Transcript Slide 1
September 2014 Healthcare Financial Management Association (HFMA) Western Michigan Chapter Grand Rapids Great Lakes Chapter Traverse City Vickie R. Kunz Senior Director, Health Finance Michigan Health & Hospital Association 1 Who is the MHA? • Advocacy organization representing all hospitals in Michigan. • Activities include: – State advocacy and policy on Medicaid funding and policy issues – Federal advocacy and policy on Medicare and Medicaid issues – MHA Keystone Center – Quality Improvement and Patient Safety Initiatives – BCBSM Contract Administration Process • Unique to Michigan 2 Payer Issues • The role of the MHA is to assist in resolving systematic payer issues. • Individual hospital contracts determine terms and conditions and take precedence. • Communicate issues to Marilyn Litka-Klein ([email protected]) or Vickie Kunz ([email protected]) at the MHA. 3 Examples of MHA Involvement in Other Issues • Other activities identified by/for the MHA membership – Maximize federal funding in state Quality Assurance Assessment Program (QAAP) – Medicaid implementation of Critical Access Hospital takeback that included “reject” vs “no-pay”, impact on Medicare reimbursement – Michigan Managed Care Rebid process – Medicaid implementation of MI Health Link (formerly dual eligible project) – HFMA/MPAA/ACMA, etc. outreach – BCBSM DRG Validation Audits 4 CMS RAC Appeals Settlement Proposal • Administrative Law Judge (ALJ) appeals back log – CMS proposes 68% of funds due if hospital withdraws all pending appeals. • Hospitals must submit request for settlement by Oct. 31, 2014. – CMS to provide payment 60 days after CMS acceptance • No timeframe for CMS to accept – PPS hospitals and CAHs are eligible- Rehab and Psych Hospitals are not eligible. • See Sept. 15 MHA Monday Report Article which includes a link to CMS’ Sept. 9 presentation. 5 CMS ALJ Settlement Proposal – cont. • These claims would not be counted for Medicare GME and other cost report reimbursement purposes. • Many hospitals that have appealed to the ALJ have had positive outcomes, therefore diminishing the value of this proposal. • Due to the significant backlog at the ALJ, it may be years before a hospital receives a positive decision and its payment under the current appeals process. • Hospitals are encouraged to carefully evaluate whether to request settlement. 6 IPPS 2015 Final Rule 7 Uncompensated Care Pool -$1.40 Billion 8 2 Midnight Rule & Short-Stay Payment Policy • No changes adopted for two-midnight policy finalized in FY 2014 IPPS rule. • CMS will continue seeking input on short stay payment methodology. – No consensus in comments received 9 Reporting of Hospital Charges • ACA provision requires hospitals to make public a list of standard charges for items/services, including a list of charges for services by MS-DRGs. • No deadline for compliance but sets expectation that hospitals should update the information at least annually, or more often as appropriate. • CMS states that hospitals should either make public a list of their standard charges or their policies for allowing the public to view a list of charges in response to an inquiry. – Can use charge master 10 IME and GME • Finalized proposal to pay the Medicare Advantage IME add-on amount to SCHs paid at the hospitalspecific rate. • IME adjustment factor remains at 1.35. 