Transcript MEDICARE WAGE INDEX - Western Michigan University

MHA Update
HFMA
January 23, 2013
Vickie R. Kunz
Senior Director
Health Finance
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“Fiscal Cliff” Options
• In late November, MHA distributed
hospital-specific reports that reflected
the impacts of various options under
consideration.
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Cuts Considered – Nov 2012
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Recent “Fiscal Cliff “ Bill
• American Taxpayer Relief Act of 2012
included several significant Medicare
payment cuts for hospitals in
conjunction with averting the 27 percent
cut to Medicare physician payments and
delaying the 2% sequester for two
months.
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Medicare Cuts
• IPPS coding adjustment reductions totaling at
least 9.7% over a 4-year period, FY 2014 -17.
• Projected to reduce IPPS payments to Michigan
hospitals by $106 million in FY 2014 and $437
million over the 4-year period.
• Takes effect Oct. 1, 2013.
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Continued, Medicare Cuts
• 58% reduction in Medicare APC payment rate
for APC 0127 (Stereotactic Radiosurgery)
from about $7,900 to $3,300 based on the
payment rate for APC 0067 (Linear
Accelerator based sterotactic radiosurgery).
• Takes effect April 1, 2013.
• Expected to reduce Michigan APC payments
by $400,000 in FY 2013 and $5.6 Million over
the next 10 years.
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Cont., Medicare Provisions
• Increased the statute of limitations for
Medicare overpayment recoveries from
3 to 5 years.
• Implements a therapy multiple
procedure payment reduction which will
reduce payment for subsequent
therapies when provided on the same
7
day.
Cont., Medicare Provisions
• Extends the outpatient therapy services
per beneficiary cap of $1,900 and the
exceptions process through Dec. 31,
2013.
– Continues to apply to services provided in
hospital outpatient departments.
• Includes services provided by critical access
hospitals.
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Cont., Medicare Provisions
• Extended the less restrictive low-volume
payment adjustment criteria authorized
by the ACA until Dec. 31, 2013.
– Expected to increase Medicare FFS
payments by $10.7 million in FY 2013.
– Retroactive to Oct. 1, 2012.
– Unclear whether hospitals have to request
this adjustment as in past years.
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Cont., Medicare Provisions
• Extended the Medicare Dependent
Hospital program until Oct. 1, 2013.
– Expected to increase FY 2013 Medicare
FFS payments to Michigan hospitals by
$1.2 million.
– Retro to Oct. 1, 2012.
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Cont., Medicare Provisions
• 2% sequestration expected to cut
payments to Michigan hospitals by $110
million from March 1 – Sept. 30, 2013,
or almost $1.4 billion over the next 10
years, if implemented.
– Includes hospital-based services
• Rehab, Psych, Home Health, LTCH, etc.
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American Taxpayer Relief Act
• Hospital-specific reports distributed
Jan. 10, to CEOs/CFOs/Directors of
Reimbursement/Government Relations.
• Concern remains that additional cuts
will occur during debt ceiling increase
negotiations in Washington DC.
– Will the 2% sequestration be changed?
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Michigan Statewide Impact
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Federal Advocacy Efforts
• MHA will participate in Feb 13 AHA
Advocacy Day in Washington DC.
• MHA coordinating Michigan hospital
advocacy day Feb 26.
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ACA Impact - DSH Payments
• Beginning Oct 1, 2013, 75% of hospitalspecific Medicare DSH payments will be
based on total Medicare DSH payments
adjusted to account for the estimated
decrease in the number of uninsured
patients, with hospital allocations based on
their portion of total uncompensated care
provided by all DSH hospitals.
• No further DSH policies available until
FY 2014 IPPS rule is released in April 2013.
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Outpatient Therapy Services
• 2013 collection of claims-based data on
patient functional status over an
episode of PT, OT and SLP services.
• All therapists will be required to report
new G-codes and modifiers on the claim
form:
– initial evaluation, every 10 visits and at
discharge.
– CMS will adopt testing period thru June 30.16
CRNAs
• Beginning Jan. 1, CRNAs may directly
bill and be reimbursed by Medicare for
services determined by the state to be
within their scope of practice, including
chronic pain management services.
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Imaging Services MPPR
• 25% multiple procedure payment reduction to
the technical component of diagnostic
cardiovascular services.
• 20% MPPR to the technical component of
diagnostic ophthalmology services provided
by the same physician (or group practice) to
the same patient on the same day.
• May impact hospital payments for technical
component for services performed.
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Medicare Advantage Plans
• As of Oct 2012, 30 plans in Michigan, with 455,000 or approximately
26% of Michigan’s 1.7 million Medicare beneficiaries enrolled.
– Up to 20 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 Oct 29 MHA Monday Report for latest info
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FY 2014 Wage Index
• Feb 6 – Deadline for FIs/MACs to
complete desk reviews.
• Feb 21 – Release of revised PUF
• March 3 – Deadline for correction
requests.
• April 10 – Deadline for final revised
wage index.
• April 17 – Deadline for hospital appeals.
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• Oct 1 – FY 2014 takes effect.
Medicaid Issues
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Medicaid Redesign
• MSA announced that they will begin a formal
project to review and redesign the Medicaid
payment system.
• MSA may consider inpatient and outpatient,
capital, MACI, HRA, GME and DSH
payments.
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FY 2014 Budget
• Gov. Snyder’s executive budget
proposal expected February 7.
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FY 2013 Rural Pool
• MSA proposes to distribute $8.3 million
through Medicaid FFS upon CMS approval
and $25 million through Medicaid HMOs as
part of the monthly HRA process.
• See MHA comment letter included in Jan. 14
MHA Monday Report – comments due to
MSA Jan. 18.
