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AHA Special Bulletin
August 22, 2022

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HHS: Hospital COVID-19 Data Reporting will Transition to CDC This December

dsamuels_drupal — Wed, 17 Aug 2022 21:06:32 +0000

HHS: Hospital COVID-19 Data Reporting will Transition to CDC This December dsamuels_drupal Aug 17, 2022 - 04:06 PM

The Department of Health and Human Services (HHS) has announced that the Centers for Disease Control and Prevention (CDC) will assume responsibility for the collection of hospital COVID-19 data, beginning in mid-December 2022. According to HHS, hospitals, as well as third parties collecting and reporting data on their behalf, will report data to the CDC’s National Healthcare Safety Network (NHSN). The reporting of these data is required under a Medicare Condition of Participation (CoP) adopted in 2020.

Key Highlights

HHS’s contract with TeleTracking – which operates the current hospital COVID-19 data reporting portal – expires at the end of 2022.
Hospitals and third parties reporting on their behalf will be required to report data into CDC’s NHSN by mid-December 2022.
The data questions will be unchanged, and NHSN will retain existing third-party collection and reporting options (including health departments, health systems and state hospital associations reporting on hospitals’ behalf).
CDC will open the NHSN portal for test submissions in October.
CDC has a transition website that it will populate with information and guidance on an ongoing basis. CDC also will host training webinars starting in late August.

ADDITIONAL BACKGROUND

Since 2020, HHS has used a web portal operated by TeleTracking as the primary mechanism for hospitals to collect and report required COVID-19 data. However, TeleTracking’s contract with HHS expires at the end of 2022. As a result, HHS opted to move the responsibility for hospital data reporting to the CDC’s NHSN. The NHSN already is used to collect healthcare-associated infection and health care personnel vaccination data from hospitals for the purposes of CMS’s quality measurement programs.

HHS has indicated that most aspects of the reporting process will remain unchanged, and that the primary change is to the data system. HHS says it will not change or add to the data questions upon which hospitals currently collect. In addition, NHSN will retain existing options for third parties to collect and report data on hospitals’ behalf. These options include:

Health system corporate offices
Jurisdictions (e.g., state health departments)
State hospital associations
Third-party vendors

To support hospitals and other stakeholders in preparing for the transition, CDC has established a transition website that will be updated on an ongoing basis with information, FAQs and other guidance. CDC also intends to open the NHSN portal by October to enable hospitals and third parties the opportunity to test the submission process. Lastly, the CDC also will host three rounds of training webinars, beginning in late August. Registration links are provided on the transition website.

FURTHER QUESTIONS

For information on how the Centers for Medicare & Medicaid Services is enforcing the condition of participation for hospitals to report HHS-requested COVID-19 data, see the AHA’s Oct. 6, 2020 Special Bulletin. If you have further questions, contact Akin Demehin, AHA’s senior director of policy, at ademehin@aha.org.

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AHA Special Bulletin
August 17, 2022

Marketplace Issues/Stability

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Senate Passes Inflation Reduction Act of 2022 with Health Care Provisions

dsamuels_drupal — Mon, 08 Aug 2022 14:52:37 +0000

Senate Passes Inflation Reduction Act of 2022 with Health Care Provisions dsamuels_drupal Aug 08, 2022 - 09:52 AM

The Senate yesterday voted 51-50 to approve the Inflation Reduction Act of 2022 (H.R. 5376), a roughly $700 billion social spending package that includes health care, climate change and tax provisions. The bill, which was considered under reconciliation procedures and amended during floor debate, is likely to be considered by the House of Representatives on Aug. 12.

Key Highlights

The legislation would:

Extend for three years the expanded eligibility and value of ACA Marketplace subsidies, originally passed in the American Rescue Plan;
Allow Medicare to negotiate drug prices on a limited set of drugs, including insulin;
Address climate change through a combination of tax changes and spending subsidies; and
Reduce the deficit.

AHA TAKE

This legislation includes important provisions that will help millions of Americans access the health care services they need.