11 FY 2015 CBSAs • CMS finalized use of the 2010 census data which results in status changes for hospitals located in five Michigan counties: – Ionia – Changes from Grand Rapids/Wyoming CBSA to Rural – Newaygo – Changes from Grand Rapids/Wyoming CBSA to Rural – Midland – From Rural to Midland CBSA – Montcalm – From Rural to Grand Rapids/Wyoming CBSA – Ottawa – From Holland/Grand Haven CBSA to Grand Rapids/Wyoming CBSA. 12 Wage Index Development • CMS accelerated the timeline for developing the Medicare wage index starting with the FY 2016 AWI. • Request for changes to hospital wage and occupational mix data are due to WPS/NGS Oct. 6. – Changes for FY 2017 AWI due in early September 2015. • Feb. 13, 2015 – CMS to release revised FY 2016 wage and OM public use files. • March 2 – Deadline for hospital requests to correct CMS/MAC processing errors. • April 15 – Deadline for hospital appeals 13 Occupational Mix Survey • Survey identical to 2010 but collected calendar year 2013. – Due to WPS or NGS July 1, 2014. • Will be used to adjust FY 2016, 2017, and 2018 AWI. • Preliminary PUF released mid-July. • Non-responding hospitals are encouraged to complete and submit survey now before annual “data scrub” period ends Oct. 6. 14 PRRB Appeals • As a result of comments received, CMS did not finalize its proposal to eliminate the current requirement that a hospital either claim reimbursement on its cost report for a specific item or self disallow and file its CR under protest. • CMS will likely address these provisions in future rulemaking. 15 Overview – Value-Based Purchasing Program • Mandated by ACA starting in FY 2013, funded by 1% withhold from all IPPS hospital payments, increasing by 0.25% to 2% in FY 2017 and future years. • Hospitals can earn more or less than their contribution amount or break even. • Nationally, this program is budget-neutral; however, it will redistribute approximately $1.4 billion in IPPS payments in FY 2015. • Michigan VBP incentive payments estimated to be $700,000 lower than VBP program contribution amount. 16 Value-Based Purchasing Program Hospital Contribution % 1.25% 1.5% 1.75% 2% Domain Scoring FY 2014 (VBP Year 2) FY 2015 (VBP Year 3) FY 2016 (VBP Year 4) Finalized FY 2017 (Year 5) Clinical Processes 45 percent 20 percent 10 percent 5 percent Clinical Outcomes 25 percent 30 percent 40 percent 25 percent 30 percent 30 percent 25 percent 25 percent N/A 20 percent 25 percent 25 percent N/A N/A N/A 20 percent Patient Experience Efficiency/Cost Reduction Safety 17 General VBP Program Trends • Continuously evolving program – – – – Addition of new domains/measures over time National Quality Strategy (NQS)-based domains beginning FY 2017 Measure complexity Hospital Eligibility 18 Readmissions Reduction Program Overview • First payment adjustment was applied Oct. 1, 2012 (FY 2013) • At risk: Hospital-specific IPPS payment penalty of up to: – 1% in FY 2013 – 2% in FY 2014 – 3% in FY 2015 and subsequent program years • Hospitals remain whole or lose and CMS gains • Payment adjusted for hospitals with excess readmissions rates (risk-adjusted hospital rates higher than risk-adjusted U.S. average) FY = Federal Fiscal Year 19 Hospital Readmissions Reduction Program • Five readmission conditions for FY 2015 up from three conditions for FY 2013 and FY 2014: – – – – Acute Myocardial Infarction (AMI); Heart Failure (HF); Pneumonia (PN); New for FY 2015: • Chronic Obstructive Pulmonary Disease (COPD); • Elective Total Hip Arthroplasty (THA); and Total Knee Arthroplasty (TKA) • CMS will calculate the FY 2015 excess readmissions ratios and the payment adjustment based on data from the 3-year time period of July 1, 2010 to June 30, 2013. 20 Hospital Readmission Reduction Program – Cont. • Payment adjustment factor will increase from 2% to 3% in FY 2015 as mandated. • Nationally, program is expected to reduce IPPS payments by $424 million in FY 2015, up from $227 million in FY 2014. – Michigan impact estimated at $22 million reduction in FY 2015. • No changes for FY 2016 program – Based on same 5 conditions as FY 2015 • Addition of one condition area to FY 2017 program: – 30 Day All-Cause Unplanned Readmission Following Coronary Artery Bypass Graft (CABG) • Currently in NQF review for endorsement – Same general measure methodology as other program measures 21 HAC Reduction Program Overview • First payment adjustment will be applied during FY 2015 • At risk: 1% payment penalty applied to Medicare IPPS payment – National impact $369 million