CHA News

CMS Issues FFY 2020 Inpatient Psychiatric Facility PPS Final Rule

The Centers for Medicare & Medicaid Services (CMS) released its final rule for the federal fiscal year (FFY) 2020 inpatient psychiatric facility (IPF) prospective payment system (PPS).

CMS finalized a 2.9% market basket update, offset by reductions including a productivity adjustment of 0.4% and an Affordable Care Act-mandated 0.75% reduction, resulting in a payment increase of approximately 1.75%. After accounting for a $10 million decrease as a result of an update to the outlier threshold, CMS estimates overall payments will increase by $65 million compared to FFY 2019. CMS also finalized its proposals to revise and rebase the market basket to reflect a 2016 base year rather than a 2012 base year, and remove the one-year lag in wage index data used under the IPF PPS. As a result, CMS will apply the FFY 2020 pre-floor, pre-reclassified inpatient prospective payment system wage index data. 

For the IPF Quality Reporting Program, CMS finalized the adoption of one new measure — Medication Continuation Following Inpatient Psychiatric Discharge (National Quality Forum #3205) — beginning with the FFY 2021 payment determination and subsequent years.

The proposed rule is effective Oct. 1. Additional information is available in a CMS fact sheet.

CMS Issues FFY 2020 Skilled-Nursing Facility PPS Final Rule

The Centers for Medicare & Medicaid Services (CMS) has issued the federal fiscal year (FFY) 2020 final rule for the skilled-nursing facility prospective payment system (SNF PPS). The provisions in the proposed rules will be effective Oct. 1, 2020.

Highlights of the final rule include:  

CMS Issues FFY 2020 IPPS Final Rule

The Centers for Medicare & Medicaid Services (CMS) released its federal fiscal year (FFY) 2020 inpatient prospective payment system (IPPS) final rule.  

Key highlights of the proposed rule include:

Area Wage Index: CMS finalized – with modification – its proposal to make changes to the area wage index. The final rule: 

Increase wage index values for low-wage hospitals in the bottom 25th percentile.
Cut the base payment for all IPPS hospitals, as opposed to the initial proposal to reduce wage index values for the hospitals in the highest 25th percentile. 
Cap any decrease in a hospital’s wage index at 5% in FFY 2020 compared to FFY 2019. 
Exclude wage index data from urban hospitals that reclassify as rural when calculating each state’s rural floor.
Include wage data from the eight California hospitals that were deleted from the proposed rule calculation.

Medicare DSH Payments: Despite CHA’s continued concerns with the reliability and validity of data reported on Worksheet S-10 and a request for a blended approach, CMS finalized its proposal to use a single year of uncompensated care data from Worksheet S-10 to determine the distribution of disproportionate share hospital (DSH) uncompensated care payments for FFY 2020. Specifically, the agency will use S-10 data from the FFY 2015 audited cost report.
Comprehensive CC/MCC Analysis: In response to comments from CHA and other stakeholders, CMS generally did not finalize proposed changes to severity level designations. CMS agreed with commenters that changes based on its comprehensive analysis were premature, and will conduct additional analysis and provide publicly available information — such as a test GROUPER — to allow for impact testing,
New Technology Add-on Payments: CMS finalized its proposal to increase the new technology add-on payment (NTAP) from 50% to 65% of the marginal cost of the case, capped at 65% of the cost of the technology. CMS is also increasing the add-on payment to 75% for certain antimicrobials.
Annual Payment Update: For FFY 2020, CMS will increase payment rates by 3.1% compared to FFY 2019. The update includes an initial market basket update of 3.1%, minus 0.4% for productivity and plus 0.5& to partially restore cuts made as a result of the American Taxpayer Relief Act (ATRA) of 2012. CMS estimates that, after accounting for all policies in the final rule, total IPPS payments will increase by 3%, or approximately $3.8 billion.
Quality Reporting Programs: CMS finalized a number of changes to hospital quality reporting programs, including two new measures for the Inpatient Quality Reporting Program. For the FFY 2023 payment period, CMS adopts one new opioid-related electronic clinical quality measures (eCQM), “Safe Use of Opioids – Concurrent Prescribing.” Beginning with the FFY 2024 payment period, all hospitals will be required to report this eCQM and choose three additional eCQMs. CMS did not finalize adoption of its proposed “Hospital Harm – Opioid Related Adverse Events” eCQM. Beginning with the FFY 2026 reporting period, CMS will require hospitals to report the currently voluntary “Hybrid Hospital-Wide All-Cause Readmissions” measure, following two additional voluntary reporting periods. CMS also finalized policies for the Hospital Readmissions Reduction Program, Hospital-Acquired Conditions Reduction Program, or the Hospital Value-Based Purchasing Program.
Promoting Interoperability Program: CMS finalized a continuous 90-day reporting period for hospitals and critical access hospitals in the Medicare Promoting Interoperability Program for the calendar year 2021 reporting period. In addition, CMS will allow optional reporting of the “Query of Prescription Drug Monitoring Program” measure for the 2020 reporting period. CMS also finalized its proposal to remove the “Verify Opioid Treatment Agreement” measure beginning in 2020, in response to comments from CHA and other stakeholders about significant implementation challenges. CMS finalized proposals to align eCQM reporting requirements with the hospital inpatient quality reporting program. 

