CHA News

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CHA has submitted the attached  comment letter on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule that would test new mandatory Medicare payment models for covered Part B prescription drugs provided in physician offices, hospital outpatient departments and certain drugs furnished through durable medical equipment (DME). While CHA appreciates that CMS is paying attention to the growing national crisis of rising drug prices, we believe the proposed demonstration will have unintended consequences — namely, incentivizing inappropriate shifts in care settings for beneficiaries and overpaying for low-cost drugs. CHA urges CMS to exclude hospital outpatient departments from the demonstration, scale back the size and scope of phase one of the demonstration, and propose phase two of the demonstration through a formal regulatory process with notice and comment. CHA urges members to use the comment letter to inform and submit their own comments. Comments are due May 9 by 2 p.m. (PT) and can be submitted at www.regulations.gov.  

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CHA reminds members to register for a member forum on April 29 from 11 a.m. – noon (PT) on the proposed rule implementing mandatory payment models for covered Part B prescription drugs provided in physician offices, hospital outpatient departments and certain drugs furnished through durable medical equipment. The proposed five-year model would first test whether lowering the current Part B drug add-on payment would push prescribing incentives toward lower-cost drugs, and would later expand to include testing of value-based purchasing models for Part B drugs. Participants should register by noon April 28 at www.surveymonkey.com/r/partbdrugmodel. Dial-in information and materials will be distributed by close of business on April 28.

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Last year, the Centers for Medicare & Medicaid Services (CMS) finalized its Comprehensive Care for Joint Replacement (CJR) payment model. Starting April 1, the program will be mandatory for Los Angeles-Long Beach-Anaheim, Modesto and San Francisco-Oakland-Hayward hospitals that are not already participating in the bundled payment care initiative. In addition to the CJR Connect website, which CMS hopes to make available soon, the agency has scheduled a series of webinars aimed at helping providers prepare for the new program. Upcoming webinars, all scheduled for noon to 1 p.m. (PT), are March 10, focusing on quality measures and voluntary reporting; March 15, focusing on preparing for and key details about the program; and March 17, focusing on quality measures and quality composite scores.
Registration links for the webinars have been sent to primary points of contact at each affected CJR hospital but can also be obtained by contacting cjrsupport@cms.hhs.gov. CJR program details — including model background documents, a list of hospitals and other materials — can be found at https://innovation.cms.gov/initiatives/cjr. 

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CHA has submitted the attached response to the Centers for Medicare & Medicaid Services (CMS) request for information on the certification of health information technology (HIT). In conjunction with the Office of the National Coordinator, CMS sought input on electronic health records products used for reporting electronic clinical quality measures (eCQMs), specifically requesting feedback on how often to require recertification of HIT modules, the number of eCQMs a certified HIT module should be required to certify to, and ways to improve module testing.

In comments, CHA urged CMS to complete a full and transparent evaluation of the current state of eCQM development in order to inform future rulemaking, and to develop a strategic, long-term, detailed measurement strategy with clear goals for identifying appropriate eCQMs. In response to CMS’ specific questions, CHA urged CMS to require recertification of HIT modules each time a new eCQM is added to a program. CHA also believes that CMS should require certification of all eCQMs used in all CMS programs, and that certification should occur in advance of the measures’ adoption into the program. Finally, CHA stressed the need for a robust testing process for each eCQM.

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CHA hosted a members-only call Jan. 13 to discuss the Centers for Medicare & Medicaid Services’ Comprehensive Joint Replacement (CJR) model final rule. CHA reviewed key provisions of the final rule and fielded questions from participants during the call, which was recorded in its entirety and is now available for members on CHA’s website. The link also contains presentation slides and additional resources related to CJR.

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CHA submitted the attached comment letter to the Centers for Medicare & Medicaid Services (CMS) today in response to CMS’ request for information on core access to care measures and metrics that could be used to assess access in the Medicaid program. CHA encourages CMS to take a thoughtful approach and develop an action plan that would ensure successful implementation of CMS’ goals for the program.

More specifically, CHA recommends that CMS develop and implement a National Access Strategy, similar to its approach when developing the National Quality Strategy, and allow multi-stakeholder and multi-agency participation in the process. CHA also urges CMS to look beyond traditional metrics to identify new evidence-based areas for measure development and to identify measurement gaps. CHA recommends that CMS consider environmental factors such as poverty, access to transportation and affordable housing when evaluating a beneficiary’s access to care. These factors can have significant impacts on patient health and health care delivery and should receive consideration. While CHA appreciates CMS’ efforts to create an equitable health care system, CHA requests that CMS recognize the costs of providing health care when it determines whether rates are adequate to ensure access. CMS must ensure that payment rates remain adequate for hospitals that are asked to do more with less. 

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The Centers for Medicare & Medicaid Services (CMS), in conjunction with the Office of the National Coordinator (ONC), has issued the attached request for information about the certification of health information technology (HIT). CMS and ONC seek information on electronic health records (EHR) products used for reporting electronic clinical quality measures for EHR incentive programs, the hospital inpatient quality reporting program and the physician quality reporting system. CMS and ONC request feedback on how often to require recertification, the number of clinical quality measures a certified HIT module should be required to certify to, and ways to improve testing of the modules. Comments on the request are due Feb. 1. 

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CHA has submitted the attached comment letter to the Environmental Protection Agency (EPA) on its proposed rule for management standards for hazardous waste pharmaceuticals. Developed in conjunction with a member workgroup, CHA’s comments are generally supportive of the proposed requirements but express concern with the overlap of state and federal law. CHA urges EPA to develop technical assistance for state agencies, ensuring that both state and federal regulations can be complied with efficiently. In addition, CHA urges EPA to delay the effective date of the final rule to no earlier than one year from its release. CHA believes that state agencies need additional time to understand the opportunities and challenges these new policies present, and develop resources to educate hospitals and health care facilities on compliance. Comments on the proposed rule are due Dec. 24.