According to the Office of the Actuary for the Centers for Medicare & Medicaid Services (CMS), Medicare reimbursement to California hospitals amounted to almost $58 billion in 2004, comprising more than one-third of all Medicare spending in the state for that year. In addition to the volume and monetary value of its reimbursement, CMS through the California Department of Health Services, and through its deeming organizations, remains an extremely important regulator of hospitals.
Because of the influence that Medicare and CMS have on California’s hospitals, CHA is consistently engaged with CMS and with Congress to ensure the adequacy of Medicare reimbursement, and to provide the federal government with California hospitals’ perspectives on policy and payment changes.
The Centers for Medicare & Medicaid Services (CMS) has released the attached list of measures under consideration for adoption in future Medicare rulemaking, as required by the Affordable Care Act (ACA). The Measures Application Partnership (MAP), convened by the National Quality Forum (NQF), will review the list and provide recommendations to CMS through a process that allows multiple stakeholders the opportunity to weigh in on measure selection before rules are finalized. For the first time in three years, the MAP will allow the public to comment prior to the beginning of its workgroups and coordinating committee meetings. The early public comment period ends on Dec. 9. In addition, as in previous years the public will have an opportunity to comment on the MAP’s recommendations to CMS, to be issued in January.
Under current law, physicians and non-physician practitioners (NPP) will see across-the-board reductions in payment rates based on a formula – the sustainable growth rate (SGR) methodology – that was adopted in the Balanced Budget Act of 1997. Without Congressional action, required by the end of the year, physicians will see payments cut in excess of 20 percent for services in 2014.
The Centers for Medicare & Medicaid Services (CMS) has finalized its CY 2014 conversion factor at $27.2006, reflecting a smaller reduction in the conversion factor than the 24.4 percent cut CMS projected in March.
CHA reminds hospitals participating in the Medicare electronic health record (EHR) incentive program to attest to demonstrating meaningful use by 8:59 p.m. (PT) on Saturday, Nov. 30, in order to receive a 2013 incentive payment. CHA urges hospitals not to wait until the last minute to attest. The Centers for Medicare & Medicaid Services (CMS) website is often flooded with requests at this time each year, causing delays.
Hospitals must attest to demonstrating meaningful use every year to receive an incentive and avoid payment adjustments that are scheduled to begin Oct. 1, 2014. Hospitals that begin participation in the EHR incentive programs in 2014 or later will receive a reduced EHR incentive payment. For federal fiscal year (FFY) 2014, the reporting period will be three months, regardless of the stage of meaningful use, to allow hospitals more time to upgrade to 2014-certified EHR technology. Further, in order to avoid the FFY 2015 payment penalty, hospitals must attest no later than July 1, 2014, which means they must begin their 90-day EHR reporting period no later than April 1, 2014. CHA continues to work with AHA to extend the period of time in which hospitals can remain at each stage to three years, instead of two. For more information regarding the program, visit the CMS EHR incentive program web page.
The Department of Health Care Services (DHCS) continues to host its monthly stakeholder webinars on the Coordinated Care Initiative (CCI), which is currently scheduled to begin no sooner than April 2014. The webinars are open to all interested parties. The next monthly webinar will be held Tuesday, Nov. 18 from 1 p.m. to 2 p.m. (PT). For more information and to register, visit http://www.calduals.org/2013/09/05/upcoming-webinars-covering-the-coordinated-care-initiative/.
The Centers for Medicare & Medicaid Services (CMS) has updated its frequently asked questions (FAQs) document regarding therapy services functional reporting. The document, attached, provides information about CMS coverage for physical therapy, occupational therapy, and speech/language pathology services.
The Centers for Medicare & Medicaid Services (CMS) has notified hospitals regarding possible delays in the release of final rules for calendar year (CY) 2014 Medicare fee-for-service payment regulations as a result of the federal government shutdown. The affected regulations were expected to be released by Nov.1. However, CMS now expects them to be released by Nov. 27 to be effective Jan. 1, 2014. Affected regulations include the CY 2014 outpatient prospective payment system (PPS), CY 2014 end-stage renal disease PPS, CY 2014 home health PPS and CY 2014 physician fee schedule.
