WSHA Sends Reports to Hospitals Regarding CMS Knee and Hip Replacement Initiative

August 6, 2015

The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule requiring prospective payment hospitals that provide hip and knee replacements in selected metropolitan areas to participate in a new bundled payment initiative.

Read the proposed rule here.

Hospitals will be responsible for the quality and cost of an episode of care ending 90 days from the date of the hip or joint placement procedure, including skilled nursing and other medical services related to the procedure. The program applies to hospitals that perform hip and knee replacement surgery in Snohomish, King, Pierce and Clark counties for services after January 1, 2016.

WSHA issued a bulletin (read it here) and sent hospital-specific reports to the hospitals that that will be part of the initiative under the proposed rule. The program does not apply to hospitals outside the four counties listed, but the program could be implemented more broadly in the final rule or afterwards. WSHA’s Decision Support team can provide reports for any member hospital that does hip and knee replacements to enable hospital staff to compare the cost for their patients compared to the regional and national averages. To request a report for your hospital, please contact Jonathan Bennett at  (Andrew Busz)

Congress Passes Bill Requiring Hospitals Notify Patients of Observation Status

Congress passed a bill last week requiring hospitals to notify, orally and in writing, Medicare patients whom are placed in observation status for longer than 20 hours. Read the bill here.

The requirement will not go into effect for 12 months, as some details regarding content of the notification are subject to the federal rulemaking process. WSHA is preparing a bulletin that will provide an overview of the bill provisions. WSHA will also review and comment on the proposed rule when it is released. 

WSHA will convene a work group of staff from member hospitals to review the provisions in the law and identify best practices for policies and communications related to the requirements. Since observation is considered an outpatient service and impacts patients’ insurance benefits, there is interest among Washington State legislators for a notification law that would go beyond Medicare enrollees. During the past legislative session, a more comprehensive observation notification bill (HB 1186) passed the House but did not pass the Senate by the end of session. The work group may consider a notification process that can be applied beyond the Medicare population to avoid a potentially conflicting set of state and federal requirements. (Andrew Busz)

Health Care Authority Releases Stakeholder Draft of Readmissions Policy Rules for Comment

The Health Care Authority released a stakeholder draft of rule changes to its readmissions policy. Going forward, HCA will use 3M software to compare each hospital’s readmission rates with an expected rate based upon its mix and severity of cases, and it will apply a prospective adjustment factor to prospective payment hospitals’ inpatient payment rates. Critical Access Hospitals (CAHs) will receive data but will not be subject to payment penalties. The new readmissions policy replaces the current policy of review and denial of individual readmission claims. HCA and Navigant staff have met with and received input from a WSHA task force of finance and quality leaders from member hospitals.

More information is available in our recent Fiscal Watch article.

We encourage hospitals to review the stakeholder draft. Contact Andrew Busz at if you have specific concerns or suggestions prior to the August 17 due date. If you comment directly to HCA, please provide us with a copy of your comments.

Below is the invitation for comment we received from HCA:

Dear Interested Parties:

Attached for your review and comment is proposed new WAC 182-550-3840—Payment adjustment for potentially preventable readmissions.

Purpose:  The prevention of inpatient hospital readmissions is a recognized issue at the federal and state level, affecting patient health and costing taxpayers unnecessary dollars. The new rules would support the reduction of inpatient hospital readmissions, improve the quality of care, and reduce waste.
Comments are due by COB on August 17, 2015

Please return comments on the proposed rule to:
Melinda Froud, Rules and Publications Program Manager, at: or fax to (360) 586-9727.

Direct policy questions to:
Gail Kreiger, Manager, Health Care Services, via email at:
Thank you for your interest in the Agency’s rule making process.
(Andrew Busz)

Bree Collaborative Makes Recommendations for Cardiac Artery Bypass Graft

The Bree Collaborative — a group appointed by the governor representing clinical leaders from purchasers, providers and state agencies — met July 22 to consider new recommendations for cardiac artery bypass grafts (CABG). Once adopted, the collaborative will submit the final report to the Washington State Health Care Authority, which can elect to use the report’s recommendations to inform contracting and purchasing for Medicaid and state employee programs. We anticipate future Health Care Authority contracts will contain more recommendations and practice guidelines from the Bree Collaborative.

The collaborative is interested in hearing your feedback on the latest draft report and recommendations. Please read the documents and provide feedback via the online survey here.

Feedback to the Bree Collaborative must be received by 5 p.m. Friday, August 21. Please also give your comments or issues to Ian Corbridge, WSHA Policy Director for Clinical Issues, at (206) 216-2514.

General Accounting Office Seeks Provider Input on Timeliness of Veterans Health Administration Payment

The U.S. General Accounting Office (GAO) is reviewing the timeliness of payment from the Veterans Health Administration (VA) to non-VA providers and plans to issue a written report late this year or early in 2016. WSHA is working with the American Hospital Association to obtain member input to share with the GAO. If you have input to provide on the following questions, please submit it to Andrew Busz at before the end of August. The GAO report will not mention specific hospitals.

  1. In general, what has been your hospital’s experience with the Veterans Administration’s claims processing? What challenges, if any, have you experienced in (a) providing VA with the information necessary to process claims or (b) receiving payment from VA for these claims?
  2. If you have had difficulty in obtaining timely payments on claims you submit to the Veterans Administration, about how long does it usually take to receive payments?
    1. Approximately how long (in months or years) have you been awaiting payments on you most aged claims?
    2. How does the timeliness of payments from the VA, compare to that of Medicare and TRICARE?
  3. In the last year, have you observed any changes (positive or negative) in the timeliness of the Veterans Administration payments or general provider customer service?

 (Andrew Busz)

ZeOmega: HIE-enabled Population Health Management Solutions   

ZeOmega, a Washington Hospital Services Industry Partner,  provides solutions that ensure your patient populations are receiving the appropriate care, and that you’re in alignment with payer requirements. If you are looking for assistance with any of the topics discussed in this newsletter, ZeOmega may be a valuable resource to consider.  To learn more about them, please visit  (Paul Unsworth)


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