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CHA has submitted comments on the Medicare disproportionate-share hospital (DSH) provisions in Section 3133 of the Affordable Care Act (ACA) to the Centers for Medicare & Medicaid Services (CMS). The comments were provided in response to the agency’s request for input following a Jan. 8 National Provider Call on the same topic. In its comment letter, CHA recommends CMS consider, for formal rulemaking, adopting a definition of “uninsured” that includes undocumented individuals; adopting a definition of “uncompensated care” that includes the unreimbursed costs of Medicaid, the Children’s Health Insurance Program and other state and local government indigent care programs; and including graduate medical education costs in calculating cost-to-charge ratios. In addition, CHA urges greater clarity regarding definitions for lines 17 and 18 of Worksheet S-10, and requests excluding revenue streams created in California’s most recent Section 1115 waiver from uncompensated care calculations. For more information, see attached comments. CHA expects CMS to propose policies for implementing both the Medicare and Medicaid DSH provisions in the fiscal year 2014 inpatient prospective payment system proposed rule to be released in April. CHA will convene members to discuss these important provisions during the comment period.
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Gov. Jerry Brown’s 2013-14 state budget proposal, released Jan. 10, includes a delay in implementing the Coordinated Care Initiative (CCI), which will transition individuals eligible for both Medicare and Medi-Cal —dual-eligibles — into managed care. It will also integrate long-term care services and supports into managed Medi-Cal. CCI implementation is now scheduled for September 2013, rather than June 2013 as originally planned. Under the revised timeline, beneficiaries will receive notice of changes no sooner than June 2013. Beneficiary enrollment schedules have also been modified and will vary among the designated counties: in Los Angeles County, enrollment will be phased in over 18 months; in the County of San Mateo, beneficiaries will be enrolled at once; and in Orange County, County of San Diego, County of San Bernardino, County of Riverside, Alameda County, and the County of Santa Clara, enrollment will be phased in over 12 months.
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The Centers for Medicare & Medicaid Services (CMS) has issued a request for information (RFI) on hospital and vendor readiness to report certain clinical quality measures under the hospital inpatient quality reporting program using certified electronic health record (EHR) technology required by the Medicare EHR Incentive Program. In the RFI, CMS asks hospitals to answer a number of questions, including if they plan to adopt EHR certified technology during or before calendar year (CY) 2014; if they are aware of payment adjustments beginning in fiscal year 2015 for failing to demonstrate meaningful use requirements under the EHR Incentive Program; what operational challenges exist to electronically report data, and what tools and methodologies they and their vendors use to validate data. For the full list of CMS questions, see attached RFI. CHA is interested in hearing from hospitals about their experiences implementing clinical quality measures using certified EHRs to inform our response to CMS. Comments can be submitted electronically to CMS at www.regulations.gov and are due Jan. 22 by 2 p.m. (PT).
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CHA has submitted comments to the U.S. Department of Health and Human Services (HHS) in response to a request for information on health plan quality management in health insurance exchanges under the Affordable Care Act. In its comment letter, CHA notes California hospitals’ extensive experience in quality reporting programs at both the state and federal level. CHA also offers HHS several guiding principles to consider as the agency begins the rulemaking process to measure quality in the exchanges.
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The Centers for Medicare & Medicaid Services (CMS) has published a request for information (RFI), seeking comments on health plan quality management in insurance exchanges. The Affordable Care Act requires qualified health plans (QHPs) that participate in insurance exchanges to implement quality improvement strategies, enhance patient safety through specific contracting requirements and publicly report quality data. CMS seeks comments on the current landscape of quality improvement strategies and how applicable these strategies are to the health insurance exchange marketplace. The RFI also provides the opportunity for stakeholders to recommend the most effective ways to enhance and align quality reporting and display requirements for QHPs beginning in 2016. Comments on the RFI are due Dec. 27 and can be submitted at www.regulations.gov. For more information, see attached RFI.
Delma Giroski brings to CHA a wealth of human resources generalist expertise with an emphasis in employee relations and recruitment of high-quality employees. Playing a major role in all aspects of the human resources department, she successfully serves as an advocate to both the association and its employees, resulting in an atmosphere that promotes growth, communication and effective leadership.
Delma has extensive experience in benefits management and immigration as gained through her previous roles with technology and e-business solutions corporations, and professional associations.
Delma completed the Professional In Human Resources (PHR) Certification in 2007, and is a member of the Society for Human Resource Management and Sacramento Area Human Resource Association.
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The House Appropriations Subcommittee on Labor, Health and Human Services (HHS), Education, and Related Agencies held a mark-up of its fiscal year 2013 appropriations bill today, reducing the HHS discretionary budget by $1.3 billion below current levels. If signed into law, the bill would restrict use of any HHS funds to implement the Affordable Care Act and would rescind funds authorized for the Consumer Operated and Oriented Plan (CO-OP) Program, Center for Medicare & Medicaid Innovation, Prevention and Public Health Fund and Patient-Centered Outcomes Research Trust Fund. The legislation also would eliminate the Agency for Healthcare Research and Quality effective Oct. 1, 2012. Members of the California congressional delegation on the subcommittee voted along party lines, with Rep. Jerry Lewis (R) joining the majority to pass the bill, and Reps. Lucille Roybal-Allard (D) and Barbara Lee (D) opposing the bill. While the legislation will likely pass the full appropriations committee, it will not pass the Senate. CHA expects a final budget to be resolved in a conference committee.
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The Office of Inspector General (OIG) is seeking comments, recommendations and other suggestions on how to revise the Provider Self-Disclosure Protocol. The OIG plans to revise the protocol to conform to current industry requirements, and to provide useful guidance to the health care industry. The OIG will use lessons learned from processing more than 800 disclosures and recovering more than $280 million over the past 14 years. The comment period closes Aug. 17. Attached is the Federal Register notice.
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The California Hospital Association (CHA) is pleased by today’s Supreme Court decision upholding the Affordable Care Act (ACA). California’s hospitals have long supported the goal of expanding coverage to the uninsured. Today’s ruling means that California will continue to make progress towards this goal.
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CHA has joined with California’s safety-net hospitals on the Disproportionate-Share Hospital (DSH) Task Force to send a letter to members of the California congressional delegation urging them to protect the Medicaid program from any additional cuts to hospital payments. As the House searches for spending reductions to offset the elimination of cuts to defense spending, proposals have emerged to reduce states’ ability to use Medicaid provider taxes and DSH payments. These programs provide critical means for hospitals to bolster their ability to preserve health care services for the state’s most needy patients. CHA will continue to advocate against further cuts to hospitals as the House continues its budget reconciliation process. The DSH Task Force letter is attached.