Specifically, we are pleased that the bill extends expanded tax credits for the Affordable Care Act that were set to expire at the end of this year. This will ensure that for another three years, millions of low- and middle-income families can continue to access affordable coverage. Without action from Congress, the health care of three million current marketplace enrollees would be at risk.

We also commend Congress for taking steps to lower prescription drug prices for Medicare patients. Lowering the out-of-pocket costs for seniors will provide greater access to needed drugs.

Highlights of provisions included in the legislation that affect hospitals and health systems follow.

COVERAGE

Extend the Expanded Eligibility for and Value of Health Insurance Marketplace Subsidies. The legislation would extend the expanded eligibility for and value of health insurance marketplace subsidies authorized through the American Rescue Plan Act through 2025. The subsidy expansion is currently authorized through 2022, and approximately three million individuals have newly enrolled as a result. Specifically, the American Rescue Plan expanded eligibility for subsidies to individuals above 400% of the federal poverty level (the limit in the ACA) by making eligible anyone for whom the cost of benchmark coverage would exceed 8.5% of income. The American Rescue Plan also lowered the premium percentage at every income level, with the effect of increasing the value of the marketplace subsidies and further reducing the cost of coverage. For individuals with income up to 150% of the federal poverty level, the subsidy amounts result in the availability of plans with zero dollar premiums.

DRUG PRICING

The legislation would allow for the first time negotiation between the federal government and pharmaceutical manufacturers to establish prices for a subset of higher cost, sole source drugs covered through Medicare Part B and Part D. This provision would be phased in beginning with 10 Part D drugs only in 2026, 15 Part D drugs only in 2027, 15 Part D and/or Part B drugs in 2028, and 20 Part D and/or Part B drugs in 2029 and beyond. Whether or not the government is limited to negotiating prices for a maximum of 20 drugs in 2029 and years thereafter or the provision is cumulative and therefore could result in upwards of 100 drugs subject to negotiation in later years is not clear. Certain drugs will be excluded from negotiation, including certain orphan drugs, certain low-spend Medicare drugs, plasma-derived biological products and certain small biotech drugs.

The price negotiated between the government and the manufacturer — known as the “Maximum Fair Price” (MFP) — must be lower than a ceiling price established based on a formula in the law. Manufacturers that sell drugs subject to the MFP at a higher amount for patients covered under Medicare Part B or Part D will be subject to civil monetary penalties. Manufacturers that refuse to negotiate with the government will be subject to an excise tax or would otherwise have to drop participation in Medicare and Medicaid. For eligible drugs, manufacturers must offer 340B entities the lower of either the MFP or the 340B discount; however, manufacturers are protected against “duplicate discounts.”

In addition, the legislation would make a number of changes in prescription drug coverage and other drug-related policies. Specifically, among other provisions, the legislation would:

Cap Medicare patients’ out-of-pocket costs in the Part D program at $2,000 per year;
Cap cost-sharing for insulin products to no more than $35 per month in the Medicare program only;
Provide additional premium and co-pay assistance on prescription drugs for low-income individuals;
Institute a new “inflation rebate” under Part B and Part D whereby drug manufacturers that raise prices faster than inflation would be subject to mandatory rebates to the Medicare program;
Prohibit implementation of the prescription drug rebate rule until at least 2032;
Provide additional federal financial assistance to stabilize Part D premiums for seniors in Medicare; and
Provide enhanced coverage for vaccines, including by covering Part D vaccines without cost-sharing obligations for Medicare beneficiaries.

OTHER PROVISONS

Imposes a 15% Corporate Minimum Tax
Provides $80 billion over the next ten years for tax enforcement and compliance
Invests in domestic energy production and manufacturing
Includes policies to address carbon emissions

FURTHER QUESTIONS

If you have further questions, please contact AHA at 800-424-4301.

