Washington State Health Care Authority Regulatory Issues

March 29, 2016 — DSHS and HCA Start Rulemaking Regarding Changes in Payment for Inpatient Psychiatric Services

Due to federal changes, the Department of Social and Health Services and Health Care Authority are exploring draft rules to change payment requirements for Behavioral Health Organizations (BHO) for inpatient psychiatric services. The first draft rules attempted to tie payment for services to medical necessity rather than legal status from an involuntary commitment. Current regulations require a BHO to pay for inpatient psychiatric services when an individual has been committed by the court under the involuntary treatment act. WSHA is concerned these changes may have unintended consequences if the definitions and intent are not clear in the rules.

WSHA has submitted initial comments and is waiting for the second draft rule to be released. The initial draft rule is available here.

For more information, please contact Andrew Busz, Policy Director, Finance (andrewb@wsha.org or 206-216-2533).

August 17, 2015 — WSHA Comments on Draft Readmissions Policy Rules

WSHA submitted a on a Health Care Authority (HCA) stakeholder draft of rule changes to its readmissions policy. The new readmissions policy will replace HCA current policy of review and denial of individual readmission claims. Instead, HCA will use 3M Corporation software to compare each hospital’s readmission rates with an expected rate based upon its mix and severity of cases, and will apply a prospective adjustment factor to prospective payment hospitals’ inpatient payment rates. Under the draft rule, the adjustment factors would be applied to inpatient services as of January 1, 2016. Hospitals will also receive periodic reports from HCA regarding their readmission rates to enable care improvements and improved coordination of post discharge services. Critical Access Hospitals will also receive data regarding their readmission cases but will not be subject to payment penalties.

HCA and Navigant staff have met with and received input from a WSHA task force of finance and quality leaders from member hospitals.  In its comments, WSHA requested that HCA include in the rule specific details and protections discussed with the task force. More information is available in our recent Fiscal Watch article. (Andrew Busz, andrewb@wsha.org)

July 7, 2015 – WSHA Comments on Telemedicine for Fee-for-Service Medicaid

In response to a proposed rule on telemedicine fee-for-service Medicaid client coverage, WSHA provided a comment letter to the Health Care Authority seeking clarity on the billing of facility fees, and urging the recognition of services provided through store and forward technology. The department revised its rule in mid-August to incorporate WSHA’s comments. WSHA believes the changes to recognize the fee-for-service Medicaid clients will eventually impact the Medicaid managed care contract. Most of the Medicaid clients in the state are enrolled in managed care. (Chelene Whiteaker,chelenew@wsha.org)

September 9, 2014 – WSHA and AWPHD Express Concern to State About Proposed Regional Service Area Boundaries.

WSHA and AWPHD sent a letter to the Washington State Health Care Authority this week expressing concerns about the state’s intent to designate proposed regional service areas (RSAs) for Medicaid purchasing.  WSHA and AWPHD are concerned that the boundaries of the RSAs do not support medical care referral patterns.  This is particularly worrisome in Cowlitz County and the Chelan-Douglas area.  WSHA and AWPHD asked the state to take care that the RSAs do not adversely affect the well-being of consumers or the effectiveness of future care delivery systems. (Zosia Stanley, zosias@wsha.org)

August 18, 2014 – Health Care Authority Issues Rulemaking Notice on Administrative Days

The Health Care Authority (HCA) released to modify rules relating to administrative days.  The rulemaking will affect HCA’s standards for when administrative days are allowed in lieu of APRDRG payment, for example when a patient no longer meets inpatient criteria but placement in an appropriate skilled nursing facility cannot be arranged.  Hospitals that are interested in the rulemaking process should respond to the HCA contact indicated in the notice. (Andrew Busz, andrewb@wsha.org)

August 18, 2014 – Health Care Authority Issues Rulemaking Notice on Hospital Revenue Codes

The Health Care Authority (HCA) released to modify rules relating to Revenue Code Billing.  The rulemaking will affect HCA’s standards for billing and payment for revenue codes for inpatient and outpatient hospital services.   Hospitals that are interested in the rulemaking process should respond to the HCA contact indicated in the notice. (Andrew Busz, andrewb@wsha.org)

June 3, 2014 – Health Care Authority Issues Rulemaking Notice on DSH Overpayment Recoupment

The Health Care Authority released notice of intent (CR-101) to create rules relating to recoupment and redistribution of disproportionate share hospital (DSH) overpayments identified through federally required DSH audits. DSH payments for state fiscal year 2011 and following are subject to recoupment.  Drafting has not yet begun on the new rules.  Hospitals that are interested in the rulemaking process should respond to the HCA contact indicated in the notice.