cut in FY 2015. – Michigan impact $14 million cut in FY 2015. • Hospitals remain whole or receive payment penalty. • Payment adjusted for hospitals with total HAC score in top quartile (worst performing quartile) • Rules adopted for FY 2015; measures adopted through FY 2017 22 General Program Themes • Increased financial exposure each year (max exposure shown below) HAC = Hospital Acquired Condition (HAC) Reduction Program; RRP = Readmission Reduction Program; VBP = Value Based Purchasing Program 23 IPPS 2015 Final Rule Summary System Component Change Update Factor 1.1% net rate increase (net of all rate adjustments) after budget neutrality for hospitals that meet meaningful use (MU) and IQRP requirements. Wage Index Redefined CBSAs based on 2010 census – besides direct wage index implications, may impact other programs or special designations. Impacts 5 Michigan counties Value Based Purchasing (VBP) Program 1.5% rate reduction with chance to earn back amount withheld or more; increasing by 0.25% annually to 2% in FY 2017 and after. Readmissions Keep pace with national average or subject to up to 3% reduction for FY 2015 Hospital Acquired Conditions (HAC) Hospitals in top quartile (the worst performing) will be penalized 1% - Reduction applies to operating payments and add-ons (DSH, IME, etc) IME/GME Changes in new hospital established programs and how rural hospitals are paid for new programs. DSH 25% of traditional formula calculation; remaining 75% pooled for all DSH hospitals, reduced by uninsured reduction factor and then redistributed to hospitals as uncompensated care (UCC) pool based on low income patient days . – No major changes from FY 2014 final rule but UCC pool $1.4 billion less than in FY 2014. Low-Volume Adjustment Loosened criteria through March 31, 2015 MDH (Medicare Dependent Hospital) Extended through March 31, 2015 LTCH 1.1% rate increase 24 Medicare Payment Challenges • Absent Congressional action, 2% sequestration across-theboard cut continues through FY 2024. • Reduction to annual MB update if hospital fails to comply with IQRP and MU program requirements. • Readmissions Reduction Program – Hospitals at risk for up to 3% in FY 2015. • Value Based Purchasing Program – 1.5% payment withhold, hospitals can earn back that amount, earn more or earn less. – withhold increases to 2% for FY 2017 and beyond • Hospital Acquired Condition (HAC) reduction program – 1% reduction to nearly 25% of hospitals nationally. – Begins in FY 2015 25 Medicaid 26 FY 2015 Budget • New $11 million OB Stabilization Pool – Funded by GF and Federal $. • Maintained GME Funding – Restored $4.3 million • Continued Rural Access Pool - $35.6 million – Funded by GF and Federal $. • New tax-funded $85 Million DSH Pool – $70 Million to be distributed to Large/Urban Hospitals – $15 Million to be distributed to Small/Rural Hospitals • More aligned with hospital provider tax paid to support these payments. 27 Hospital Reimbursement Reform Initiative • 2013 meetings with hospitals, MSA steering committee finalizing areas to implement • Representatives include small, medium, and large hospitals and CAHs • Several ideas discussed: · statewide inpatient rate with hospital adjustors, · APR-DRG for inpatient · Increase in outpatient payments financed with reduced inpatient rates · Medicaid OPPS rates are 53% of Medicare OPPS rates · DSH methodology changes · HRA methodology changes · GME methodology changes 28 FY 2011 DSH Audits • Early-to-Mid October, Myers and Stauffer expected to distribute hospital-specific worksheets. – Hospitals will have 2 weeks to notify M&S of errors • Sept. 30 draft report due to MSA. • Dec. 31 final report due to CMS. 29 FY 2014 & 2015 DSH Payments • FY 2014 Step 1 review occurred in early August, with hospitals having until Aug. 20 to return DSH feedback form to MSA. • FY 2014 DSH payments distributed mid-to-late September. • FY 2015 DSH eligibility form released early September. Hospitals must complete and return to the MSA by Oct. 2 in order to be eligible for FY 2015 DSH payments. – Failure to do so will result in hospital being deemed ineligible for DSH payments 30 Newborn Claim Requirements • • • • • • Dates of service Oct. 1, 2014 and after Type of admission/visit Birth weight C-section/inductions related to gestational age Both FFS & HMO claims Informational edits, but will be required effective Jan. 1, 2015. 