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AHA Special Bulletin
August 8, 2022

Legislation includes provisions on health care coverage, drug pricing; House expected to return to Washington to consider

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AHA Files Motions in 340B Case

dsamuels_drupal — Wed, 03 Aug 2022 20:25:50 +0000

AHA Files Motions in 340B Case dsamuels_drupal Aug 03, 2022 - 03:25 PM

The AHA today made a series of filings in district court to ensure that 340B hospitals are promptly repaid and that the rest of the hospital field is not penalized for the agency’s unlawful policy.

The Supreme Court of the United States June 15 unanimously ruled in favor of the AHA’s challenge to the Department of Health and Human Services’ drastic cuts to outpatient reimbursement rates for certain hospitals that participate in the 340B Drug Pricing Program. The Supreme Court did not, however, specify the remedy for HHS’ unlawful cuts. Today, the case was remanded to the United States District Court for the District of Columbia to determine how the affected 340B hospitals should be repaid.

AHA’s filings with the district court included:

Motion to Immediately Halt HHS’ Unlawful Reimbursement Cuts for the Remainder of 2022. Even though the Supreme Court has ruled against HHS, under the 2022 outpatient prospective payment system rule that is now in effect, the agency continues to apply its unlawful reimbursement cuts. The AHA explained to the lower court that “[w]ith every passing day, Defendants continue to underpay for 340B drugs pursuant to this unlawful” policy. AHA asked the Court to immediately vacate — and thereby halt — the portion of the 2022 OPPS rule that applies these reimbursement reductions.
Motion to Include 2020-2022 Reimbursement Cuts in AHA’s Case. As a technical matter, the Supreme Court held that the reimbursement cuts only in the 2018 and 2019 OPPS rules were unlawful. Because the reasoning of the Supreme Court’s decision applies to the agency’s cuts for 2020 to 2022, AHA moved to amend its complaint to add those years to its challenge.
Motion to Remedy HHS’ Unlawful Reimbursement Cuts. The AHA asked the lower court to order HHS “to promptly correct their past underpayments to Plaintiffs and their members for 2018–2022.” It explained that following the Supreme Court’s decision, “there is only one available remedy: repaying those hospitals that were unlawfully underpaid, from 2018 to the present.” In addition, the AHA explained to the court that it should not permit HHS to retrospectively recoup funds from the rest of the hospital field. The AHA’s brief noted that nothing in the 340B law requires HHS to retrospectively take back these funds, and in similar circumstances HHS has never recouped funds already spent without explicit congressional authorization, which does not exist here. The AHA’s brief further argued that basic principles of fairness support AHA’s proposed remedy. “As the Supreme Court recognized, ‘340B hospitals perform valuable services for low-income and rural communities but have to rely on limited federal funding for support,’” AHA’s brief notes. “Yet for five years, Defendants deprived hospitals of this limited funding by stubbornly persisting with legal arguments that both this Court and a unanimous Supreme Court rejected.” Similarly, the brief explained, “fairness dictates that the government not penalize other hospitals — which have long spent the funds that the government may seek to recoup — for Defendants’ own mistakes.” For example, the brief noted that “when implementing their unlawful reimbursement cuts, Defendants exempted” certain entities like rural sole community hospitals, children’s hospitals, and certain cancer hospitals, but if CMS “attempted to achieve retrospective budget neutrality, these entities would be forced to return or forego vital funding.”

Watch for updates from the AHA as the case develops.

FURTHER QUESTIONS

If you have further questions, please contact AHA at 800-424-4301.

