CHA Association Supporter

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The Centers for Medicare & Medicaid Services’ Comprehensive Care for Joint Replacement (CJR) is a nationwide mandatory episode payment model impacting 135 California hospitals in three metropolitan service areas. The program was effective April 1.

To help participating hospitals and their staff understand the clinical and financial risks associated with the program, CHA developed the Implementing CJR — Strategies for Success seminar. The program will be held on Oct. 25 from 8:30 a.m. – 4 p.m. in Los Angeles.

This comprehensive program will provide participants with the knowledge needed to manage patient care, foster physician alignment and develop effective partnerships with post-acute care providers. 

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CHA has submitted the attached draft comment letter on the proposed Medicare Outpatient Observation Notice (MOON) form and its instructions. The MOON fulfills the Notice of Observation Treatment and Implication for Care Eligibility (NOTICE) Act’s requirement that hospitals and critical access hospitals provide written and oral notification to all Medicare-eligible beneficiaries receiving observation services as outpatients for more than 24 hours. The Office of Management and Budget (OMB) is accepting comments on the updated MOON and instructions through Sept. 1.

In the letter, CHA strongly urges several changes, including changing the free-text box that requires hospitals to complete the statement “you are not an inpatient because…” to a standardized statement about observation status. In addition, CHA urges a delay in implementation and/or enforcement to ensure hospitals have ample time to train staff, update procedures and integrate the form into electronic health records.

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The United Network for Organ Sharing (UNOS) has proposed changes to the geographic regions for liver transplants to better match organ supply with demand and make access more equitable. UNOS proposes establishing eight liver distribution districts nationwide, instead of the current 11, to create a better balance between organ availability and the number of patients waiting.

CHA believes that the current organ transplantation system, which arbitrarily favors certain zip codes and those with financial means, must be reformed to make the process more equitable.

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The Office of Management and Budget (OMB) will accept comments on the updated Medicare Outpatient Observation Notice (MOON) and instructions through Sept. 1. The fiscal year 2017 inpatient prospective payment system final rule implemented the Notice of Observation Treatment and Implication for Care Eligibility (NOTICE) Act, which requires hospitals and critical access hospitals to provide written and oral notification to Medicare beneficiaries receiving observation services as outpatients for more than 24 hours. Under the final rule, the notification requirements will take effect no later than 90 calendar days after the updated MOON is approved by OMB.CHA will host a member forum on Aug. 23 from 10-11 a.m. (PT) to discuss the proposed notice and development of CHA’s comments. To register for the forum, select “Read more.”

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The Food and Drug Administration (FDA) has issued draft guidance on insanitary compounding, attached below. The goal of the FDA’s guidance is help  drug compounding facilities identify insanitary conditions, which can result in serious harm to patients. Comments on the draft guidance are due on October, 3 2016. 

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CHA has prepared the attached slide deck that provides a step-by-step understanding of the payment methodology for the Comprehensive Care for Joint Replacement (CJR) model. The slides include illustrative examples of how hypothetical hospitals would perform for reconciliation payments. CHA encourages members participating in the CJR model to review the slides, as well as other program resources CHA has made available at www.calhospital.org/resource/cjr-payment-model-final-rule-resources. 

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CHA has submitted the attached  comment letter on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule that would test new mandatory Medicare payment models for covered Part B prescription drugs provided in physician offices, hospital outpatient departments and certain drugs furnished through durable medical equipment (DME). While CHA appreciates that CMS is paying attention to the growing national crisis of rising drug prices, we believe the proposed demonstration will have unintended consequences — namely, incentivizing inappropriate shifts in care settings for beneficiaries and overpaying for low-cost drugs. CHA urges CMS to exclude hospital outpatient departments from the demonstration, scale back the size and scope of phase one of the demonstration, and propose phase two of the demonstration through a formal regulatory process with notice and comment. CHA urges members to use the comment letter to inform and submit their own comments. Comments are due May 9 by 2 p.m. (PT) and can be submitted at www.regulations.gov.  

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CHA reminds members to register for a member forum on April 29 from 11 a.m. – noon (PT) on the proposed rule implementing mandatory payment models for covered Part B prescription drugs provided in physician offices, hospital outpatient departments and certain drugs furnished through durable medical equipment. The proposed five-year model would first test whether lowering the current Part B drug add-on payment would push prescribing incentives toward lower-cost drugs, and would later expand to include testing of value-based purchasing models for Part B drugs. Participants should register by noon April 28 at www.surveymonkey.com/r/partbdrugmodel. Dial-in information and materials will be distributed by close of business on April 28.