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In the federal fiscal year (FFY) 2019 inpatient prospective payment system final rule, the Centers for Medicare & Medicaid Services (CMS) finalized its second year of a three-year transition to use Worksheet S-10 data for distributing Medicare disproportionate share hospital (DSH) uncompensated care payments. CMS will use two years (FFYs 2014 and 2015) of Worksheet S-10 cost report data and one year of proxy data to distribute the uncompensated care payments for FFY 2019.
In response to comments from CHA, CMS noted in the final rule that it planned audits of the data in fall 2018. In late August, CMS began audits of selected hospitals’ FFY 2015 cost reports. A number of hospitals in California have received this data request, and must respond by Sept. 28.
Because CMS has given the Medicare administrative contractors (MACs) only until the end of January to complete the audits, providers have a short timeline to complete this work with their MACs. Though CHA acknowledges that this presents a challenge from both technical and resource perspectives, CHA highly encourages hospitals that have received a request to respond as quickly as possible. Early communication with Noridian (or its subcontractor, Figliozzi & Company) is critical under this short timeline. A copy of the letter Noridian sent to select providers requesting documentation is attached; these letters are consistent across all MACs.
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Today, the Centers for Medicare & Medicaid Services (CMS) issued its final rule updating the outpatient prospective payment system (OPPS) for calendar year (CY) 2019, which also includes payment updates for ambulatory surgical centers. Despite strong opposition from CHA and the hospital field, CMS finalized an expansion of its site-neutral payment policies.
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CHA has submitted the attached letter on the calendar year (CY) 2019 physician fee schedule (PFS) and quality payment program (QPP) proposed rule, providing comments on many of the provisions that are significant to hospitals and the physicians who provide care in hospitals. This includes CMS’ proposal to maintain a payment rate of 40 percent of outpatient prospective payment system (OPPS) rates for items and services furnished at certain off-campus hospital outpatient provider based clinics, as required by Section 603 of the Bipartisan Budget Act of 2015. CHA is disappointed that the agency continues to ignore the significant differences in regulatory requirements and responsibilities of the hospital outpatient department in providing health care services to Medicare beneficiaries, and urges the agency to refine its methodology for determining the rate. CHA believes a more robust analysis would support a payment rate of 65 percent of the OPPS rates.
CHA also comments on CMS’ proposal to reduce documentation requirements for evaluation and management (E/M) visits while collapsing payments for Level 2 through Level 5 E/M visits into a single blended payment rate. While supporting a number of the proposals that would reduce documentation burden, CHA urges the agency to withdraw its payment proposal and engage stakeholders to address the outdated coding system and improve payment accuracy in the future.
This post has been archived and contains information that may be out of date.
Yesterday, the Centers for Medicare & Medicaid Services (CMS) released the outpatient prospective payment system (OPPS) proposed rule for calendar year (CY) 2019, which also includes payment updates for ambulatory surgical centers (ASCs).
What’s new in CHA Education? On-demand learning!
CHA is now offering members-only on-demand programs that provide the knowledge you need, on your time schedule. How much time can you spare for learning in a day — 15 minutes? Three hours? The choice is yours.
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The Centers for Medicare & Medicaid Services (CMS) has notified hospitals participating in the Comprehensive Care for Joint Replacement (CJR) Model that they must make selections to participate in either Track 1 or Track 2 of the model by Oct. 24 at 5 p.m. (PT). Track 1 of the CJR model is considered an Advanced Alternative Payment Model (APM) under requirements of the Medicare Access and CHIP Reauthorization Act (MACRA). Participation in Track 1 requires hospitals to attest to the use of Certified Electronic Health Record Technology, as defined in 42 CFR Section 414.1305, to document and communicate clinical care to their patients or other health care providers, and to submit a financial arrangement list of CJR collaborators. CJR collaborators of the Track 1 participant hospitals and the practice collaboration agents of CJR collaborators are eligible to earn a 5 percent APM incentive payment under the Quality Payment Program, provided they achieve threshold levels of participation in Advanced APMs to attain qualifying APM participant (QP) status for a year.
CMS also notes that hospitals that previously selected Track 2 participation may revise their election to Track 1. Track selection can be made by filling out the attached Excel spreadsheet and sending it to CJRSupport@cms.hhs.gov. A document providing additional instructions is attached.
CHA News is sent to members at 9 a.m. every Thursday. All CHA communications —including updates on legislation and regulations, and notifications on legal decisions — are consolidated into one easy-to-scan newsletter. Please log in to subscribe. Need assistance? Please contact us at info@calhospital.org.
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On Jan. 20, the Trump Administration issued a memo to the heads of all executive departments and agencies freezing new and pending federal regulatory activity until the President’s appointees or designees have had the opportunity to review any new, recently finalized or pending regulations. The memo, which is common for an incoming administration, addresses regulations that have been sent to the Office of the Federal Register but not yet published, as well as regulations that have been published in the Federal Register but were not yet effective on Jan. 20.
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Webinar Recorded Live on April 30, 2015
A CHA members-only program
Overview
The National Labor Relations Board (NLRB) has been altering the workplace landscape for the last several years. Two recent and important NLRB changes will significantly impact employers — union and non-union alike.
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CHA has submitted the attached comments to the Office of Medicare Hearings and Appeals (OMHA), responding to its request for information (RFI) on initiatives to address the current backlog of claims pending at the administrative law judge (ALJ) level of appeals. While CHA applauds OMHA’s willingness to begin to address the backlog through a number of pilot programs, the increase in recovery audit contractor (RAC) claim denials will intensify challenges at the ALJ level without fundamental RAC reform. CHA urges OMHA to improve the transparency of data by continuing to release it on a quarterly basis and including additional information, such as the total number of claims, total charges being appealed by the individual Medicare payment system, the most frequent reason for appeals, the number of requests overturned on appeal and the number of cases that moved to the ALJ level. CHA also urges OMHA to improve communication on its established pilots, such as hosting a provider call to educate hospitals on the methodology of its statistical sampling pilot.
