Transcript MEDICARE WAGE INDEX - HFMA Western Michigan

MHA Update
HFMA
March 22, 2012
Vickie R. Kunz
Senior Director
Health Finance
1
Auto No Fault
• Discussions continue with governor’s office and
insurance industry.
• MHA opposes implementation of lifetime limits on
total benefits.
• MHA opposes potential move to fee screen
reimbursement.
– worker’s comp has been discussed
• No guarantee for reduced auto insurance
premiums.
2
Medicare Issues
3
Michigan MAC Transition
• Transition from fiscal intermediary National
Government Services (NGS) for Pt A and Wisconsin
Physician Services (WPS) as Pt B carrier.
• Late January 2012 - Award protest by unsuccessful
bidders – GAO decision confirming WPS as MAC.
• No further information has been released regarding
the transition.
• MAC will perform Medicare FFS claims processing,
enrollment, education, provider audits.
4
Physician Payment Fix
• HR 3630 prevented the 27.4% cut to Medicare
physician payments scheduled to take effect March1.
• Funded by cuts to hospitals:
– Medicare bad debt reimbursement reduced from
70% to 65% in FY 2013 for PPS hospitals.
– Reduced from 100% to 65% over 3-years for
CAHs.
– Extension of hospital OP therapy services cap
through 12/31/12.
– Reductions to Medicaid DSH payments in 2021.
5
Revised SSI Ratios Available
• Used in Medicare DSH payment
calculation.
• Revised FY 2006 -2009 ratios available
on CMS website:
http://www.cms.gov/AcuteInpatientPPS/
05_dsh.asp.
• Includes dual eligible exhausted and
Medicare advantage patient days in the
6
Medicare fraction.
FY2013 Wage Index Timeline
• FY 2013 AWI using data from hospital
– cost reports for FYs ending Sept. 2009 – Aug. 2010
• April 11 – FI/MAC to transmit final revised data to
CMS for inclusion in final FY 2012 AWI.
• April 18 – Deadline for hospitals to appeal FI/MAC
determinations and request CMS’ intervention.
• FY 2013 AWI takes effect Oct. 1, 2012, for IPPS.
7
ICD-10 Deadline Delayed
• See Feb. 20 Monday Report.
• Oct. 1, 2013 implementation deadline
delayed, with no new date.
• MHA encourages hospitals to continue
working toward completing education,
training and system upgrades
necessary system upgrades.
8
HIPAA 5010
• CMS announced 3-month delay from
April 1 to July 1, 2012.
9
Proposed Rule - Reporting of Medicare Overpayments
• Mid-February, CMS released a
proposed rule regarding self-identified
overpayments.
• Health care providers required to report
and return overpayments within 60 days
after the date the overpayment was
identified or date any corresponding
cost report is due.
10
Cont., Reporting of Overpayments
• CMS noted these examples:
– duplicate payments by FI
– Payment for non-covered services
– Payments exceeding the allowable amount
for a covered service
– Medicare payments when other payer had
primary responsibility.
11
Issues Identified to Date
• Would errors by claims processors be
attributed to hospitals?
• Cost report reopening extended from 3
years to 10 years to correspond with
proposed time frame for returning
overpayments.
• MHA reviewing proposed rule and will
provide draft comments prior to April 16
12
deadline.
Medicare Advantage Plans
• As of January 2012, 29 plans in Michigan, with 415,000 or
approximately 24% of Michigan’s 1.7 million Medicare beneficiaries
enrolled.
– Up to 19 plans in some counties.
• Review MA payment rate for all plans.
• CAH entitled to Medicare cost reimbursement.
• Each MA plan may determine own utilization model and is not
required to maintain electronic transactions.
• Many MA have instituted “RAC-like” utilization programs.
• Matrix of MA plans by county available at MHA website – updated
quarterly, with MHA Monday Report article.
– See Feb. 6 Monday Report for latest info
13
Mandatory Medicare Delivery System Reform
FY 2013
Inpatient
Readmissions
• Implemented
October 1, 2012
(FY 2013)
• 1% reduction in
FY 2013,
increasing to 3%
in FY 2015.
• Expected to
reduce Michigan
reimbursement
by $458 million /
10 years.
FY 2015
Inpatient ValueBased
Purchasing
Health CareAcquired
Conditions
EHR Meaningful
Use (ARRA)
• 1% withhold
Implemented
October 1, 2012
(FY 2013),
increasing to 2%
in FY 2017.
• Budget neutral;
redistributive
within PPS
system.
• 1% payment
• Medicare
penalty
payment
• Implemented
penalties
October 1, 2015
assessed against
(FY 2016)
eligible hospitals
• Expected to
and physicians
reduce Michigan
that fail to be
inpatient hospital
meaningful users
reimbursement
by October 1,
by $ 47 million/10
2014 (FY 2015).
years.
What’s at Stake Under VBP?
