On Sept. 27, CHA submitted the attached comments on the Enhancements of the Overall Hospital Quality Star Ratings report, which proposed improvements to the overall star rating methodology.
In the letter, CHA urges CMS to remove the hospital star ratings until all comments are responded to and errors are addressed. CHA also shares concerns about CMS using the contractor who developed and implemented the five star methodology to also conduct the evaluation of it.
CHA strongly supports alternative approaches to an overall five star rating, as well as the proposal to remove hospitals that do not meet the public reporting thresholds for measures from its k-means clustering analysis, which adversely affects the star ratings categories.
CHA also supports CMS’ proposal to run the k-means clustering analysis to convergence, ensuring that each observation within a cluster is more similar to the other observations within that cluster than to observations in the other clusters.
CHA is pleased that CMS has announced it is postponing the October 2017 update of its Overall Hospital Quality Star Ratings as it continues to examine potential changes to the methodology based on public feedback. While data from the October Star Ratings Preview Reports will not be published on Hospital Compare, Star Ratings released in December 2016 will remain on the site until the next update.
The Centers for Medicare & Medicaid Services (CMS) has issued the attached request for information seeking stakeholder input on potential new models that could be tested by its Center for Medicare & Medicaid Innovation (CMMI). Specifically, CMS seeks input on a new direction for CMMI to promote patient-centered care and test market-driven reforms that empower beneficiaries as consumers, provide price transparency, increase choices and competition to drive quality, reduce costs and improve outcomes.
CMS provides information on eight areas it is interested in testing new models for: increased participation in advanced alternative payment models; consumer-directed care and market-based innovation models; physician specialty models; prescription drug models; Medicare Advantage innovation models; state-based and local innovation, including Medicaid-focused models; mental and behavioral health models; and program integrity. Comments can be submitted online or via email to CMMI_NewDirection@cms.hhs.gov by 8:59 p.m. (PT) on Nov. 20.
CHA DataSuite has provided member hospitals and health systems with a hospital-specific analysis showing how Medicare inpatient fee-for-service payments will change from federal fiscal year (FFY) 2017 to FFY 2018 based on the policies in the Centers for Medicare & Medicaid Services’ (CMS) FFY 2018 inpatient prospective payment system (IPPS) final rule. The analysis compares the year-over-year changes in operating, capital and uncompensated care IPPS payments. It also includes breakout sections with detailed insight into specific policies that influence IPPS payment changes, including:
Potential penalties under the Inpatient Quality Reporting and Electronic Health Record Incentive programs
Expiration of the Medicare Dependent Hospital and expanded Low-Volume Hospital Adjustment programs
Quality-based payment adjustments
Disproportionate share hospital (DSH) uncompensated care (UCC) payments
CMS’ transition to the Medicare Cost Report Worksheet S-10 for UCC payments for FFY 2018
CHA has released the attached summary, prepared by Health Policy Alternatives, on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule that would cancel the episode payment models (EPMs) and the cardiac rehabilitation incentive payment model scheduled to begin Jan. 1, 2018.
The rule also proposes to revise aspects of the ongoing Comprehensive Care for Joint Replacement (CJR) model involving mandatory hospital participation, Track 1 clinician eligibility, reconciliation calculation and telehealth service payment.
CMS proposes to reduce the number of mandatory metropolitan statistical areas (MSAs) to include 34 continued mandatory MSAs and 33 voluntary (formerly mandatory) participation MSAs, including two in California: Modesto and San Francisco-Oakland-Hayward. The Los Angeles-Long Beach-Anaheim MSA remains on CMS’ list for mandatory participation.
CHA has submitted the attached comment letter on the Centers for Medicare & Medicaid Services (CMS) advance notice of proposed rulemaking (ANPRM) outlining potential revisions to the skilled-nursing facility (SNF) prospective payment system (PPS) case-mix methodology. Overall, CHA supports CMS’ proposal to revise the SNF PPS to more closely align with patients’ medical and rehabilitative needs, and to reflect the intensity of services provided to medically complex patients. Additionally, CHA requests that CMS take steps to include adequate controls and oversight to ensure that patients continue to receive medically necessary services. CHA also urges CMS to adopt a budget-neutral approach and include a transition period for implementation of associated reimbursement changes.