June 3, 2014 – Health Care Authority Issues Final Rule on Hospital Rebasing

The Health Care Authority released final rules updating definitions and various provisions relating to Medicaid Hospital payment to support the planned rebasing of inpatient payment for prospective payment hospitals effective July 1, 2014.

June 3, 2014 – Health Care Authority Issues Final Rule on Federally Qualified Health Center and Rural Health Clinic Enhancement Payments

The Health Care Authority released final rules related to Medicaid enhancement payments to federally qualified health centers and rural health clinics for services provided to Medicaid recipients enrolled with managed care plans. The rule change supports a legislative proviso in the 2013-2015 operating budget, which requires that the enhancement payments be made by the managed care plans.

May 13 – WSHA Comments on Budget Neutrality Adjustment Stakeholder Draft

WSHA has submitted a comment letter in response to the Health Care Authority’s stakeholder draft rules outlining the budget neutrality adjustment process. WSHA strongly objects to the HCA’s proposed payment methodology, which would use an up-front reduction of rates. We propose, instead, that any necessary changes be made prospectively, and that the elimination of the up-front reduction will be incorporated into the CR-102 version of the rules. HCA staff has indicated they are receptive to our comments and will be proposing modifications in the proposed rule. (Andrew Busz, andrewb@wsha.org)

May 6, 2014 – WSHA Testifies on Proposed Inpatient and Outpatient Payment Rules

WSHA submitted comments and testified at a May 6 rulemaking hearing regarding the Health Care Authority’s proposed rules pertaining to inpatient and outpatient payment as part of its planned transition to a new All Patient Refined DRG grouping system (APR-DRG), and Enhanced Ambulatory Payment Groups (EAPGs) scheduled for implementation on July 1, 2014.

WSHA’s comments focused specifically on language concerning the budget target adjuster and the lack of separate criteria to be used for setting base payment rates.  WSHA argued that in the absence of specific criteria to ensure rates consistent with economy and efficiency, the budget adjustor could be used to reduce rates to fit a specific and arbitrary budget target number, which may be insufficient to preserve access to services for Medicaid enrollees. (Andrew Busz, andrewb@wsha.org)

April 15, 2014 – Health Care Authority Releases Draft Hospital Medicaid Rates for July Rebasing

The Health Care Authority (HCA) has released draft payment rates as well as the All Payer Refined-DRG and Enhanced Ambulatory Payment Group weights to be used effective July 1, 2014. The move to new groupers and weights is a significant change to payment for prospective payment hospitals.

Here are the direct links to the rate documents that contain those weights:

HCA presented implementation and policy decisions during a February 24 webcast.

WSHA and a rebasing task force of WSHA members strongly objects to HCA’s decision to apply a three percent budget neutrality reduction to the inpatient and outpatient payment rates, particularly since it is unclear how this will be applied by the managed care plans. WSHA received this response from HCA to WSHA’s  comments to a stakeholder draft of proposed rules.  The WSHA Executive Committee has directed WSHA to work on a lobbying effort on this issue and to consider additional options, such as legal action, if necessary.  (Andrew Busz, andrewb@wsha.org)

April 9, 2014 – Health Care Authority Issues Stakeholder Drafts of Proposed Inpatient Payment Rules

The Health Care Authority recently issued two stakeholder exposure drafts of proposed rules pertaining to inpatient payment as part of its planned transition to a new All Patient Refined DRG grouping system (APR-DRG), scheduled for implementation on July 1, 2014.

WSHA has submitted comments on March 7 and April 7. We have questioned the distribution of the stakeholder drafts as well as the lack of specificity in the content of the proposed rules.  We have focused comments specifically on the budget neutrality adjuster and budget adjuster, which can be used to cut payment rates when rates exceed expected levels of payment. (Andrew Busz, andrewb@wsha.org)

November 25, 2013 – HCA Finalizes Rules Requiring Hospitals to Report Adverse Events to the Agency

The Washington State Health Care Authority (HCA) finalized rules that require hospitals and providers to report preventable provider conditions and health care-acquired conditions to the agency.  In August 2012, WSHA raised concerns in its initial comments since hospitals are already required to report adverse events to the Washington State Department of Health. WSHA also commented on the January 2013  draft rules, asking the HCA to streamline how hospitals report to the agency.  Vergil Cabasco, vergilc@wsha.org

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