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Tragedy in Gilroy

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“My son had his whole life to live and he was only six. That’s all I can say.” – Alberto Romero, father of Gilroy shooting victim Stephen Romero

“I have no words to describe this pain I’m feeling…We just want Keyla to be remembered as someone that is beautiful…She really cared a lot about other people. She loved animals. She had big dreams and aspirations and her life was cut short.” – Katiuska Pimentel Vargas, aunt of 13-year-old Gilroy shooting victim Keyla Salazar

CMS Issues CY 2020 Physician Fee Schedule Proposed Rule

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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.

CMS Issues FFY 2020 Inpatient Rehabilitation Facility PPS Final Rule

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The Centers for Medicare & Medicaid Services (CMS) has issued the final rule for the inpatient rehabilitation facility prospective payment system (IRF PPS) for federal fiscal year (FFY) 2020. The provisions will be effective Oct. 1, 2020. According to CMS, this final rule represents continued movement toward the eventual transition to a unified post-acute care (PAC) PPS. 

Below are highlights of the final rule.  

Payment Impact
As provided in the FFY 2019 final rule, CMS will reform the current IRF patient assessment and case-mix  process by discontinuing the use of the functional independence measure (FIM), and instead incorporating similar data elements contained in Section GG of the IRF patient assessment instrument (IRF-PAI) for the purpose of assigning patients to a payment category, or case-mix group (CMG).  Notably, in response to comments, CMS opts not to adopt a weighted motor score for CMG calculation.  

The final rule updates the CMG relative weights and average length of stay values, and uses concurrent inpatient prospective payment system (IPPS) wage index data to align wage index data across settings of care.  Overall, CMS projects that payments to IRFs will increase by 2.5%, or $210 million, as compared to FFY 2019, the result of a 2.9% market basket update, offset by statutorily mandated 0.4% cut for productivity. 

Quality Reporting/SPADEs
CMS finalizes several proposals relating to the IRF Quality Reporting Program (QRP), including the addition of several standardized patient assessment data elements (SPADEs), several of which address social determinants of health. CMS also finalizes two new measures on transfer of health information, as well as a change to the existing “Discharge to Community” measure to exclude baseline nursing home residents. In response to comments, CMS does not finalize its proposal to collect IRF QRP data on all patients regardless of payer source. 

2020 Conference Theme & Program Schedule Questionnaire

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Thank you for participating in the planning of the 2020 California Hospital Volunteer Leadership Conference. Your feedback related to the conference theme and program schedule is requested. Please review the draft program schedule (see email) to help guide your responses.

Controller

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The California Hospital Association is seeking a full-time, seasoned Controller to oversee day-to-day accounting operations. Our association is the leading voice representing California’s hospitals before state and federal legislators and regulators in our work to advance better health for all Californians.

This role is a key position at CHA and will have functional responsibility over accounting, accounts payable, accounts receivable, grant administration, and reporting activities. This position reports directly to the Chief Financial Officer and supervises a staff of nine.

Livestreaming Expands Hospitals’ Opportunity to Benefit From Disaster Planning Conference

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For the first time, CHA members will be able to livestream the Disaster Planning for California Hospitals conference — taking place Sept. 10-11 in Pasadena — hearing and viewing the conference from the convenience of their own office or conference room. The livestream option allows multiple people to experience the conference with a single registration fee and no lodging or transportation expenses.

OSHPD Reminds Hospitals About 2030 Seismic Safety Deadline Attestation

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Last week, the Office of Statewide Health Planning and Development (OSHPD) sent a letter to hospitals that have not yet met the 2030 seismic safety requirements for all of their buildings, reminding them that they are required to submit to OSHPD, by Dec. 31, an attestation that their board of directors is aware of these requirements. The attestation can be sent via email to seismiccomplianceunit@oshpd.ca.gov.

9/11 First Responder Will Speak at CHA Disaster Preparedness Conference

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For the first time, CHA’s Disaster Planning for California Hospitals conference will take place on Sept. 11. To honor those who gave everything they had — and those who continue to put their lives at risk — CHA has invited a Ground Zero 9/11 first responder, Glen Klein, to help us remember how that day has shaped our world.

CMS Issues CY 2020 OPPS Proposed Rule

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The Centers for Medicare & Medicaid Services (CMS) has issued its calendar year (CY) 2020 outpatient prospective payment system (OPPS) proposed rule, including significant proposals related to price transparency and changes to the hospital area wage index (AWI). Specifically, CMS would carry over hospital AWI policies proposed under the federal fiscal year 2020 inpatient PPS (IPPS) proposed rule, applying the finalized inpatient policies to outpatient payments.