Care?”