The Centers for Medicare & Medicaid Services (CMS) issued the attached guidance to Medicare administrative contractors (MACs) on accepting fiscal year (FY) 2015 amended cost reports from hospitals requesting to revise Worksheet S-10. The guidance is issued in conjunction with CMS’ FY 2018 inpatient prospective payment system (IPPS) proposed rule, which proposes to utilize Worksheet S-10 data for calculating Medicare disproportionate share hospital (DSH) payments beginning in FY 2018. CMS states that amended cost reports received on or before Oct. 31 must be accepted by the MAC. If amended cost reports are submitted after Oct. 31, the MAC should follow normal timelines and procedures, including rejection of the cost report.
CHA urges members that wish to revise Worksheet S-10 of their FY 2015 cost report to do so before the Oct. 31 deadline, as the IPPS final rule is expected to be released in early August. While CHA continues to oppose the use of Worksheet S-10 data in Medicare DSH calculations, members should note that revisions to the cost report will be time-sensitive should CMS finalize its proposed policy.
The Medicare Payment Advisory Commission (MedPAC) released its June 2017 Report to the Congress: Medicare and the Health Care Delivery System. The document includes 10 chapters covering key issues facing the Medicare program and offers solutions to ensure the program’s continued viability.
In its June report the commission continues its work, required by the Improving Medicare Post-Acute Care Transformation (IMPACT) Act, evaluating the feasibility of a unified prospective payment system (PPS) spanning post-acute care (PAC) settings (e.g., skilled-nursing facility, inpatient rehabilitation facility, long-term care hospital and home health agency). After determining a unified PPS is feasible in its 2016 report, the commission studied three implementation issues: a transition period with blended setting-specific and unified PPS rates, appropriate levels of aggregate PAC payments, and ways to address ongoing refinements to the system after implementation. MedPAC recommends that a unified PAC PPS be implemented beginning in 2021 with a three-year transition, and that aggregate payments should be reduced by 5 percent.
CHA has issued the attached summary, prepared by Health Policy Alternatives, of a recent Centers for Medicare & Medicaid Services (CMS) advance notice of proposed rule-making (ANPRM) outlining potential revisions to the skilled-nursing facility (SNF) prospective payment system (PPS) case-mix methodology. CMS seeks feedback on the changes, which it is considering including in federal fiscal year (FFY) 2019 rulemaking.
CMS proposes to replace the current resource utilization groups (RUGs) case-mix system with a new methodology, the Resident Classification System, Version l (RCS-I). RCS-I would aim to pay SNFs accurately based on beneficiary complexity and required care, and avoid incentivizing therapy delivery by payment policy. Notably, the therapy component would be case-mix adjusted based on resident performance on selected functional status measures, rather than on documented therapy utilization. Additionally, CMS proposes to create a non-therapy ancillary services component, separate from the nursing component.
The Centers for Medicare & Medicaid Services (CMS) has issued the attached final rule delaying until Jan. 1, 2018, implementation of its new mandatory episode-based payment model (EPM) for cardiac care and expansion of the current Comprehensive Care for Joint Replacement (CJR) model to include surgical hip/femur fracture treatment (SHFFT) excluding lower extremity joint replacement. Previously, CMS issued an interim final rule with comment period that delayed implementation until Oct. 1, 2017. In comments on the interim final rule, CHA urged CMS to further delay implementation of the cardiac EPM and CJR SHFFT episodes until Jan. 1, 2018, and is pleased CMS has responded to stakeholder concerns. CHA also offered a number of other policy issues to consider as the agency proceeds in testing EPMs. In the final rule, CMS notes that it will not respond to comments outside the scope of the delay, but may address these comments in future rulemaking. Additional resources on EPMs are available on CHA’s dedicated resource page.
The Centers for Medicare & Medicaid Services (CMS) requests comments on the attached advanced notice of proposed rulemaking addressing revisions to the skilled-nursing facility (SNF) prospective payment system (PPS) methodology. Specifically, CMS seeks feedback on replacing the existing case-mix classification model — the Resource Utilization Groups, Version 4 — with a new model, the Resident Classification System, Version I. The proposal is based on recent CMS payment models research and is designed to address concerns that incentives in the current SNF PPS have led to overutilization of therapy services and resulting classification of patients into higher payment categories. Comments are due August 25.
CHA has submitted the attached comment letter on the Centers for Medicare & Medicaid Services’ (CMS) interim final rule delaying implementation of certain episode payment models (EPMs) from July 1 to Oct. 1. The EPMs delayed by the interim final rule include those focused on episodes of care for acute myocardial infarction, coronary artery bypass graft and surgical hip/femur fracture treatment (SHFFT) excluding lower extremity joint replacement, as well as the Cardiac Rehabilitation Incentive Payment Model. CHA supports the delay and offers CMS a number of other policy issues to consider as the agency proceeds in testing EPMs.
The Centers for Medicare & Medicaid Services (CMS) has issued the attached interim final rule with comment period delaying, by three months, implementation of its new mandatory episode-based payment model (EPM) for cardiac care and expansion of the current Comprehensive Care for Joint Replacement (CJR) model to include surgical treatments for hip and femur fractures beyond hip replacement. The interim final rule, which was issued to give the Trump Administration additional time to review the original final rule consistent with the administration’s regulatory freeze, delays the implementation date of these models from July 1 to Oct. 1. It also further delays certain provisions for a second time, from March 21 to May 20. In addition, CMS seeks comments on the appropriateness of the delay, and whether implementation of the new models should be delayed further until Jan. 1, 2018.
CHA anticipates that CMS will make fairly significant modifications to these programs through separate rulemaking in the very near future, and will respond during this 30-day comment period. As providers await more details from CMS, CHA is interested in learning from members about the programs’ opportunities and challenges and changes that are needed. Contact Alyssa Keefe, CHA vice president, federal regulatory affairs, at akeefe@calhospital.org or (202) 488-4688 with feedback.
CHA reminds hospitals participating in the Comprehensive Care for Joint Replacement (CJR) Model to provide the Centers for Medicare & Medicaid Services (CMS) with a list of previous and current CJR collaborators as of Feb. 28. Participating hospitals are required to provide CMS with “evidence sufficient to enable the audit, evaluation, inspection, or investigation of the individual’s or entity’s compliance with CJR requirements, the quality of services furnished, the obligation to repay any reconciliation payments owed to CMS, or the calculation, distribution, receipt, or recoupment of gainsharing payments, alignment payments, or distribution payments.” CJR participant hospitals should complete the attached Excel form and submit to CJRsupport@cms.hhs.gov by 5 p.m. (PT) on March 21.
CHA has submitted the attached comment letter on the Centers for Medicare & Medicaid Services (CMS) proposed rule specifying necessary qualifications practitioners must meet to furnish and fabricate prosthetics and custom-fabricated orthotics. Noting that the proposed rule would impose additional burden on hospitals, and is inconsistent with the Trump Administration’s commitment to reducing regulatory burden, CHA urges CMS to withdraw rather than finalize the proposed rule. If CMS moves forward in finalizing the rule, CHA urges CMS to make changes to its proposed policies. Specifically, CHA urges CMS to exempt occupational and physical therapists from certain certification requirements and to make changes to its fabrication facility requirements. Comments on the proposed rule are due March 13 by 5 p.m. (PT).
Yesterday, CHA met with representatives from the Centers for Medicare & Medicaid Services (CMS) at its headquarters in Baltimore to discuss the Medicaid managed care rules finalized in May 2016 and January 2017 and, specifically, their impact on the Quality Assurance Fee (QAF) program.