340B

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AHA Special Bulletin
August 3, 2022

As 340B case returns to district court, series of filings determine remedy

Unopposed Motion For Permission to File Second Supplemantal Complaint

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AHA Summary of Hospital Inpatient PPS Final Rule for Fiscal Year 2023

dsamuels_drupal — Tue, 02 Aug 2022 22:10:53 +0000

AHA Summary of Hospital Inpatient PPS Final Rule for Fiscal Year 2023 dsamuels_drupal Aug 02, 2022 - 05:10 PM

The Centers for Medicare & Medicaid Services (CMS) August 1 issued its hospital inpatient prospective payment system (PPS) and long-term care hospital (LTCH) PPS final rule for fiscal year (FY) 2023. The final rule will increase inpatient PPS payments by a net 2.6% in FY 2023 as compared to FY 2022. The increase reflects a 4.3% rate update (a 4.1% market basket update, less 0.3 percentage points for productivity, plus 0.5 percentage points required by statute) as well as a 1.7 percentage point cut for outlier payments. This Special Bulletin reviews highlights of the IPPS provisions, while the LTCH provisions are covered in a separate Special Bulletin.

Key Highlights

CMS’ final policies will:

Update inpatient PPS payment rates by 4.3% in FY 2023, which is 1.1 percentage points higher than proposed.
Offset rates by 1.7 percentage points for outlier payments, compared to 1.8 percentage points in the proposed rule.
Use FY 2018 and 2019 Worksheet S-10 data to determine the distribution of FY 2023 disproportionate share hospital (DSH) uncompensated care payments. CMS also adopted the use of a three-year average of S-10 data for FY 2024 and beyond.
Distribute $10.4 billion in DSH payments, which is $500 million more than proposed.
Permanently apply a 5% cap on any decrease in a hospital’s area wage index.
Implement a modified policy to the calculation of full-time equivalent (FTE) caps in graduate medical education (GME) programs.
Apply COVID-19 measure suppressions to the Hospital Acquired-Condition (HAC) Reduction and Hospital Value-based Purchasing (HVBP) programs, resulting in neutral payment adjustments for FY 2023.
Add 10 new measures to the inpatient quality reporting (IQR) program, including 3 new health equity measures and 2 maternal health measures.
Adopt a new “birthing friendly” designation on CMS’s Care Compare website.
Finalize a modified extension of the hospital COVID-19 data reporting requirements beyond the end of the COVID-19 Public Health Emergency (PHE), but withdraw its proposal to establish hospital data reporting requirements for future PHEs.

AHA TAKE

We are pleased that CMS will provide hospitals and health systems with increased inpatient payments next year, rather than a cut as proposed, allowing them to better provide care for their patients and communities. That said, this update still falls short of what hospitals and health systems need to continue to overcome the many challenges that threaten their ability to care for patients and provide essential services for their communities. This includes the extraordinary inflationary expenses in the cost of caring hospitals are being forced to absorb, particularly related to supporting their workforce while experiencing severe staff shortages. See AHA’s full statement that was shared with the media.

Read the AHA Special Bulletin for a detailed summary of the inpatient PPS rule

Inpatient PPS

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August 2, 2022

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CMS Releases FY 2023 Long-term Care Hospital PPS Final Rule

dsamuels_drupal — Tue, 02 Aug 2022 20:24:25 +0000

CMS Releases FY 2023 Long-term Care Hospital PPS Final Rule dsamuels_drupal Aug 02, 2022 - 03:24 PM

The Centers for Medicare & Medicaid Services (CMS) yesterday issued its fiscal year (FY) 2023 final rule for the inpatient and long-term care hospital (LTCH) prospective payment systems (PPS). This Special Bulletin reviews highlights of the LTCH provisions, while the inpatient PPS provisions are covered in a separate Special Bulletin.

Key Highlights

The final rule:

Increases net LTCH payments by $71 million in FY 2023, relative to prior levels.
Resumes the use of the most recently available claims and cost report data to calculate the LTCH PPS weights and rates, with some modifications to account for the remaining impact of the COVID-19 public health emergency (PHE).
Caps annual decreases in wage index updates.
Caps annual relative weight decreases per MS-LTC-DRG.
Makes no changes to the LTCH quality reporting program (QRP).