The Centers for Medicare & Medicaid Services’ (CMS’) federal fiscal year (FFY) 2018 inpatient prospective payment system final rule establishes changes to fund distribution for Medicare disproportionate share hospital (DSH) uncompensated care (UCC) payments. CMS determined that it will phase-in payments based on information collected from Line 30 on the S-10 Worksheet of the Medicare cost report to determine the UCC payment factor, starting with FFY 2014 cost reports for DSH UCC payments in FFY 2018.
As previously reported in CHA News, hospitals may submit revisions to Worksheet S-10 of their Medicare cost report for FFYs 2014 and 2015. CHA urges members to review Worksheet S-10 of their FFY 2014 and 2015 cost reports and submit amendments to their respective Medicare administrative contractors before the Oct. 31 deadline.
The Centers for Medicare & Medicaid Services (CMS) has issued the attached proposed rule that would cancel the episode payment models (EPMs) and the cardiac rehabilitation incentive payment model, scheduled to begin Jan. 1, 2018. The proposed rule would also reduce the number of mandatory metropolitan statistical areas (MSAs) participating in the Comprehensive Care for Joint Replacement (CJR) model, including two in California: Modesto and San Francisco-Oakland-Hayward. Los Angeles-Long Beach-Anaheim remains on CMS’ list of MSAs for mandatory participation.
In addition, CMS proposes to exempt rural hospitals and low-volume hospitals located in the mandatory participation MSAs from required participation in the CJR model beginning in February 2018, and allow them instead to make a one-time voluntary participation election.
Overview
We appreciate your participation as faculty for an upcoming CHA education program. Our programs are valuable to our members, in large part, because of the efforts and contributions from our stellar faculty.
Today, the Centers for Medicare & Medicaid Services (CMS) issued its final rule updating the inpatient and long-term care hospital prospective payment systems (PPS) for federal fiscal year (FFY) 2018.
For inpatient PPS hospitals, CMS finalized a market-basket update of 2.7 percent, reduced by a negative 0.6 percent productivity adjustment and the negative 0.75 adjustment required by the Affordable Care Act (ACA), as well as a cut of 0.6 percent to remove the one-time, temporary adjustment that it made in FFY 2017 to restore the unlawfully instituted two-midnight policy cuts. In addition, CMS finalized an increase of 0.4588 percent, as required by the 21st Century Cures Act, to partially restore cuts made as a result of the American Taxpayer Relief Act of 2012. CMS estimates total Medicare spending on inpatient hospital services will increase by approximately 1.2 percent, or $2.4 billion, as compared to FFY 2017.
The final rule also implements ACA-mandated Medicare disproportionate share hospital (DSH) reductions. Despite CHA's strong opposition, CMS has adopted its proposed Medicare DSH policy with slight modifications. CMS will proceed in implementing a three-year transition period, beginning in FFY 2018, during which it will utilize a blend of the current proxy and uncompensated care cost data from Worksheet S-10 of the Medicare cost report in the methodology for distributing Medicare DSH uncompensated care payments. CMS did, however, modify the trim methodology and comments on aberrant data. CHA is currently analyzing those provisions.
The Centers for Medicare & Medicaid Services (CMS) has issued the attached proposed rule updating the physician fee schedule (PFS) for calendar year (CY) 2018. The proposed rule includes a number of provisions that will impact hospitals, including a proposal to reduce payments to non-excepted, off-campus provider-based departments to 25 percent, rather than 50 percent, of the outpatient prospective payment system (OPPS) rates. That provision is described in more detail in CHA’s overview of the CY 2018 OPPS proposed rule. Under the PFS, CMS proposes a total increase in payment rates of 0.31 percent for CY 2018, which includes a 0.5 percent update as required by the Medicare Access and CHIP Reauthorization Act 2015, adjusted for a misvalued code as required under the Achieving a Better Life Experience Act of 2014.
Other provisions that will impact hospitals are:
Telehealth Services: CMS proposes to add a number of codes to the list of Medicare-payable telehealth services, including psychotherapy for crisis, health risk assessments, care planning for chronic care management, interactive complexity and counseling visits to determine low dose computed tomography eligibility.
