Two WSHA-supported bills recently passed the Washington State Legislature and will aid efforts to ensure access to safe and cost-effective access to health care in our communities. Hospital finance staff should consider potential impacts for their facilities.
Telemedicine (House Bill 1403/Senate Bill 5175): This bill, which passed both chambers of the legislature with near unanimous support, requires health plans to cover appropriate telemedicine services if the services would have been covered in person. The bill should enhance access in rural areas for specialized services such as stroke intervention and mental health. The bill does not establish payment rates for telemedicine services but will create a better environment for providers and payers to negotiate arrangements for care provided through telemedicine. Requirements for health plans start on January 1, 2017. See our Telemedicine issue brief.
Suspect and Inmate Care (Senate Bill 5593): This bill was developed in partnership with the Washington Association of Sheriffs and Police Chiefs and the Association of Washington Cities. It passed both chambers of the legislature with unanimous support. Importantly for law enforcement entities, the bill addresses payments by these entities for patients not covered by the Medicaid program or under a negotiated agreement between the hospital and the jurisdiction. While hospitals will continue to bill based on billed charges, the law provides a mechanism for discounts for the law enforcement entities. Local law enforcement entities are not health plans and generally do not have resources to negotiate and administer complex payment arrangements. The bill provides a default payment structure based on the percentage of allowed charges calculated for each facility by the Department of Labor and Industries. These rates are readily available and used by entities for worker’s compensation claims without the need for sophisticated grouping software. Importantly for hospitals, the bill also requires law enforcement to provide guards for patients who are inmates or suspects of violent or sexual crimes. While these changes will not resolve all issues related to care of suspects and inmates, it provides a structure to make care safer, more financially predictable and with lower administrative burden. See our Suspect and Inmate Care issue brief. (Andrew Busz, firstname.lastname@example.org)
HCA Announces 2012 DSH Audit Training Webinar
The Health Care Authority (HCA) announced a provider training webinar for the 2012 Disproportional Share Hospital (DSH) audit from 1:00-3:00 p.m. Tuesday, May 5, 2015. Please forward this information to staff in your organizations who are involved in the DSH audit process. The training session will be conducted by Myers and Stauffer, the company that performs the federally-required DSH audits for Washington and several other states.
The provider training session will spend the majority of time going through the survey process in detail. Myers and Stauffer staff will take provider questions, which will then be summarized and provided to the hospitals along with Myers and Stauffer’s responses. HCA will also make available PDF copies of the presentation.
Title: WA DSH 2012 Provider Training
Date: Tuesday May 5, 2015 1:00-3:00 p.m. Pacific Time
Attendee code: 7374435
CMS Releases 2016 Inpatient PPS Proposed Rule
Last week, the Centers for Medicare & Medicaid Services (CMS) issued its hospital inpatient prospective payment system (PPS) and long-term care hospital (LTCH) PPS proposed rule for Fiscal Year (FY) 2016. WSHA is preparing hospital-specific analyses of the impacts of the proposed rule. The analyses will be made available to hospitals upon completion within the next few weeks. Highlights of the proposed rule:
Inpatient PPS Payment Update The proposed rule would increase inpatient PPS rates by a net average of 1.1 percent in FY 2016, after accounting for inflation and other adjustments required by law. Specifically, the update includes an initial market-basket update of 2.7 percent, less a 0.6 percentage point for productivity and an additional 0.2 percentage point mandated by the Affordable Care Act (ACA). In addition, CMS proposes a 0.8 percentage point reduction in response the American Taxpayer Relief Act of 2012 (ATRA). Additionally, hospitals not submitting quality data would be subject to a one-quarter reduction of the initial market, and hospitals that were not meaningful users of electronic health records (EHRs) in FY 2014 would be subject to a one-half reduction in the initial market basket. Hospitals that fail to meet both of these requirements would receive an update of (0.925) percent instead of a positive 1.1 percent.
Disproportionate Share Hospital (DSH) Payment Changes The ACA required changes to the way in which DSH payments are made to hospitals, beginning in FY 2014. In FY 2016, as required under the Affordable Care Act, CMS proposes to further decrease the amount of DSH that is subject to reduction due to expected reductions in uninsured. The agency anticipates that DSH payments would decrease by an additional $1.3 billion in FY 2016 compared to FY 2015. CMS also considering the possibility of using Worksheet S-10 of the Medicare Cost Report to determine uncompensated care in the future, though at this time will continue use the current formula of inpatient days of Medicaid patients plus inpatient days of Medicare SSI patients.
‘Two-Midnight’ Policy and Short Inpatient Hospital Stays CMS did not propose or discuss any changes to the two-midnight policy in the rule despite recommendations from the Medicare Payment Advisory Commission that included requiring CMS to withdraw its two-midnight policy and target recovery audit contractor (RAC) reviews to hospitals with the most short inpatient stays. Hospital groups are concerned with this approach, as the RACs are currently incentivized to deny short says with little accountability, given the high rates of denials overturned on appeal. CMS expects to address the issue more completely in the Calendar Year 2016 hospital outpatient PPS proposed rule to be published this summer.
Value-based Purchasing CMS continues to incorporate new measures and mechanisms to move from volume to value, including measures and penalties for hospital acquired conditions and hospital readmissions. There will continue to be discussion regarding need for clinical consensus on measures and need for demographic adjustments.
Next Steps Comments on the proposed rule will be accepted through June 16, 2015. The final rule will be published around August 1, and the policies and payment rates will take effect October 1. (Andrew Busz, email@example.com)
Noridian Announces Small Number of Medicare Physician Claims May Reflect SGR Reductions
Until the Senate acted on April 14 with a new law to eliminate the physician sustainable growth rate (SGR), it was unclear if Medicare payments would be reduced by 21 percent effective on April 1. Because the Medicare Administrative Contractors (MACs) can only hold submitted claims for ten business days, Noridian, the Washington State MAC, processed a small number of claims with April dates of service using the reduced payment amounts. Noridian will automatically identify and reprocess these claims without the need of additional action from the provider. For more information, see the Noridian Bulletin. WSHA staff are in contact with Noridian and will be monitoring this issue. Please let us know if you are experiencing unusual reductions or unreasonable delay in the reprocessing of any reduced claims. (Andrew Busz, firstname.lastname@example.org)
State Adjusts Payment Rate for Medical Record Copies
The Washington State Department of Health (DOH) announced rulemaking to adjust the maximum amount health care providers can charge for copies of medical records. Under law, the DOH must update the rate every two years based on changes to the consumer price index for the Seattle-Tacoma-Bremerton area. These rates are often referenced in health plan contracts.
For the time period July 1, 2015 through June 30, 2017, the new maximum rates are:
- $1.12 per page for the first 30 pages
- $0.84 per page for additional pages
In addition, the provider can charge an additional $25.00 fee for labor related to searching and handling medical records. (Andrew Busz, email@example.com)