CMS Memos Clarify Policies for Providers, State Survey Agencies

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What’s happening: In four new memos, the Centers for Medicare & Medicaid Services (CMS) clarifies survey policies for critical access hospitals (CAHs), long-term care facilities (LTC), and laboratories.  

What else you need to know: New and revised guidance addresses time-share and leased space arrangements in CAHs, immediate jeopardy in laboratories, and LTC policies.  

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CMS Requires Patient Reclassification Notices in February 2025

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What’s happening: Beginning Feb. 14, 2025, the Centers for Medicare and Medicaid Services (CMS) will require giving “Observation Change of Status Notices” to patients who are reclassified from inpatient to observation (outpatient) status.  

What else to know: CMS has issued updated information on these new requirements for communication to affected patients. Hospitals will be required to provide a Medicare Change of Status Notice (MCSN) to eligible Medicare patients who are reclassified from inpatient to outpatient receiving observation services.

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CHA DataSuite Analysis of CY 2025 Medicare OPPS Final Rule Shows Fee-for-Service Payment Changes from CY 2024

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What’s happening: CHA DataSuite has issued a hospital-specific analysis of calendar year (CY) 2025 Medicare outpatient prospective payment system (OPPS) final rule.  

What else to know: The analysis is intended to show providers how Medicare outpatient fee-for-service payments will change from CY 2024 to CY 2025 based on the policies set forth in the final rule.  

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Advancing the Fight for Better Behavioral Health Care

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Last week, CHA held its Behavioral Health Care Symposium, attended by hundreds of clinical professionals, hospital leaders, policymakers, and community stakeholders. This annual gathering highlights the important work hospitals are doing alongside many others to improve behavioral health care across the state. Sessions at the symposium highlighted successful collaborations among hospitals, counties, and health plans.  

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Ninth Circuit Court of Appeals Finds Low Wage Index Policy Unlawful

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What’s happening: CHA prevails in Kaweah Delta Health Care District, et al. v. Becerra, the legal challenge to the Centers for Medicare & Medicaid Services’ (CMS’) low wage index policy. 

What else to know: CHA has supported this litigation on behalf of its members to reverse a policy that is harmful to all California hospitals.  

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Final Rule Advances Interoperability, Info Sharing in Health Care

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What’s happening: The Assistant Secretary for Technology Policy (ASTP) and Office of the National Coordinator for Health Information Technology issued a final rule to advance interoperability and improve information sharing among patients, providers, payers, and public health authorities.  

What else to know: In future rulemaking, the ASTP will finalize additional policies included in the proposed rule.  

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CMS Posts List of Measures Under Consideration for Federal Quality Programs

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What’s happening: The Centers for Medicare & Medicaid Services (CMS) has posted its annual list of measures under consideration (MUC) for use in quality reporting and payment programs. The list includes boarding measures on patient safety and emergency departments for hospitals.  

What else to know: As required by law, the MUC list will be reviewed by the Partnership for Quality Measurement’s (PQM) Pre-Rulemaking Measure Review (PRMR) committees, who will provide CMS with recommendations on the measures’ appropriateness for federal quality programs by Feb. 1, 2025. Written public comments can be provided to the PRMR by Dec. 30, and the public can register for listening sessions and committee meetings on the PQM website.   

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CHA Issues Summaries of CY 2025 OPPS, Physician Fee Schedule Final Rules

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What’s happening: Summaries of the calendar year (CY) 2025 outpatient prospective payment system (OPPS) and physician fee schedule final rules are available for CHA members. 

What else to know: The rules are effective Jan. 1, 2025.  

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182 Members of Congress Sign Letter to Prevent Medicaid DSH Cuts

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What’s happening: A bipartisan letter asking House leadership to prevent upcoming Medicaid disproportionate share hospital (DSH) payment cuts gathered 182 signatures — including 36 from the California delegation. CHA thanks hospital leaders for their outreach on this critical issue.  

What else to know: Reductions in Medicaid DSH payments to states are scheduled to take effect on Jan. 1, 2025. If these cuts go into effect, California’s hospitals would lose $1.2 billion in 2025.  

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CHA DataSuite CY 2025 HH Final Rule Impact Analysis Shows How Medicare FFS Payments Will Change

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What’s happening: CHA DataSuite has issued a hospital-specific analysis of the calendar year (CY) 2025 Medicare home health (HH) prospective payment system final rule analysis.  

What else to know: The analysis is intended to show HH providers how Medicare fee-for-service (FFS) payments will change from CY 2024 to CY 2025 based on the policies set forth in the final rule. A detailed summary of the final rule is available for CHA members. 

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