Every year, California’s hospitals treat millions of patients, many of them covered by Medi-Cal, the state’s health care safety net. This includes numerous essential health care services for Californians, including care for more than 50% of all births, 46% of behavioral health-related emergency department visits, 58% of rural hospital patient care days, 1 million inpatient stays, and nearly 16 million outpatient visits in 2018. CHA is committed to protecting Medi-Cal rates and assuring that the state’s neediest maintain access to the high quality of care that all Californians deserve.
In the federal fiscal year (FFY) 2019 inpatient prospective payment system final rule, the Centers for Medicare & Medicaid Services (CMS) finalized its second year of a three-year transition to use Worksheet S-10 data for distributing Medicare disproportionate share hospital (DSH) uncompensated care payments. CMS will use two years (FFYs 2014 and 2015) of Worksheet S-10 cost report data and one year of proxy data to distribute the uncompensated care payments for FFY 2019.
In response to comments from CHA, CMS noted in the final rule that it planned audits of the data in fall 2018. In late August, CMS began audits of selected hospitals’ FFY 2015 cost reports. A number of hospitals in California have received this data request, and must respond by Sept. 28.
Because CMS has given the Medicare administrative contractors (MACs) only until the end of January to complete the audits, providers have a short timeline to complete this work with their MACs. Though CHA acknowledges that this presents a challenge from both technical and resource perspectives, CHA highly encourages hospitals that have received a request to respond as quickly as possible. Early communication with Noridian (or its subcontractor, Figliozzi & Company) is critical under this short timeline. A copy of the letter Noridian sent to select providers requesting documentation is attached; these letters are consistent across all MACs.
The California Hospital Association, the California Association of Public Hospitals and Health Systems, Private Essential Access Community Hospitals, Inc., the California Children’s Hospital Association and the District Hospital Leadership Forum have submitted the attached joint letter on the Centers for Medicare & Medicaid Services (CMS) proposed rule on fee-for-service access to care monitoring requirements within the Medicaid program. The proposed rule would amend the process by which states document whether Medicaid payments in fee-for-service (FFS) systems are sufficient to enlist providers to assure beneficiary access to covered care and services consistent with existing statute.
In the letter, the organizations oppose an exemption from the FFS access standards, regardless of the managed care penetration rate, as it eliminates safeguards that promote a more transparent data-driven process. The letter also outlines concerns with proposals related to an exemption for states with high managed care enrollment, exemptions for nominal rate reductions, relief from public notice of rate reductions and the need for greater CMS oversight of state Medicaid programs.
Comments on the proposed rule are due by 2 p.m. (PT) on May 22.
The Centers for Medicare & Medicaid Services (CMS) recently issued a proposed rule that would provide states with greater flexibility in how they meet access to care requirements within the Medicaid program.
The proposed rule addresses concerns associated with the 2015 final rule — which CHA commented on — that requires states proposing to reduce or restructure Medicaid fee-for-service payment rates to collect data through an Access Monitoring Review Plan and solicit input on the potential impact on beneficiaries’ access to care.
CMS proposes to exempt states with an overall Medicaid managed care penetration rate of 85 percent or greater from most fee-for-service access monitoring requirements; California’s current Medi-Cal managed care penetration rate is 80 percent.
Last night the House of Representatives passed the Bipartisan Budget Act of 2013. The Senate is expected to do so today, and the President has indicated he will sign the measure. The vote in the House was 332-62; nine Californians voted against passage. The legislation contains both good news and bad news for California’s hospitals.
Also this week, the House Ways and Means and Senate Finance Committees reported bipartisan legislation to repeal the sustainable growth rate (SGR) for physician Medicare payments. They will continue to work toward a permanent solution during the first quarter of 2014. The financing mechanisms for offsetting the cost of repeal have not been released. Payments to hospitals continue to be vulnerable as the committees look for as much at $150 billion over the next 10 years to pay for the SGR repeal.
CHA has provided the attached summary of the Bipartisan Budget Act of 2013 with additional information about the hospital-related provisions.
CHA President/CEO C. Duane Dauner was joined by 10 representatives of CHA member hospitals in Washington, D.C., Dec. 3 for the CHA and American Hospital Association hospital advocacy day. The group met with about half of the California Congressional delegation, including House Minority Leader Nancy Pelosi, House Majority Whip Kevin McCarthy, and Sens. Boxer and Feinstein.
Gov. Jerry Brown’s 2013-14 state budget proposal, released Jan. 10, includes a delay in implementing the Coordinated Care Initiative (CCI), which will transition individuals eligible for both Medicare and Medi-Cal —dual-eligibles — into managed care. It will also integrate long-term care services and supports into managed Medi-Cal. CCI implementation is now scheduled for September 2013, rather than June 2013 as originally planned. Under the revised timeline, beneficiaries will receive notice of changes no sooner than June 2013. Beneficiary enrollment schedules have also been modified and will vary among the designated counties: in Los Angeles County, enrollment will be phased in over 18 months; in the County of San Mateo, beneficiaries will be enrolled at once; and in Orange County, County of San Diego, County of San Bernardino, County of Riverside, Alameda County, and the County of Santa Clara, enrollment will be phased in over 12 months.
CHA has joined with California’s safety-net hospitals on the Disproportionate-Share Hospital (DSH) Task Force to send a letter to members of the California congressional delegation urging them to protect the Medicaid program from any additional cuts to hospital payments. As the House searches for spending reductions to offset the elimination of cuts to defense spending, proposals have emerged to reduce states’ ability to use Medicaid provider taxes and DSH payments. These programs provide critical means for hospitals to bolster their ability to preserve health care services for the state’s most needy patients. CHA will continue to advocate against further cuts to hospitals as the House continues its budget reconciliation process. The DSH Task Force letter is attached.