AHA Take

We are pleased that the final rule recognized the need for a more adequate update to LTCH payments; however, the rates still fall short of what these providers need to continue to overcome the many challenges that threaten their ability to care for patients and provide essential services for their communities. We generally support the final policies related to the annual wage index and relative weight updates for individual MS-LTC-DRGs, which collectively should help maintain stability from year to year — although we preferred a budget neutral approach for implementing the wage index cap. In addition, we remain concerned that implementation of the full site-neutral payment policy continues to challenge some LTCHs — especially as site-neutral payments, on average, do not cover the cost of care.

Highlights from the rule follow.

LTCH PPS Payment Changes for FY 2023

Overall Update. When considering all LTCH provisions in the rule, CMS estimates an aggregate net spending increase of $71 million in FY 2023 compared to FY 2022 — more than the proposed $25 million increase. CMS estimates that in FY 2023, Medicare payments for standard-rate cases would account for 89% of aggregate payments to LTCHs, with the remaining 11% spent on site-neutral cases.

The rule resumes CMS’s standard methodologies used to calculate most elements of the PPS. Specifically, calculation of the FY 2023 weights and rates are based on the most recently available data — the FY 2021 MedPAR claims and FY 2020 cost report data — based on the agency’s expectation that the volume of COVID-19 hospitalizations will continue to drop in FY 2023.

Update for Standard LTCH PPS Rate Cases. CMS estimates that 72% of all LTCH discharges will be paid a LTCH PPS standard rate in FY 2022 — a reduction from the prior FY’s level of 75%. CMS finalized a payment update for this category of cases of net 2.3% (or $61 million) for FY 2023 compared to FY 2022. This increase includes a 3.8% market-basket update that would be offset by a statutorily mandated cut of 0.3 percentage point for productivity, a 1.2 percentage point cut for high-cost outlier (HCO) payments, and other adjustments. The final standard rate increases from $45,952.67 in FY 2022 to $46,432.77 in FY 2023.

To explain the increase in the final FY 2023 market basket, relative to the proposed 3.1% market basket, CMS notes the final rule’s incorporation of enhanced forecast data used to calculate the market basket. These more accurate price proxy data incorporate more recent historical data and reflect a revised outlook regarding the U.S. economy (which incorporates more recent historical CPI growth, estimated impacts of the Russia/Ukraine war, expectations regarding changes to Federal Reserve interest rates, and the estimated impacts of continued tight labor markets).

HCO Threshold. The rule finalized a FY 2023 HCO threshold for standard-rate cases of $38,518, far lower than the proposed $44,182 threshold, which strives to maintain a HCO pool of 7.975% of aggregate payments to LTCHs, as required by law. Regarding the final methodology used to calculate this threshold, CMS replaced its approach in the proposed rule with the methodology suggested by the Medicare Payment Advisory Commission, which aligns better with the expectation of fewer COVID-19 LTCH patients in FY 2023. Specifically, the final HCO threshold was calculated using the FY 2021 claims to compute and then average the high outlier-fixed loss threshold calculated with and without COVID-19 cases.

CMS states that this substantial change in threshold also reflects a newly realized anomaly that, when addressed, resulted in the lower, more accurate threshold. Specifically, the final threshold was re-calculated without the cases of a particular LTCH with an extreme level of charges in FY 2021, including over 50 LTCH PPS standard rate cases with charges exceeding $9 million, and outlier payments for over 80 percent of its standard rate cases that year.

Update for Site-neutral Rate Cases. CMS finds that the proportion of all LTCH discharges that are paid an LTCH site-neutral rate increased from 25% to 28% in FY 2022. For this category of cases, the rule updates net payments by 2.8% (or $9 million) compared to FY 2022. Site-neutral payment rates are paid the lower of the inpatient PPS-comparable per-diem amount, including any outlier payments, or 100% of the estimated cost of the case. For FY 2023, the HCO threshold for site-neutral cases continues to mirror that of the final inpatient PPS threshold, $38,859, which is substantially lower than initially proposed.

For FY 2023, all site-neutral cases will continue to receive the full site-neutral payment rate, instead of the prior 50/50 blend of LTCH PPS and site-neutral rates. We note that, as required by statute, the cost of the last two years of the blended-rate (cost reporting periods starting in FYs 2018 and 2019) is offset by a 4.6% payment cut to site-neutral payments in FYs 2018 through 2026. This offset is explained in CMS Transmittal 4046.

