The federal fiscal year (FFY) 2018 final rule addressing Medicare payment changes failed to include an increase required to restore the inpatient prospective payment system (IPPS) standardized amount to appropriate levels. Hall, Render, Killian, Heath & Lyman, P.C., has initiated a group appeal on behalf of affected hospitals across the country to challenge CMS’ refusal to restore the entire documentation and coding offset and preserve affected hospitals’ rights to these funds during the periods CMS does not restore this adjustment. The firm is requesting information by January 15 for those wishing to participate.
This comes in the wake of the Centers for Medicare & Medicaid Services completing the MS-DRG documentation and coding adjustment reductions it was required to implement during FFYs 2014-2017 to recoup $11 billion from the industry. CMS planned to implement those reductions at the rate of .8% per year for FFYs 2014-2017 for a total impact of 3.2% However, in the final year, 2017, CMS increased the reduction percentage from the predicted 0.8 percent to 1.5 percent (increasing the cumulative impact to 3.9%) to obtain the full $11 billion impact required by the law.
Originally CMS planned to fully restore the 3.2 percent cumulative reduction in the 2018 rates. However, Congress intervened and mandated that CMS do .5% per year during 2018-2023. That schedule was set by Congress before CMS implemented the 2017 reduction that included the additional 0.7% percent decrease. The aggregate impact on Medicare payments for affected Washington hospitals (n/a to CAHs or other PPS/DRG excluded facilities) in 2018 is estimated to be approximately $13 million/year (average of about $280,000/hospital).
The appeal is initiated through a Provider Reimbursement Review Board process from the FFY 2018 Final Rule issued on August 14, 2017, so the appeal deadline runs in early February.
If you would like a more detailed legal explanation of this issue, more information concerning this Medicare Group Appeal, engagement forms, terms of engagement, or estimate of the dollar amount of the impact to your facility, please contact Stephen D. Rose in Hall Render’s Bellevue office:
Stephen D. Rose
Hall Render Killian Heath & Lyman
600 108th Avenue NE, Suite 320
Bellevue, WA 98004
Please note that this adjustment does not impact Critical Access Hospitals or other PPS/DRG excluded facilities, so they are not eligible to participate in this appeal