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OMB Accepting Comments on Updated MOON Through Sept. 1

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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.”

FDA Releases Guidance on Insanitary Compounding

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The Food and Drug Administration (FDA) has issued draft guidance on insanitary compounding, attached below.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 Comments on the draft guidance are due on October, 3 2016. 

CHA Submits Letter to HHS Calling for Liver Allocation Reform

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In the attached letter to Department of Health and Human Services (HHS) Secretary Sylvia Burwell, CHA emphasizes the ongoing geographic disparities in access to liver transplantation. The current liver allocation methodology, which is based on 58 local donation service areas (DSAs), puts Californians seeking livers at a significant disadvantage compared to patients in other parts of the nation. California transplants 27 liver patients per 100 patient years of waitlist time, though the national rate is 42 patients per 100 patient years. 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. CHA calls on HHS to adopt the United Network for Organ Sharing’s policy recommendations, which would consolidate the 58 DSAs into four to eight sharing districts, with each district containing at least six liver transplant centers and a maximum median transplant-volume-weighted transport time between DSAs of no more than three hours.

CHA Provides Step-by-Step Examples of CJR Model Payment Methodology

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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. 

CHA Submits Comment Letter on Proposed Part B Prescription Drug Demonstration

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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.  

Register for CHA Member Forum on Part B Prescription Drug Model Proposed Rule

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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.

House Committee Votes to Cut Health Care Spending by $25 Billion

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As part of the House budget resolution process, the Energy and Commerce Committee announced earlier today  the Common Sense Savings Act of 2016 (H.R. 4725), legislation introduced by Health Subcommittee Chairman Joe Pitts (R-PA) to reduce the federal deficit by almost $25 billion through cuts to Medicaid, the Children’s Health Insurance Program (CHIP) and the Prevention and Public Health Fund. The legislation, opposed by CHA, would:

Eliminate the enhanced federal Medicaid matching funds available for the coverage of prisoners as a result of the Affordable Care Act’s Medicaid expansion.  States would continue to be allowed to receive federal funds for Medicaid coverage for prisoner inpatient services, but at the traditional federal matching rate.
Reduce the amount of the non-federal share that can come from providers by gradually reducing the Medicaid provider tax threshold from its current 6 percent of the net patient service revenues to 5.5 percent (the amount that was in place until Oct. 1, 2011).
Eliminate the 23 percentage point increase in the CHIP matching rate implemented in the Affordable Care Act.
Repeal the Prevention and Public Health Fund, which amounts to more than $14 billion over the next 10 years.
Close a loophole in a current statute that has allowed lottery winners to retain taxpayer-financed Medicaid coverage.

Resources for CJR Program Available

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Last year, the Centers for Medicare & Medicaid Services (CMS) finalized its Comprehensive Care for Joint Replacement (CJR) payment model. Starting April 1, the program will be mandatory for Los Angeles-Long Beach-Anaheim, Modesto and San Francisco-Oakland-Hayward hospitals that are not already participating in the bundled payment care initiative. In addition to the CJR Connect website, which CMS hopes to make available soon, the agency has scheduled a series of webinars aimed at helping providers prepare for the new program. Upcoming webinars, all scheduled for noon to 1 p.m. (PT), are March 10, focusing on quality measures and voluntary reporting; March 15, focusing on preparing for and key details about the program; and March 17, focusing on quality measures and quality composite scores.
Registration links for the webinars have been sent to primary points of contact at each affected CJR hospital but can also be obtained by contacting cjrsupport@cms.hhs.gov. CJR program details — including model background documents, a list of hospitals and other materials — can be found at https://innovation.cms.gov/initiatives/cjr. 

CHA Responds to Information Request on Certification of eCQMs

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CHA has submitted the attached response to the Centers for Medicare & Medicaid Services (CMS) request for information on the certification of health information technology (HIT). In conjunction with the Office of the National Coordinator, CMS sought input on electronic health records products used for reporting electronic clinical quality measures (eCQMs), specifically requesting feedback on how often to require recertification of HIT modules, the number of eCQMs a certified HIT module should be required to certify to, and ways to improve module testing.

In comments, CHA urged CMS to complete a full and transparent evaluation of the current state of eCQM development in order to inform future rulemaking, and to develop a strategic, long-term, detailed measurement strategy with clear goals for identifying appropriate eCQMs. In response to CMS’ specific questions, CHA urged CMS to require recertification of HIT modules each time a new eCQM is added to a program. CHA also believes that CMS should require certification of all eCQMs used in all CMS programs, and that certification should occur in advance of the measures’ adoption into the program. Finally, CHA stressed the need for a robust testing process for each eCQM.

Recording Available From Member Call on CJR Model Final Rule

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CHA hosted a members-only call Jan. 13 to discuss the Centers for Medicare & Medicaid Services’ Comprehensive Joint Replacement (CJR) model final rule. CHA reviewed key provisions of the final rule and fielded questions from participants during the call, which was recorded in its entirety and is now available for members on CHA’s website. The link also contains presentation slides and additional resources related to CJR.