Cap on Relative Weight Decreases per MS-LTC-DRG

To improve the stability of this PPS, CMS finalized as proposed a 10% cap on relative weight decreases to mitigate fluctuations in MS-LTC-DRG relative weight changes from year to year. The agency notes that in recent years, some MS-LTC-DRGs weight fluctuations have been quite significant and some stakeholders have asked the agency to mitigate these negative effects. This cap will be implemented in a budget-neutral manner to prevent impacting aggregate payments. In addition, CMS states its expectation that the impact of a cap on relative weight reductions in a given year will be relatively small, as the cap will be applied on a per MS-LTC-DRG basis. The cap also will apply to “low-volume MS-LTC-DRGs” — those with 1-25 cases, with no application to “no-volume MS-LTC-DRGs.”

Cap on LTCH Wage Index Decreases

CMS finalized as proposed a permanent approach to smooth year-to-year changes in the LTCH PPS wage index. In the past, to mitigate stability, CMS phased in significant changes to labor market area boundaries and other changes. CMS notes that, while relatively rare, year-to-year fluctuations in an area’s wage index can occur due to external factors beyond a provider’s control, such as the COVID-19 pandemic. To mitigate this type of occasional instability, CMS will implement a permanent 5.0% cap on any decrease to a provider’s wage index, relative to the prior year, regardless of the circumstances causing the decline. For a new LTCH, the agency will apply the wage index for the area in which it is geographically located with no cap applied because the new hospital will not have a wage index to reference from the prior year. This policy will be implemented in a budget neutral manner.

Further Questions

Please contact Caitlin Gillooley, AHA director of policy, at cgillooley@aha.org, regarding any questions on this rule.

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AHA Special Bulletin
August 2, 2022

Skilled Nursing Facility PPS

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CMS Releases FY 2023 Skilled Nursing Facility PPS Final Rule

dsamuels_drupal — Mon, 01 Aug 2022 20:49:16 +0000

CMS Releases FY 2023 Skilled Nursing Facility PPS Final Rule dsamuels_drupal Aug 01, 2022 - 03:49 PM

The Centers for Medicare & Medicaid Services (CMS) late Friday issued its fiscal year (FY) 2023 final rule for the skilled-nursing facility (SNF) prospective payment system (PPS). The rule updates SNF rates and also finalizes a budget neutrality offset related to the Patient Driven Payment Model (PDPM) case-mix system, which was implemented in FY 2020.

Key Highlights

The final rule:

Increases aggregate SNF payments by $904 million in FY 2023, relative to FY 2022
Implements a behavioral offset, which CMS states is necessary to ensure budget neutral implementation of the PDPM case-mix system
Adopts one new quality measure on the rate of influenza vaccination for staff
Revises, effective in October 2023, the compliance date for reporting certain measures and patient data that were delayed due to the COVID-19 public health emergency
Adopts two new quality measures for SNF VBP starting in FYs 2026, with an additional quality measure added in 2027

AHA TAKE

In addition to the annual payment update required by law, the rule finalized a substantial behavioral offset that CMS states is intended to ensure the budget neutral implementation of the new PDPM case-mix system. While AHA is concerned about the size of the offset, we do appreciate that, instead of the proposed one-year implementation of the cut, CMS finalized a two-year phase-in to mitigate the cut’s single-year impact. Given the ongoing impact of the COVID-19 pandemic on SNFs and nursing homes, this phase-in approach helps to avoid substantially amplifying current clinical and financial instabilities.

View the detailed Special Bulletin below.