Noridian has announced that it will hold a public Part A Open Door Coverage meeting on Oct. 22 from 11 a.m. – 12:30 p.m. (PT). The meeting will allow for the submission of information related to local coverage determinations, currently in the draft stage, prior to implementation. Specific claims will not be discussed during the meeting. Providers, practitioners and CMS staff may participate by attending via teleconference or the on-site meeting – at Cedars-Sinai in Los Angeles, Advanced Health Science Pavilion, Conference Room PEC 6 & 7. All other interested participants may attend by phone. To attend in person, participants should pre-register with Amber Petersen at Amber.Petersen@noridian.com, no later than Oct. 21. For more information about the meeting, visit https://med.noridianmedicare.com/web/jea/policies/lcds/open.
As Congress remains deadlocked in negotiations regarding a government funding bill for federal fiscal year (FFY) 2014, the threat of a government shutdown remains a possibility. The U.S. Department of Health and Human Services (HHS) has released a report detailing its plan for operations should Congress not reach a deal. The report says that “in the short term,” the Medicare program will largely continue without disruption, and that states will have funding for Medicaid on Oct. 1, due to the advanced appropriation enacted in the FFY 2013 legislation. Implementation of the Affordable Care Act, including exchanges set to open Oct. 1, is largely funded through mandatory spending and will continue despite a government shutdown. HHS will furlough about 52 percent of its employees, but activities related to the safety of human life and protection of property will continue.
The Centers for Medicare & Medicaid Services (CMS) today released additional information regarding the “two-midnight” benchmark and presumption for inpatient admission and medical review criteria. During its hospital open door forum, CMS announced that it will not allow post-payment review of patient status by the MACs or the RACs on inpatient claims that span two midnights for admissions beginning on or after Oct. 1 through Dec. 31, 2013. Further, it will not permit RACs to review inpatient admissions of one midnight or less that begin on or after Oct. 1, 2013. When asked if CMS would prohibit review of these claims at a later date, CMS staff confirmed that it is not their intention to have these claims reviewed at a later date.
The Centers for Medicare & Medicaid Services (CMS) will host its second in a series of calls intended to educate hospitals about the two-midnight benchmark for inpatient admissions on Thursday, Sept. 26 from 11 a.m. to noon (PT). The call also will include the physician order and physician certification, inpatient hospital admission and medical review criteria included in the federal fiscal year 2014 inpatient prospective payment system (IPPS) final rule. Providers will have an opportunity during the call to ask CMS questions about the policies. CHA encourages members to participate in this important call. To participate, dial (866) 501-5502 and enter conference ID 68257949. Providers can also provide feedback to CMS on the two-midnight provision by sending an email to IPPSAdmissions@cms.hhs.gov. Additional resources on the policies are available on CHA’s website at www.calhospital.org/resource/inpatient-admission-and-medical-review-resources.
**Please note the dial-in number was changed by CMS shortly before the call. The dial-in number above reflects the updated version.
The Centers for Medicare & Medicaid Services (CMS) released hospital wage and occupational mix data one month early on Sept. 13. Hospitals may review and request revisions to their data, which will be used to develop the fiscal year 2015 hospital wage index, until Nov. 21. Because of the earlier than expected data release, other subsequent dates in the wage index development process will also occur earlier than in previous years. Hospitals are encouraged to review the attached CMS timeline.
The Centers for Medicare & Medicaid Services (CMS) has delayed for a second time the requirement that medical professionals document face-to-face meetings with patients before prescribing certain durable medical equipment (DME). The 2013 Medicare physician fee schedule required physicians and other medical personnel to document face-to-face encounters within the six months preceding prescription of certain DME items. Originally scheduled to take effect July 1, the requirement was then delayed to Oct. 1. This month, CMS again postponed the effective date until sometime in 2014, with the actual date to be announced later. According to a Sept. 9 CMS notice, the delayed enforcement will allow DME suppliers and physicians more time to prepare and comply. CMS plans to address questions and provide updates at www.cms.gov/medical-review.