• Program is self-funded by hospital “contribution”
 Contribution based on Medicare FFS payment*
– 1.0% reduction in FY 2013
– Reduction increased by 0.25% each year
– 2.0% reduction for FY 2017 and beyond
 VBP performance determines P4P amount
 Budget-neutral
– Redistributive
– Best performers win, others break even or lose
– VBP payments are netted against contributions
* Payment reductions exclude IME, DSH low-volume hospitals and outliers.
15
16
VBP Domains
FFY 2013 Program
FFY 2014 Program
Measure
Count
Domain
Weight
Measure
Count
Domain
Weight
Process of Care
12
70%
13
45%
HCAHPS
1
Domain
1
(using 8 HCAHPS
dimensions)
30%
(using 8 HCAHPS
dimensions)
30%
N/A
N/A
3
25%
Efficiency
N/A
N/A
N/A
N/A
Other TBD
N/A
N/A
N/A
N/A
Totals
13
100%
17
100%
(Patient Experience of Care)
Outcomes
(Mortality, HACs, AHRQ)
(2 domains)
(3 domains)
17
ACA Readmission Payment Policy
 Effective October 1, 2012
 Three condition areas to start:
– Heart failure, heart attack, pneumonia care
 Expansion by October 2014:
– COPD, CABG, PTCA, other vascular procedures
 May eventually apply to all-payer, all-conditions, all-cause
readmissions
 Observed-to-expected ratios based on statistical analysis
and national benchmarks
 Payment penalties for O/E ratios greater than 1.
 MHA distributed hospital-specific reports Dec. 21.
Medicare Revenue Forecast
• Distributed to CEOs/CFOs/Directors of
Reimbursement and Government
Relations on Feb. 7.
• Comprehensive analysis of Medicare
revenue and payment reductions for
2012 – 2021, including:
– Affordable Care Act-authorized changes
– Budget Control changes
18
Medicaid Issues
19
FY 2012 Budget
• $14.7 million cut to graduate medical
education (GME) payments.
– 100% of cut will be applied to FFS GME.
• No cuts to provider rates.
• Tax-funded Outpatient Uncompensated Care
DSH pool reduced from $60 million to $50.4
million.
• HRA pool increased from $686 million to $736
million.
20
• $29.5 million Rural/SCH pool.
$29.5 Million Budget Appropriation
• Included in FY 2012 budget appropriation as
“one time funding”.
• Funded by state GF and matching federal $—
no associated provider tax.
• Rural and sole community hospitals (SCHs)
• Payment to individual hospital or system
limited to no more than 5 percent of pool.
21
Cont., $29.5 Million Pool
• MSA opted to distribute these funds as
part of monthly HRA payments.
• $2.9 million distributed monthly
– As part of Dec 2011 – Sept 2012 HRA
– Paid Jan 2012 – Oct 2012
• MSA correction made - February HRA.
• See MHA e-mail from Jan. 12.
22
Cont., $29.5 Million Pool
• MSA defined rural hospitals as:
• not more than 50 staffed beds
– Occupied beds used as a proxy.
• located outside an MSA or
• in a MSA but within a city, village or
township with population of 12,000 or
less and county population of 165,000
or less.
– Based on 2000 census.
23
Cont., $29.5 Million Rural SCH Pool
• Rural hospitals - FY 2010 unreimbursed
costs for Medicaid outpatient FFS and
HMO services.
• Rural & SCHs – add-on payment for
2009 deliveries if hospital still provided
OB services in 2011.
24
FY 2013 Budget
• Executive budget recommendations
released by Governor Snyder Feb 9.
• Recent testimony – House
Appropriations Subcommittee
• Deliberations began in Senate last
week.
25
Continued, FY 2013 Budget
• Additional $17 million cut to GME,
increasing the total cut to $32 million.
• Elimination of $29.5 million Rural/SCH
pool.
26
Medicaid Rates
• MSA revised DRG rates effective Jan. 1
to incorporate updated wage and cost
data.
• Move to Grouper 29.0, consistent with
Medicare.
• DRG weights available on MDCH
website.
• Capital rates updated April 1, may be
27
delayed.
Statewide DRG Rate
• MSA recently provided a concept paper
regarding the move to a statewide DRG
rate with adjustments for teaching,
outliers and wage index.
• MHA and hospitals to provide additional
input.
• Earliest implementation Jan 1, 2013.
28
OPPS Payment Factor
• Effective Jan. 1, Medicaid pays 55.3%
of Medicare rates, excluding an area
wage adjustor for OPPS and ASC
services.
29
FY 2009 DSH Audits Underway
• Requests sent by PHBV Partners to
hospital contacts in mid-February.
• MHA education session held 2/21.
• Requested data due to auditors 3/23.
• Contact Joe Lackey at PHBV with
questions or regarding deadline.
– [email protected]
30
Cont., DSH Audits
• Beginning with audits of FY 2011 DSH
ceilings, hospitals subject to DSH
payment recoveries if audits indicate
DSH payments exceeded their actual
DSH ceilings.