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AHA Special Bulletin
August 1, 2022

Inpatient Rehab Facility PPS

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CMS Releases FY 2023 Inpatient Rehabilitation Facility PPS Final Rule

dsamuels_drupal — Thu, 28 Jul 2022 19:44:35 +0000

CMS Releases FY 2023 Inpatient Rehabilitation Facility PPS Final Rule dsamuels_drupal Jul 28, 2022 - 02:44 PM

The Centers for Medicare & Medicaid Services (CMS) late yesterday issued the final rule for the inpatient rehabilitation facility (IRF) prospective payment system (PPS) for fiscal year (FY) 2023.

AHA Take

We appreciate CMS’ streamlined approach to the rule, which allows providers to focus on responding to patient care needs and challenges related to the COVID-19 pandemic. While we are pleased that the final net increase for FY 2023, $275 million, is more than the proposed amount of $170 million, we remain concerned that the agency fell short in fully recognizing the impact of broader economic pressures on IRFs and the delivery system as a whole.

Key Highlights

The final rule:

Increases IRF payments by an estimated 3.2% in FY 2023.
Caps annual decreases in wage index updates.
Updates current policy affecting displaced medical residents.
Requires IRFs to collect quality data on all patients, regardless of payer, beginning in October 2023.

Highlights from the rule follow.

IRF PPS Payment Changes

FY 2023 Payment Update

CMS finalizes an overall increase in FY 2023 payments to IRFs, relative to FY 2022, of 3.2%, or $275 million. This includes a 4.2% market basket update offset by a statutorily-mandated cut of 0.3 percentage point for productivity, and a 0.6 percentage point cut for high-cost outlier payments. The latter would reduce the number of cases that qualify for an outlier payment with the goal of limiting total FY 2023 outlier payments to 3.0% of all IRF PPS payments that year, per current policy.

Permanent Cap on Wage Index Decreases

As proposed, CMS adopts a permanent policy that would cap wage index decreases from year-to-year at 5%. CMS anticipates that this cap would rarely be used, but, when needed, would improve the stability of this payment system.

Changes Related to the Facility-Level Adjustment for "Teaching IRFs"

Changes Regarding Displaced Medical Residents

The rule updates and clarifies current policy addressing medical residents (and interns) who are displaced when a teaching IRF closes. In addition, the status of a relocating resident will be based on the date that the originating IRF publicly announces its closure (for example, via a press release), rather than the actual closure date, to mitigate delayed transfers of a displaced resident to a new IRF. The rule also allows the receiving IRF to increase its FTE resident cap by submitting a letter to its Medicare Administrative Contractor (MAC) within 60 days after beginning to train the displaced residents.

Codification of IRF Teaching Status Adjustment

To improve clarity, CMS will codify and consolidate existing policies related to reimbursement for IRFs providing graduate medical education.

IRF Quality Reporting Program (QRP)

CMS finalized its proposal to require IRFs to report quality data, including the standardized patient assessment data in the IRF Patient Assessment Instrument (PAI), on all patients regardless of payer. However, CMS will delay the implementation of this requirement by one year; as finalized, IRFs will be required to collect the IRF PAI for all patients beginning Oct. 1, 2024. The agency estimates that the increased burden will result in an additional average cost of nearly $29,000 per IRF annually, at a total cost of over $31 million for the field per year.

CMS did not propose any other changes to the QRP, including any new quality measures.

Further Questions

AHA’s IRF members will receive an invitation for a call to discuss the rule. Please direct any questions to Caitlin Gillooley, AHA director of policy, at cgillooley@aha.org.

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AHA Special Bulletin
July 28, 2022

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AHA Releases New Report Examining How Commercial Insurers’ Policies Compromise Patient Safety

dsamuels_drupal — Thu, 28 Jul 2022 16:29:37 +0000

AHA Releases New Report Examining How Commercial Insurers’ Policies Compromise Patient Safety dsamuels_drupal Jul 28, 2022 - 11:29 AM

The AHA today released a new report highlighting numerous commercial health insurer policies that compromise patient safety and raise costs.