Today marks the official transition from Palmetto to Noridian Administrative Services for Medicare Part A fee-for-service claims in California; Part B implementation will begin Sept. 16. It was announced earlier this year that Noridian received the Medicare Administrative Contractor award for processing Part A and Part B fee-for-service claims in Jurisdiction E, which includes California. To assist with the transition, hospitals may want to attend one of Noridian’s online training opportunities, including its Ask the Contractor teleconference series. For more information about training events, visit https://med.noridianmedicare.com/web/jea/education/act.
The Centers for Medicare & Medicaid Services (CMS) has posted a transcript and recording of the national provider call held on Aug. 15 regarding newly revised policies implemented in the federal fiscal year 2014 inpatient prospective payment system final rule. The call focused on policies related to the physician order certification for inpatient hospital admission, as well as the medical review criteria that will be used by the MACs and RACs in reviewing inpatient admissions. CMS also reviewed the final rule’s Part B inpatient billing provisions. CMS is still seeking feedback from providers as it develops guidance for the MAC and RAC auditors, and CHA urges members to submit questions and comments to IPPSAdmissions@cms.hhs.gov. The transcript and link to the audio recording are attached.
The Centers for Medicare & Medicaid Services (CMS) is seeking input from inpatient rehabilitation facilities (IRFs) and long-term care hospitals (LTCHs) regarding implementation of new quality reporting programs (QRPs) for those settings. On behalf of CMS, Health Care Innovation Services is requesting that IRF and LTCH providers participate in brief interviews to help better understand the burdens imposed on providers, how providers ensure accuracy of data, how the QRP has impacted patient services and outcomes, and what CMS can do in the future to improve the program and processes.
Interviews will be conducted by telephone, and reports or supplemental documents submitted to CMS will not link specific answers to any specific providers. Anyone interested in participating for either the IRF or the LTCH QRP should contact Pat Hanson at email@example.com.
The Department of Health Care Services (DHCS) has announced that implementation of the coordinated care initiative (CCI) will begin no sooner than April 2014. The demonstration program was previously scheduled to begin in January 2014 in eight designated counties.
A major component of the CCI is the Cal MediConnect program, which will enroll beneficiaries with both Medicare and Medi-Cal (“dual eligibles”) into managed care. The CCI also includes the integration of long-term care services and supports, including long-term care provided in a skilled-nursing facility, in-home support services and multipurpose senior services programs.
Earlier this year, the Office of Inspector General released a report indicating that Medicare had improperly paid hospitals for services provided to incarcerated beneficiaries. As a result, the Centers for Medicare & Medicaid Services (CMS) identified the overpaid claims and issued letters to hospitals demanding they either repay the overpayments or appeal the denial decisions. Many hospitals identified errors in the data CMS used to identify the overpaid claims and raised their concerns with CHA. Last week CMS acknowledged the error and agreed to cease its overpayment collection efforts.
The Centers for Medicare & Medicaid Services (CMS) has posted an updated version of the calendar year (CY) 2014 physician fee schedule proposed rule. The updated copy corrects formatting and software problems that resulted in incorrect information in several tables and shrinking the document by nearly 50 pages. In addition, a small amount of previously missing content was restored to the affected tables. The comment deadline remains Sept. 6. The updated proposed rule is attached.
The California Department of Health Care Services (DHCS) has issued for public comment a draft enrollment strategy and schedule for Cal MediConnect in Los Angeles County. The plan is directed at transitioning 213,000 dually eligible beneficiaries into the new program of integrated care beginning in January 2014. CHA encourages member hospitals in Los Angeles County to review the plan and communicate questions and concerns to CHA staff. A copy of the draft plan is attached. Comments are due Aug. 2, 2013.