• Prior year audit reports available on
MSA’s website.
31
Medicaid Interim Payments
• MSA evaluating the continuation of
interim payments (MIP) based on
recommendation from a recent
Michigan auditor general report.
• MSA will convene a smaller workgroup
to obtain input and will complete its
review by September.
32
Integrated Care – Dual Eligibles
• Michigan is one of 15 states
• Approximately 200,000 individuals.
• $8 billion total
– $4 billion Medicaid
– $4 billion Medicare
•
•
•
•
•
MDCH Draft plan recently released.
See March 12 Monday Report article.
See March 19 Advisory Bulletin.
Comments due April 4.
Public forums scheduled
– March 20 – Lansing
– March 29 - Detroit
33
MDCH Draft Plan Released
• Draft plan includes two contracts which
would coordinate beneficiary care:
– Existing prepaid inpatient health plans
(PIHPs) for behavioral health services.
– Integrated care organization (ICOs) for
physical health services.
• Michigan split into 3 geographic regions.
• Implementation July 2013 – June 2014.
34
Draft Plan - Issues
• No guarantee of Medicare payment rates.
• Separate contracts with the PIHP & the ICO are
proposed
– both required to “coordinate” care, with neither
ultimately responsible for care of the individual.
• Reporting and payments for Medicare bad debts,
DSH and 340 (b) drug pricing unresolved.
• ICOs would negotiate innovative reimbursement
arrangements with providers.
• No clear direction provided on utilization
management, including inpatient versus observation 35
status.
Bridges / Eligibility Issues
• MHA Feb. 28 letter to Steve Fitton
focused on:
– Delays in Medicaid eligibility resulting in
significant increases in hospital A/R
– Resumption of Bridges Workgroup
Meetings
– Ability of hospital contractors to have
outstation DHS workers
36
Cont., Bridges Issues
• Directors of MDCH and MDHS meeting
with MHA leadership in early April.
• Please email me if your hospital is
experiencing significant delays in
Medicaid eligibility due to Bridges
issues.
37
HMOs & Observation
• Some HMOs have issued policy change
that stays less than 24 hours for
patients meeting inpatient criteria will be
paid as observation.
• Recent MHA meeting with MAHP to
review this issue.
38
GME & HRA Transactions
•
•
•
•
•
•
•
•
March GME Payments
March HRA Payments
March HRA Tax Bills Due
April GME Payments
April HRA Payments
April HRA Tax Bills Due
Q2 Psych HRA Payments
Q2 Psych Tax Bills Due
March 26
April 6
April 20
May 3
May 4
May 18
April 5
April19
39
Engler EO Reductions
• $45.9 million reduction to inpatient DRG and
rehab per-diem payments.
– Carry forward from 2002, 2003, & 2005 E/Os
• Historically, MSA recouped via lump sum
reduction to MIP amounts in Aug/Sept.
• MSA proposed policy would eliminate E/O
recovery and achieve savings in budget neutral
manner via increased FFS QAAP tax.
– Policy not expected to be finalized by MSA.
40
Days in A/R
• Based on 41 hospitals participating in
MHA Monthly Financial Survey (MFS)
• Dec 2011 versus Dec 2010
•
•
•
•
Medicare – up from 33 to 36 days
Medicaid - down from 63 to 54 days
BCBSM – up slightly from 35 to 36 days
Overall – up from 49 to 50 days
41
MHA Resources
• Monday Report is available FREE to anyone and is distributed
via email each Monday morning.
– Go to website and select “Newsroom”, then Monday Report
• MHA Monday Report – electronic publication issued weekly
• Request password if you don’t have one.
– Email Donna Conklin at [email protected] to obtain MHA
member ID number
• Advisory Bulletins – Extensive communications available only to
MHA members, as needed. (Require password to obtain from
website).
• Hospital specific mailings as needed for various impact
analyses, etc.
• Periodic member forums
• See mha.org for other resources.
• Monthly Financial Survey provides free benchmarking of
financial and utilization statistics.
42
Medicare Reports & Information
•
•
•
•
Proposed Rules (IPPS, OPPS, SNF, IRF, IPF, HHA)
Final Rules (IPPS, OPPS, SNF, IRF, IPF, HHA)
Hospital Acquired Condition (HAC) Reports
Quarterly Value Based Purchasing (VBP)
–
–
–
–
–
Quality Indicators
QI Trends
30-day mortality rates (updated annually by CMS)
30-day readmission rates (updated annually by CMS)
HCAHPS
• Recovery Audit Contractor (RAC) Reports
– 1-day stays
– Transfers to SNF
43
??? Questions ???
Vickie Kunz , Senior Director, Health Finance
Michigan Health & Hospital Association
110 West Michigan Avenue, Suite 1200
Lansing, MI 48933
Phone: (517) 703-8608
Fax: (517) 703-8637
email: [email protected]
44