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CHA has submitted the attached letter on the calendar year (CY) 2019 physician fee schedule (PFS) and quality payment program (QPP) proposed rule, providing comments on many of the provisions that are significant to hospitals and the physicians who provide care in hospitals. This includes CMS’ proposal to maintain a payment rate of 40 percent of outpatient prospective payment system (OPPS) rates for items and services furnished at certain off-campus hospital outpatient provider based clinics, as required by Section 603 of the Bipartisan Budget Act of 2015. CHA is disappointed that the agency continues to ignore the significant differences in regulatory requirements and responsibilities of the hospital outpatient department in providing health care services to Medicare beneficiaries, and urges the agency to refine its methodology for determining the rate. CHA believes a more robust analysis would support a payment rate of 65 percent of the OPPS rates.

CHA also comments on CMS’ proposal to reduce documentation requirements for evaluation and management (E/M) visits while collapsing payments for Level 2 through Level 5 E/M visits into a single blended payment rate. While supporting a number of the proposals that would reduce documentation burden, CHA urges the agency to withdraw its payment proposal and engage stakeholders to address the outdated coding system and improve payment accuracy in the future.

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The U.S. Department of Health and Human Services’ (HHS) Office of Inspector General (OIG) has issued the attached request for information seeking recommendations on the anti-kickback statute and barriers it creates for value-based or coordinated care. OIG notes it is interested in how it can modify or add new safe harbors to the anti-kickback statute. OIG also seeks comments on how it might modify exceptions to the beneficiary inducements civil monetary penalty definition of “remuneration” to promote care coordination and advance value-based care delivery. Comments are due to HHS by 2 p.m. (PT) on Oct. 26.

CHA is currently analyzing the request for information and asks for additional input from members in anticipation of submitting comments. Feedback should be provided to Alyssa Keefe, vice president federal regulatory affairs, or Jacquelyn Garman, vice president, legal counsel, by Oct. 12.

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CHA has submitted the attached comment letter responding to the Centers for Medicare & Medicaid Services’ (CMS) request for information on how to address the burdens of the physician self-referral law — also known as the Stark Law — as well as feedback on how the law impedes care coordination. In its comments, CHA highlights the obstacles California hospitals and physicians face navigating compensation regulations built for a fee-for-service model. CHA encourages CMS to create or modify compensation exceptions to the Stark Law to enable hospitals and physicians to better coordinate care and improve patient outcomes.

Members are also encouraged to send individual letters to CMS. Responses are due by Aug. 24 and may be submitted electronically. Additional information is available on the CMS website.

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CHA has issued the attached summary, prepared by Health Policy Alternatives, detailing the Centers for Medicare & Medicaid Services’ (CMS) proposed rule that would make significant changes to the Medicare Shared Savings Program (MSSP) beginning in July 2019. CHA is currently reviewing the proposed rule and actively soliciting member input for its comment letter, which is due by 2 p.m. (PT) on Oct. 16.  

The updated program would phase out tracks with no financial risk for shared losses and offer two accountable care organization (ACO) tracks. Specifically, CMS proposes a “BASIC track” that would allow eligible ACOs to participate under a one-sided, upside-only agreement for one to two years; after that period, risk levels would be incrementally increased. At the highest level of risk, the BASIC track would qualify as an Advanced Alternative Payment Model under the Quality Payment Program. CMS also would offer an “ENHANCED track” based on the program’s existing Track 3. Both tracks would include agreement periods of no fewer than five years.

The current Track 1, Track 1+ and Track 2 would be discontinued for future applications.

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The Centers for Medicare & Medicaid Services (CMS) has issued the attached proposed rule that would make significant changes to the Medicare Shared Savings Program (MSSP) beginning in July 2019. The updated program would phase out tracks with no financial risk for shared losses and offer two accountable care organization (ACO) tracks.

Specifically, CMS proposes a “BASIC track” that would allow eligible ACOs to participate under a one-sided, upside-only agreement for one to two years; after that period, risk levels would be incrementally increased. At the highest level of risk, the BASIC track would qualify as an Advanced Alternative Payment Model under the Quality Payment Program. CMS also would offer an “ENHANCED track” based on the program’s existing Track 3. Both tracks would include agreement periods of no fewer than five years.

The current Track 1, Track 1+ and Track 2 would be discontinued for future applications. CMS proposes a six-month extension for current ACOs with agreements that expire Dec. 31, 2018, along with a special one-time start date of July 1, 2019. Applications for new participation options would be accepted in spring 2019.

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CHA has released the attached summary of the calendar year 2019 physician fee schedule (PFS) proposed rule, which also outlines proposed provisions implementing the third year of the Quality Payment Program (QPP) for physician payment.

The summary provides detailed information on a number of proposed policies, including payment for non-excepted off-campus provider departments, reduced administration burden for evaluation and management services, a reduction of payment for new Part B drugs and the implementation of Bipartisan Budget Act of 2018 provisions related to therapy and telehealth services.

The summary also details proposed updates to the Merit-based Incentive Payment System (MIPS) under the QPP, including an expanded definition of MIPS-eligible clinicians, a reduction of the MIPS measure set and proposed testing of the Medicare Advantage Qualifying Payment Arrangement Incentive Demonstration.

Comments on the proposed rule are due Sept. 10 by 2 p.m. (PT).

CHA will host a member forum on Aug. 30 at 10:30 a.m. (PT) in anticipation of submitting comments.

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The Centers for Medicare & Medicaid Services (CMS) regularly provides important updates about post-acute care quality reporting programs (QRPs), including training opportunities, public reporting, and reminders of data submission and review deadlines.  

Inpatient Rehabilitation Facilities 
QRP training
CMS will host two webinars for inpatient rehabilitation facilities (IRFs) on proper coding of Section M Skin Conditions (Pressure Ulcer/Injury) and Section N of the IRF Patient Assessment Instrument Version 2.00. Updated reporting requirements for Sections M and N became effective on Oct. 1 for IRF providers. See the IRF Quality Reporting Training web page for details.   

Long-Term Acute Care Hospitals  
Provider preview reports
CMS has informed long-term acute care hospitals (LTCHs) that previous provider preview reports for the Discharge to Community – PAC measure contained an error. Preview data released in June 2018 incorporated only seven of eight required quarters of data. Data from October through December 2016 were inadvertently omitted.

CMS has reissued the LTCH provider preview reports, and corrected reports are now available via CASPER system folders. LTCH providers have until Aug. 31 to preview the corrected data in advance of public reporting for the September 2018 LTCH Compare Refresh.