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CMS Announces Bundled Payments for Care Improvement Advanced Model

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The Centers for Medicare & Medicaid Services (CMS) has announced the creation of a new voluntary advanced alternative payment model called Bundled Payments for Care Improvement Advanced (BPCI Advanced). Under the BPCI Advanced model, participants will take on financial risk for a 90-day clinical episode with a single retrospective bundled payment. CMS has determined the model qualifies as an advanced alternative payment model under the requirements of the Medicare Access and CHIP Reauthorization Act for the purposes of payment incentives under the physician Quality Payment Program. The attached request for applications includes additional information on the model, and CMS will hold an open door forum with a question and answer session on Jan. 30 from 9-10 a.m. (PT). Registration is open on CMS’ website.

CHA Provides Update on 2017-19 Hospital Fee Program

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As reported in CHA News last month, the Centers for Medicare & Medicaid Services approved the supplemental fee-for-service payments and overall tax structure of the 2017-19 hospital fee program. CHA is working with the Department of Health Care Services (DHCS) to update the draft model so hospital-specific implementation schedules can be distributed by the end of this month. DHCS expects the first round of invoices will be sent to hospitals within the next month, with a due date in late February. As soon as the exact timing is finalized, CHA will notify members via CHA News.

Now that the fee-for-service component of the program has been approved, DHCS has turned its attention to the managed care components of the program. As previously reported in CHA News, the new federal Medicaid managed care rules require significant changes to how supplemental Medi-Cal managed care payments are made through the hospital fee program. Effective July 1, 2017, roughly half of the supplemental Medi-Cal managed care payments must be transitioned to a directed payment methodology. Under the directed payment method, supplemental payments can be made only to network providers based on utilization in the encounter data file from the current rate year.

Alternative Payment Models

Below are a number of resources to help member hospitals understand the regulatory framework as they move toward development and implementation of one or more alternative payment models (APMs). The information includes:

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Clarification Issued on Revised Worksheet S-10 Instructions

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In response to several questions submitted by CHA and others, as well as questions asked during a recent open door forum, the Centers for Medicare & Medicaid Services has released the attached document clarifying its recently revised instructions for Worksheet S-10 of the Medicare cost report. CHA reminds hospitals that the deadline to submit amended cost reports for federal fiscal years 2014 and 2015 is Jan. 2. Worksheets received by Dec. 2 will be reflected in the cost report data file used to develop federal fiscal year proposed rules. Hospital data submitted after Dec. 2 but by Jan. 2 will be reflected in the cost report data file that is typically used to develop the federal fiscal year final rules. Additional resources for Worksheet S-10 are available on CHA’s website. 

CHA Provides Principles for Alternative Payment Model Design

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CHA has prepared the attached comment letter in response to the Centers for Medicare & Medicaid Services’ request for information on the development of alternative payment models and the future of the Center for Medicare & Medicaid Innovation (CMMI). CHA shares a number of guiding principles toward new model designs that CMMI has offered in its request for information. For example, CHA agrees that there should be a focus on voluntary models that reduce burdensome requirements and unnecessary regulations to allow providers to focus on providing high-quality, patient-centered care. CHA also shares CMMI’s commitment to transparent model design and evaluation and looks forward to continued engagement as CMMI builds on the experiences of previous alternative payment model participation and continues to move Medicare payments from a volume-based system to a value-based system.

House Passes Budget Resolution

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The House narrowly passed the Senate’s fiscal year 2018 budget resolution, House Concurrent Resolution 71, by a vote of 216-212 with 20 Republicans voting “no.” The budget resolution allows Congress to use the reconciliation process, which only requires a majority vote, to move forward on a tax reform bill that could increase the deficit by $1.5 trillion. CHA will continue to monitor tax reform legislation, expected to be unveiled in the coming weeks.

CMS Extends Deadline for Revised Worksheet S-10 Data to Jan. 2

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The Centers for Medicare & Medicaid Services (CMS) has extended the deadline for hospitals to submit amended cost reports for federal fiscal years (FFY) 2014 and 2015 to account for recently issued changes to the instructions for Worksheet S-10. CMS has instructed Medicare administrative contractors to accept revised cost reports until Jan. 2, 2018. Previously, CMS required hospitals to submit this information by Oct. 31. Worksheets received by Dec. 2 will be reflected in the cost report data file that would typically be used to develop FFY proposed rules. However, if a hospital submits data after Dec. 2 but by Jan. 2, 2018, the data will be reflected in the cost report data file that is typically used to develop the FFY final rules.

CHA recently held an executive briefing, featuring faculty from Toyon Associates, to explain the revised instructions to Worksheet S-10 and provide hospitals with the information needed to make decisions on how best to position themselves to improve performance under the revised instructions. A recording of the executive briefing and additional resources on Worksheet S-10 are available on CHA’s website.

Carmela Coyle

Carmela Coyle began her tenure as President & CEO of the California Hospital Association, the statewide leader representing the interests of more than 400 hospitals and health systems in California, in October 2017.

Previously, Coyle led the Maryland Hospital Association for nine years, where she played a leading role in reframing the hospital payment system in Maryland and moving to a value-based methodology. Maryland is now considered a national leader in health care policy and innovation.

Prior to 2008, Coyle spent 20 years in senior policy positions with the American Hospital Association (AHA), including 11 years as the senior vice president of policy, where she served as a national media spokesperson and led AHA’s policy development and strategy planning activities. Earlier in her career, she worked for the Congressional Budget Office in Washington, D.C., advising members of Congress and their staff on the economic and budgetary implications of legislative policy.