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Cont., Rural Pool Proposal
• MSA proposes to calculate each
hospital’s allocation from this pool
based on unreimbursed cost for
inpatient and outpatient services using
FY 2011 cost report data.
• Payments must include gross MACI,
HRA, and GME.
• MSA proposes to use same eligibility
criteria used for FY 2012.
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MHA Rural Comments
• Requested MSA to distribute approx
$2.5 million in unspent funds based on
the number of Medicaid deliveries to
hospitals that experienced a decline in
rural payments between FY 2013 and
2012 and provide OB services.
• Provide data to hospitals for validation
prior to finalization of payment amounts.
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CSHCS Beneficiaries
• HMO enrollment for children dually
eligible for Title V and XIX.
• Change effective Oct. 1, with enrollment
staggered through March.
• Medicaid FFS hospital payments for this
population of 20,000 children are
approximately $135 million annually.
– MSA shifted $103 million from FY 2012
MACI to HRA to reflect this impact.
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Medicaid Rates Updated
• Updated hospital DRG and capital rates
effective Jan. 1.
– Available on MDCH website.
• MS-DRG relative weights also updated
effective Jan. 1.
• Medicaid OPPS payment factor reduced
to 54.3 % of Medicare rates, excluding
an area wage adjustor.
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Cont., Medicaid Rates
• Also effective Jan. 1, Medicaid changed
from paying claims based on rates and
DRG weights in effect on date of
admission to paying based on date of
discharge.
– Consistent with Medicare and other payers
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Medicaid DSH Audits
• Hospitals encouraged to review
FY 2009 Medicaid DSH audit report and
data on MSA website.
• Prior year audit reports available on
MSA’s website.
• FY 2010 audits expected to begin soon.
– Watch for info on MHA education session
scheduled for morning of March 7.
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Final DSH Policy
• Oct. 1, MSA released its final policy
using a multiple-step DSH process:
– Initial DSH payment
– Interim DSH payment revision
– Final DSH audit-related redistribution
• CMS has not yet approved the MSA’s
revised DSH process.
• Unlike historical DSH payments, DSH
payments will be subject to change.
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Post Stabilization Proposal
• MSA proposed policy captures much of same intent
as Dec. 2009 L-Letter.
• In its November comments, the MHA recommended
that the MSA add:
• “An authorization for inpatient admission may not be
subsequently reversed based upon the length of time
the patient is hospitalized.” Patient status and the
need for inpatient services as determined by a
physician should be the determinant for inpatient
payments rather than the length of time the patient
remains an inpatient.
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Cont., Post Stabilization
• The MHA believes the policy should
apply to non-contracted hospitals that
have signed the hospital access
agreement (HAA).
• The MHA believes the policy should not
apply to hospitals that have not signed
the HAA.
• See Nov. 19 and Jan. 14 MHA Monday
Report articles and comment letters. 33
FY 2013 Supplemental Pools
• MACI – Decrease from $640 million to
$564 million after shift for CSHCS
beneficiaries.
• HRA – Target $839 million
• Psych HRA - $45 million
• OP Uncomp DSH - $60 million
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FY 2013 Provider Tax
• Hospital tax based on data from
FY 2011 cost reports.
• Hospitals identified inconsistency due to
GAAP change and reporting of bad debts.
• MSA provided hospitals with an opportunity to
amend their FY 2011 cost reports by Dec 31,
with acceptance required by March 31.
• MSA will revise tax base retro to Oct. 1.
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MIP & CIP
• MSA will change from biweekly
payments to monthly payments.
• Proposed policy expected in next few
months with implementation about 6
months later.
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Integration of Dual Eligibles
• Tentative agreement between MDCH
and CMS announced on Dec. 21.
• Regional vs statewide implementation.
• Request for proposal for ICOs expected
to be issued in mid/late February.
• ICOs to be selected by July, with a
Jan 2014 target for active enrollment.
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Health Care Advocacy Day
• 8 a.m. to 1 p.m. on April 17 in Lansing.
• MHA
• Michigan Association of Healthcare
Advocates
• Michigan Healthcare Volunteer
Resource Professionals
• Registration available on MHA website
by March 15.
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BCBSM Mutualization
• In late December, Gov. Snyder vetoed legislation to
transition BCBSM to a nonprofit mutual disability
company regulated under the state insurance code.
– Governor’s decision was influenced by provisions
added to the bills that would have changed how
the insurance market administers coverage for
abortion services.
• Legislation expected to be re-introduced by the 97th
legislature.
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BCBSM Fee Screens
• Certain outpatient services currently paid as a
percentage of charges will be converted to
fee-based payments effective April 1, in
accordance with the BCBSM PHA.
• Change affects emergency, observation, treat
room, dialysis, general therapeutic, diabetes
education, cardiac rehab, pulmonary rehab,
clinic, urgent care, ambulance.
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Cont., BCBSM Fee Screens
• Fee screen payments available on
Web-DENIS by HCPCS.
• BSBSM intends to implement the
change in a budget-neutral manner for
first year of implementation.
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BSBSM MA
• Outpatient claims for dates of service on and
after Jan 1, 2013, will be paid at 2012 rates
until new rates installed.
• 2013 rates expected to be installed around
Jan 23.
• 2013 claims to be reprocessed.
• New vendor and claims processing system.
• Hospitals will receive payments once per
week instead of twice.
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Days in A/R
• Based on 39 hospitals participating in
MHA Monthly Financial Survey (MFS)
• Jan – Oct 2012 versus 2011
•
•
•
•
Medicare – down from 34 to 33 days
Medicaid - down from 51 to 50 days
BCBSM – up from 34 to 35 days
Overall – unchanged at 47 days
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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.
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???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]
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