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CHA seeks member input on a Centers for Medicare & Medicaid Services (CMS) proposed rule specifying necessary qualifications practitioners must meet to furnish and fabricate prosthetics and custom-fabricated orthotics. The rule would also address the qualifications and accreditation requirements suppliers must meet in order to fabricate and bill for the same devices. In addition, the rule sets forth a time frame by which qualified practitioners and suppliers must meet the rule’s requirements. CHA is developing its comment letter and seeks input from members on how the provisions in this proposed rule would impact their operations. Comments and questions should be directed to Megan Howard, CHA senior policy analyst, at mhoward@calhospital.org.

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On Jan. 20, the Trump Administration issued a memo to the heads of all executive departments and agencies freezing new and pending federal regulatory activity until the President’s appointees or designees have had the opportunity to review any new, recently finalized or pending regulations. The memo, which is common for an incoming administration, addresses regulations that have been sent to the Office of the Federal Register but not yet published, as well as regulations that have been published in the Federal Register but were not yet effective on Jan. 20.

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The Centers for Medicare & Medicaid Services has published the attached Medicare Learning Network Matters article about the waiver of the three-day qualifying stay for post-hospital care provided in a skilled-nursing facility (SNF) under the Comprehensive Care for Joint Replacement model. The article addresses policies related to the waiver and how services should be billed, and describes conditions that must be met for coverage of the SNF stay.

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The Centers for Medicare & Medicaid Services (CMS) has issued the attached final rule implementing the Physician Quality Payment program as required by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). In response to comments from CHA and other stakeholders, CMS has finalized a number of changes that increase flexibility for the Merit-based Incentive Payment System (MIPS) and for qualifying for incentive payments through participation in advanced alternative payment models (APMs).

Among the changes finalized, CMS has codified its previous announcement that physicians will be able to pick their own pace under MIPS for the 2017 transition year. Specifically, CMS will allow MIPS-eligible clinicians to avoid a negative payment adjustment by submitting a minimum amount of data (for example, one quality measure or one improvement measure). CMS has also finalized an option of a continuous 90-day MIPS reporting period that would allow clinicians to receive a neutral or modest payment increase, depending on performance. Clinicians who choose to report for more than 90 days up to a full year would be eligible for moderate positive payment adjustments.

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CHA has developed a seminar to help participating hospitals and their staff understand the clinical and financial risks associated with the Centers for Medicare & Medicaid Services’ (CMS) Comprehensive Care for Joint Replacement (CJR) program. Implementing CJR —Strategies for Success will be held on Oct. 25 from 8:30 a.m. – 4 p.m. in Los Angeles.

The nationwide mandatory episode payment model, which took effect April 1, impacts 135 California hospitals in three metropolitan service areas. The Implementing CJR—Strategies for Success seminar will provide participants with the knowledge needed to manage patient care, foster physician alignment and develop effective partnerships with post-acute care providers. The program features state and national faculty, each with an area of expertise in episode care payment models. Session topics include: CJR program overview; using data to identify opportunities and risks; creating or strengthening your post-acute care strategy; legal considerations including collaborator agreements, gainsharing and program waivers; and planning for CJR implementation in your facility.

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The Centers for Medicare & Medicaid Services’ Comprehensive Care for Joint Replacement (CJR) is a nationwide mandatory episode payment model impacting 135 California hospitals in three metropolitan service areas. The program was effective April 1.

To help participating hospitals and their staff understand the clinical and financial risks associated with the program, CHA developed the Implementing CJR — Strategies for Success seminar. The program will be held on Oct. 25 from 8:30 a.m. – 4 p.m. in Los Angeles.

This comprehensive program will provide participants with the knowledge needed to manage patient care, foster physician alignment and develop effective partnerships with post-acute care providers. 

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CHA has submitted the attached draft comment letter on the proposed Medicare Outpatient Observation Notice (MOON) form and its instructions. The MOON fulfills the Notice of Observation Treatment and Implication for Care Eligibility (NOTICE) Act’s requirement that hospitals and critical access hospitals provide written and oral notification to all Medicare-eligible beneficiaries receiving observation services as outpatients for more than 24 hours. The Office of Management and Budget (OMB) is accepting comments on the updated MOON and instructions through Sept. 1.

In the letter, CHA strongly urges several changes, including changing the free-text box that requires hospitals to complete the statement “you are not an inpatient because…” to a standardized statement about observation status. In addition, CHA urges a delay in implementation and/or enforcement to ensure hospitals have ample time to train staff, update procedures and integrate the form into electronic health records.

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The United Network for Organ Sharing (UNOS) has proposed changes to the geographic regions for liver transplants to better match organ supply with demand and make access more equitable. UNOS proposes establishing eight liver distribution districts nationwide, instead of the current 11, to create a better balance between organ availability and the number of patients waiting.

CHA believes that the current organ transplantation system, which arbitrarily favors certain zip codes and those with financial means, must be reformed to make the process more equitable.

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The Office of Management and Budget (OMB) will accept comments on the updated Medicare Outpatient Observation Notice (MOON) and instructions through Sept. 1. The fiscal year 2017 inpatient prospective payment system final rule implemented the Notice of Observation Treatment and Implication for Care Eligibility (NOTICE) Act, which requires hospitals and critical access hospitals to provide written and oral notification to Medicare beneficiaries receiving observation services as outpatients for more than 24 hours. Under the final rule, the notification requirements will take effect no later than 90 calendar days after the updated MOON is approved by OMB.CHA will host a member forum on Aug. 23 from 10-11 a.m. (PT) to discuss the proposed notice and development of CHA’s comments. To register for the forum, select “Read more.”