For the past several months, insurers, joined by the Washington State Hospital Association (WSHA) and the Washington State Medical Association (WSMA), have been highlighting problems in the Washington Health Benefit Exchange, Washington Healthplanfinder. There about 6,000 individual accounts whose premiums have not been properly processed due to technical glitches. The exchange has committed to fixing the problems by August 30, but some patients who have paid their premiums are finding they are not enrolled and claims are being pended or not covered.
As a workaround to the exchange issues, Insurance Commissioner Mike Kreidler recently announced a new open enrollment period for the outside individual market, from August 27 to November 14, for those who attest to having previously enrolled but have not been processed. This option may not make sense for the majority of individuals receiving significant subsidies inside the exchange (subsidies are only available inside the exchange market). Traditional open enrollment for all 2015 individual and family coverage starts November 15, 2014 and ends February 15, 2015. (Chelene Whiteaker, email@example.com)
Washington State Quarterly Data Shows Positive ACA Implications: Your Data Needed
Hospitals are feeling the initial impacts of the Affordable Care Act (ACA), and the initial results appear to be positive. The data are important to understanding the impact of the changes. WSHA thanks the hospitals that have already submitted their data and strongly encourages non-reporting hospitals to submit their quarterly information to the state Department of Health. The deadline for the submission was August 15.
Based on data from 52 hospitals in Washington State, charity care and bad debt continue to decline, and margins are improving from the economic-recession lows. Compared to 1Q13 and 2Q13, the 2014 data show:
- Inpatient discharges and surgeries remain flat, along with commercial net patient revenue;
- Outpatient visits from hospital-based clinics increased about 10 percent; and
- Ambulatory surgeries are up about 15 percent.
WSHA expected the initial decline on charity care and bad debt as the number of uninsured decreased in our state from the coverage expansions through the ACA. The ACA, however, back-loaded the cuts to Medicare payments and Medicare and Medicaid DSH cuts. We will continue to work to understand how these initial results from the first six months of data compare with the overall cuts coming through the ACA. WSHA understands that some of the reporting in the quarterly segments is preliminary, and results can be altered by year-end adjustments. Chelene Whiteaker, firstname.lastname@example.org)
HCA Medicaid Recovery Audit Contractor Program on Hold until July 2015
Hospitals and providers will have a temporary respite from at least one source of audits. The Washington Health Care Authority (HCA) announced it intends to request a twelve-month exception to the federal requirement to contract with a Medicaid Recovery Audit Contractor (RAC). This follows the recent termination of HCA’s contract with CGI Federal which was the Medicaid RAC from July 2012 through June 2014. The twelve-month period would allow for procurement of a new RAC effective July 2015. HCA has not provided additional detail regarding the circumstances of the termination of the contract with CGI Federal or the procurement process.
On a separate note, a federal court ruled the Centers for Medicare and Medicaid Services (CMS) could commence with its Medicare RAC procurement. Contracting for a new set of Medicare RACs was delayed due to a protest of contract terms by one of the RAC firms. CMS hopes to have the new contracts awarded by the end of December. (Andrew Busz, email@example.com)
WSHA Models Hospital Impact of Medicare Outpatient Payment Changes
WSHA provides member hospitals with hospital-specific analyses of the estimated impact of Medicare payment changes. WSHA recently made available a detailed analysis of the proposed 2015 outpatient rule, including hospital-specific estimated impact of Medicare changes, which if adopted will apply to services on or after January 1, 2015. A summary and information on how hospitals can access their reports on the proposed outpatient rule are in our August 25 Bulletin. WSHA is currently working on an analysis of the recently released final 2015 inpatient rule and expects to have that available to member hospitals shortly. (Andrew Busz, firstname.lastname@example.org)
HCA Issues Rulemaking Notices for Administrative Days and Hospital Revenue Codes
Hospitals will have the opportunity to review and comment on two proposed changes to HCA’s rules: Hospital revenue codes and treatment of administrative days. Administrative days are hospital days paid at a skilled nursing payment rate when a patient no longer meets inpatient criteria but placement in an appropriate skilled nursing facility cannot be arranged.
WSHA will be reviewing the changes and commenting when the proposals are available. Hospitals interested in the rulemaking process should respond to the HCA contact indicated in the notices. (Andrew Busz, email@example.com)
340B Drug Pricing Program Recertification Deadline is September 10
Hospitals and other entities participating in the 340B Drug Pricing program must re-certify through the Health Resources and Services Administration (HRSA) by September 10 to retain eligibility under the program. HRSA is required to re-certify annually all participating covered entities to ensure they are appropriately listed on the 340B database and remain compliant with program requirements. More information is available here. (Andrew Busz, firstname.lastname@example.org)