Among other issues, the report details how many commercial health insurers:

Apply prior authorization requirements in ways that create dangerous delays in care, contribute to clinician burnout and significantly drive-up administrative costs for the health care system.
Establish flawed or overly stringent medical necessity policies that prevent patients from obtaining the necessary care recommended by their physician.
Use their market power and position to steer providers to purchase their auxiliary products that drive up administrative costs and line insurer pockets.

In addition, the report outlines the need for commercial health plan abuses to be addressed to protect patients’ health and ensure that medical professionals, not the insurance industry, are making the key decisions in patient care.

ADDITIONAL EFFORTS TO HOLD HEALTH PLANS ACCOUNTABLE

Congressional Action — the AHA continues to call for greater congressional oversight to protect access to care for Medicare Advantage beneficiaries. Specifically, the AHA supports legislation (H.R.3173/S.3018) to streamline MA plans’ prior authorization requirements, which the Ways and Means Committee advanced on Wednesday.
DOJ Taskforce — the AHA has urged the Department of Justice to establish a taskforce to conduct False Claims Act investigations into commercial health insurance companies that are found to routinely deny patients access to services and deny payments to health care providers.
CMS Oversight — The AHA has asked the Centers for Medicare & Medicaid Services to take action to hold plans accountable for egregious practices through increased oversight.
Insurer Watch, powered by the AHA Vitality Index™ — This is a new solution from the AHA in collaboration with Hyve Health (formerly ATEX Financial), that can help hospitals uncover how often their organization’s payment claims are denied, determine if those denial rates vary by payer or service line, and compare their organization’s metrics to other providers and peer groups. It will arm the hospital field with the data it needs to hold commercial health plans accountable for burdensome practices, while also enabling individual hospitals to benchmark their financial and operational performance on key metrics. If your organization is not participating in this effort yet, please click here to learn more. (https://www.ahadata.com/aha-vitality)

SHARE YOUR STORY WITH US

The AHA wants to hear about your organization’s experience with commercial health plans and how inappropriate use of prior authorization, payment delays and other harmful policies are affecting your patients. Visit our Health Plan Accountability webpage for additional resources as well as ways you can share your organization’s story with us. AHA members must log into the AHA website to access the materials.

FURTHER QUESTIONS

If you have further questions, please contact AHA at 800-424-4301.

Commercial Insurer Accountability

Quality & Patient Safety

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AHA Special Bulletin
July 28, 2022

AHA Releases New Report Examining How Commercial Insurers’ Policies Compromise Patient Safety, Raise Health Care Costs

Report is latest in AHA’s continued efforts to push back on harmful policies

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AHA Releases Next Section of Workforce Guide Focused on Data and Technology

dsamuels_drupal — Wed, 27 Jul 2022 18:30:27 +0000

AHA Releases Next Section of Workforce Guide Focused on Data and Technology dsamuels_drupal Jul 27, 2022 - 01:30 PM

The AHA today released section two of a three-part series that offers immediate and longer term strategies to help hospital and health system leaders navigate workforce challenges and opportunities. Today’s section focuses on data and analytics, as well as technological supports.

“America’s health care workforce is the heart of health care,” AHA President and CEO Rick Pollack said in announcing the report. “The AHA has sounded the alarm repeatedly that our workforce is in crisis, and the national emergency demands immediate attention from health care leaders and policymakers at every level of government. As part of our ongoing efforts to support the field, we have developed this new guide with strategies and resources that can help hospital and health system leaders navigate these complex challenges.”

The guide, which was informed by the AHA Board of Trustees’ Task Force on Workforce, includes strategies, resources and case studies from hospitals and health systems across the country.

The first section of the report offered strategies and resources to support workforce well-being and behavioral health and prevent workplace violence. The last section of the report will focus on strategies and staffing models to support recruitment, retention, diversity, equity and inclusion.

View AHA’s workforce webpage to download the new section of the guide. You also can access section one of the guide, as well as additional resources on this webpage.

FURTHER QUESTIONS

If you have further questions, please contact AHA at 800-424-4301.

Workforce

Type

Access Level

AHA Special Bulletin
July 27, 2022