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.
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CHA’s annual members-only Labor and Employment Law Seminar begins Monday in Sacramento. Also held Oct. 25 in Costa Mesa, the program will cover a diverse array of topics impacting human resources personnel, legal counsel and risk managers, nursing directors and others. Participants will learn about the latest developments in wage and hour law, wrongful discharge and employment discrimination, determining exempt status for hospital information technology staff, and co-employment issues.
In addition, program faculty will discuss how to conduct effective workplace investigations and update attendees on federal and state legislation. For complete information and to register, visit www.calhospital.org/labor-employment.
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The Centers for Medicare & Medicaid Services (CMS) formally has formally withdrawn a number of proposed rules, including the Medicare Part B Prescription Drug Model that was opposed by CHA and not finalized by the Obama Administration. In addition, CMS withdrew a proposed rule that would have specified qualifications practitioners must meet to furnish and fabricate prosthetics and custom-fabricated orthotics. In comments on the proposed rule, CHA urged CMS to withdraw the proposal and is pleased to see the agency do so.
Finally, CMS also withdrew a proposed rule that would have revised certain conditions of participation for health care providers, conditions for coverage for suppliers, and requirements for long-term care facilities to revise certain definitions and patients’ rights provisions to ensure they are consistent with the Supreme Court decision in United States v. Windsor. CMS believes that a subsequent Supreme Court decision on same-sex marriage, Obergefell v. Hodges, “has addressed many of the concerns raised” in the original rule.
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FFY 2019 Uncompensated Care Payments to Come From 2014, 2015 Worksheet S-10 Data: Worksheet S-10 audits have begun for select hospitals (September 2018)
S-10 Audit Letters
CHA Executive Briefing (October 16, 2017)
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Attached are the PowerPoint slides from the October 3 CHA Member Forum on the proposed rule cancelling EPMs and making revisions to CJR.
Background
On October 6, 2014, the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act) was signed into law. The Act requires post-acute care (PAC) providers — including long-term care hospitals (LTCHs), skilled-nursing facilities (SNFs), inpatient rehabilitation facilities (IRFs) and home health agencies (HHAs) — to submit standardized data using specific reporting tools.
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The Centers for Medicare & Medicaid Services (CMS) has updated its instructions for Worksheet S-10. The update, attached, clarifies definitions and instructions for uncompensated care, non-Medicare bad debt, non-reimbursed Medicare bad debt and charity care to include uninsured discounts. It also modifies the calculation relative to uncompensated care costs. The changes are effective for cost reporting years from Oct. 1, 2013, onward. CHA is currently reviewing the revisions and will provide members with more detail in the coming weeks.
In addition, CMS has extended the deadline for hospitals to revise and submit amended cost reports for federal fiscal years (FFY) 2014 and 2015 from Sept. 30 to Oct. 31. 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. More information is available in the attached MLN Matters article.
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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.
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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.
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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