CHA is currently analyzing the final rule and will provide members with a more detailed summary in the coming weeks. Additional information is available in a CMS fact sheet.

On August 16, CHA will host a complimentary members-only briefing from 10-11 a.m. (PT) to update members on the finalized area wage index proposal and next steps. Register here. 

Governor Signs Bill Expanding Career Pathway for Medical Laboratory Technicians

Earlier this week, Governor Newsom signed Senate Bill 334 (Chapter 144, Statutes of 2019), which requires the California Department of Public Health (CDPH) to establish a pathway program that allows licensed medical laboratory technicians (MLTs) to apply their MLT work experience and training toward the completion of a clinical lab scientist (CLS) training program. 

CMS Releases Final, Proposed Rules

This week, CMS released the following rules: 

Inpatient Prospective Payment System (PPS) Final Rule
Skilled-Nursing Facility PPS Final Rule 
Inpatient Rehabilitation Facility PPS Final Rule
Physician Fee Schedule Proposed Rule

CMS Issues CY 2020 Physician Fee Schedule Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) has issued its proposed rule updating the Medicare physician fee schedule (PFS), quality payment program, and other Medicare Part B payment policies for calendar year (CY) 2020. Comments on the proposed rule are due Sept. 27. Key provisions of the proposed rule are highlighted below:

Evaluation and Management (E/M) Services: In a change from its policies finalized for the CY 2019 PFS, CMS proposes to revert back to setting separate payment rates for all levels of E/M visits rather than blending payment rates for certain levels. Specifically, CMS would retain five levels of coding for established patients, reduce the number of levels to four for new patients, and allow providers to choose the E/M level based on either medical decision-making or time. In addition, for CY 2021, CMS would adopt a new add-on code for prolonged service time and consolidate previously finalized add-on codes for primary care and non-procedural specialty care.
Medicare Coverage for Opioid Use Disorder Treatment Service: CMS proposes policies to implement requirements of the SUPPORT Act to establish a new Medicare Part B benefit for opioid use disorder (OUD) treatment services, including medications for medication-assisted treatment (MAT), furnished by opioid treatment programs (OTPs).
Bundled Payments for Substance Use Disorder Services: CMS proposes to create new coding and payment for a bundled episode of care for management and counseling for OUD.  The proposed codes describe a monthly bundle of services for the treatment of OUD that includes overall management, care coordination, individual and group psychotherapy, and substance use counseling. CMS also seeks comment on bundles describing services for other SUDs and on the use of MAT in the emergency department setting to inform future rulemaking.
Telehealth Services: CMS proposes to add three HCPCS codes that describe a bundled episode of care for treatment of opioid use disorders to the list of available telehealth services.
Case Management Services: CMS proposes several policies related to care management services, including increasing payment and billing flexibility for care management provided to beneficiaries after discharge from inpatient and certain outpatient stays. CMS also proposes changes to improve the accuracy of payment for chronic care management services and reduce burden associated with billing for these services, and to introduce new coding and payment for care management services for patients with a single serious chronic condition.
Therapy Services: CMS proposes policies to implement mandated therapy modifiers — as finalized in the CY 2019 PFS final rule — that identify therapy services furnished in whole or in part by physical therapy and occupational therapy assistants. Beginning with services furnished in 2022, these services are paid at a reduced level; CMS clarifies that this does not apply to services furnished by critical access hospitals because they are not paid for therapy services at PFS rates.
Medicare Shared Savings Program: CMS proposes changes to the Medicare Shared Savings Program quality reporting requirements, and seeks comment on how to better align the quality performance scoring methodology more closely with the Merit-based Incentive Payment System (MIPS) quality performance scoring methodology.
Quality Payment Program: CMS proposes changes to the physician Quality Payment Program, including updates to the MIPS for the CY 2020 reporting period, such as a higher weight on cost measures, and higher performance standards for earning positive payment adjustments. CMS also proposes policies related to incentives for alternative payment model participation.

CHA will provide members with a more detailed summary of the proposed rule in the coming weeks. Additional information is available in a CMS fact sheet and a separate Quality Payment Program fact sheet.

Authors
  • Megan Howard
    Vice President, Federal Policy