31 Healthy Michigan Plan • Enrollment as of Sept. 16 was 385,000 • Statewide $53 million in HRA payments • No QAAP tax associated with these payments • All counties have achieved enrollment • Additional appropriation required for FY 2015 as enrollment has exceeded budget • Despite 100% federal funding, there may be some resistance in the legislature to pass the additional funding bill 32 Continued, Healthy Michigan Plan • CMS confirmed that HMP inpatient days should be included for Medicare DSH calculations. • HRA payments (April – Aug.) = approx. $53 million • No QAAP tax associated with these payments. • Hospital registration staff encouraged to use CHAMPS to determine which patients are HMP versus regular Medicaid. • Can use 270/271 batch transactions • Hospitals required to report both FFS and HMO HMP 33 data separately on MMF. BCBSM DRG Validation • Consultant found BCBSM erred in removing codes for BMI and cerebral edema • Other audit areas for improvement • Sept. 24 education session, webinar available • 2014 audits will be reviewed for compliance with consultant findings • MHA advocated for retroactive adjustment – BCBSM has not finalized retroactive policy 34 Nov. 4 Voters Will Decide…. • • • • • • U.S. Senate (1 seat, open) U.S. House of Representatives (14 seats, 4 open) Governor Attorney General Secretary of State State Supreme Court (2R incumbents, 1 open seat) • State Senate (38 seats, 10 open seats) • State House of Representatives (110 seats, 41 open seats) 35 Michigan Loses Seniority • U.S. Senate – Sen. Carl Levin (35 yrs) • U.S. House of Representatives – – – – – Rep. John Dingell Rep. Dave Camp Rep. Mike Rogers Rep. Gary Peters Rep. Kerry Bentivolio (59 yrs) (23 yrs) (13 yrs) (5 yrs) (2 yrs) Total experience + seniority lost = 137 years 36 General Election 2014 - State Legislature • Senate – 38 seats – 10 open seats – First election since 2011 redistricting – Majority Leader Randy Richardville is term limited • House of Representatives – 110 seats – 41 open seats – 70 lawmakers will have no more than 2 years of legislative experience – Speaker of the House Jase Bolger is term limited 37 Legislative Issues to Watch: Federal Level Likelihood That Congress Will Consider Key Legislation Likely to Consider Uncertain Legislation Unlikely to Consider Before Elections In LameDuck Session In 114th Congress Budget and Appropriations Appropriators are unlikely to finish funding bills before the new fiscal year in October, but will probably pass a continuing resolution, pushing broader budget negotiations into a lame-duck session and beyond Debt Ceiling The federal debt ceiling is currently suspended through March 15, 2015; the 113th Congress is unlikely to propose any hike or extension, but the 114th Congress is certain to consider the issue Export-Import Bank The bank’s charter expires on Sept. 30th, but Congress could reauthorize the institution through a bill in the lame-duck session Tax Extenders Expired and expiring tax provisions may not see action before the midterms, but after the elections, Congress could consider a larger taxation bill Affordable Care Act If Republicans win the Senate, they are certain to vote to repeal the ACA; if Dems hold the chamber, Congress could pass legislation to address the law’s perceived deficiencies Immigration Reform The Senate immigration bill is almost certainly dead, but Congress could move limited immigration legislation in a lame-duck session, or more likely in a new Congress •Analysis •The fact that both parties hope to be in a stronger negotiating position post-elections may mean that Republicans and Democrats wait until 2015 to act on major legislation, gambling on a more favorable composition of the other chamber Sources: Billy House, “Time is Running Out for Big Bills,” National Journal, Apr. 13, 2014; National Journal Research, 2014 . Election 2014 — Call to Action • Meet your candidates for state House and Senate, and candidates for Congress • Use MHA election tools available on the MHA election web page • http://www.mha.org/mha/elections.htm – – – – – Election Materials (table tent, posters, brochure) Election Snapshot Candidate Listing Redistricting Information Non-partisan sources 39 Dates to Remember • Last day to register for general election: Oct. 6 • General election: Nov. 4 40 Objective & Useful Information www.MIVote.org • Non-partisan guide to candidates and issues Secretary of State- michigan.gov/vote • Elections in Michigan website www.MichiganTruthSquad.com • Non-partisan website providing analyses of campaign ads and literature from candidates for Gov., state Legislature and Congress www.mha.org (click on election logo) • MHA election web page containing candidate information and election information pertinent to hospital community 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 (MFS) provides free benchmarking of financial and utilization statistics. 42 ???Questions??? Vickie Kunz Senior Director, Health Finance Michigan Health & Hospital Association 110 West Michigan Avenue, Suite 1200 Lansing, MI 48933 Phone: (517) 703-8608 email: [email protected] 43 DRG Operating Rate – 2015 Final Rule • Labor and Non-Labor Related Standard Rates Hospitals with a Wage Index Greater than 1 (69.6% Labor Share/30.4% Non-Labor Share) Hospitals with a Wage Index Equal to or Less than 1 (62% Labor Share/38% Non-Labor Share) Full Update Labor Non-Labor Related Related $3,780.13 $1,651.09 $3,367.36 $2,063.86 44 Rate Update with Meaningful Use and Inpatient Quality Reporting PASSES BOTH MU AND IQR • Incentives ending for many; penalties starting up • Connects IQR and MU Programs to update factor for PPS hospitals • Creates 4 update scenarios going forward • MU exposure increases over 3 years beginning 2015; IQR holds constant (MU = 25%; 50%; 75% | IQR = 25%) • CAHs = cost-based payment reduced; exposure increases over 3 years beginning 2015 (-0.33%; -0.66%; -1.0%) FY 2015 Market Basket Rate-of-Increase Adjustment for Failure to Submit Quality Data under Section 1886(b)(3)(B)(viii) of the Act Adjustment for Failure to be a Meaningful EHR User under Section 1886(b)(3)(B)(ix) of the Act MFP Adjustment under Section 1886(b)(3)(B)(xi) of the Act Statutory Adjustment under Section 1886(b)(3)(B)(xii) of the Act Proposed Applicable Percentage Increase Applied to Standardized Amount FAILS MU FAILS BOTH MU AND IQR FAILS IQR Hospital Hospital Hospital did NOT Hospital submitted did NOT submit submitted quality data submit quality data quality data and is NOT quality data and is NOT and is a a and is a a meaningful meaningful meaningful meaningful EHR user EHR user EHR user EHR user 2.9 2.9 2.9 2.9 0.0 0.0 −0.725 −0.725 0.0 −0.725 0.0 −0.725 −0.5 −0.5 −0.5 −0.5 −0.2 −0.2 −0.2 −0.2 2.2 1.475 1.475 0.75 45 Cost Outlier Threshold & Capital Rates • Final FY 2014 threshold: $21,748 • Final FY 2015 threshold: $24,758 • Represents a 13.8 percent increase in the cost outlier threshold, resulting in fewer cases being eligible for outlier payments. • Threshold is adjusted annually based on CMS’ projections for total outlier payments so that total outliers payments approximate 5.1 percent of total IPPS payments. • Final FY 2015 federal capital rate of $434.26, up from the current $429.31 – 1.15 percent increase 46 MS-DRGs ― See Table 5 in final rule for file containing weights. MS-DRG 470 – Major Joint Replacement W/O MCC 871 – Septicemia W/O MV 96+ Hrs W MCC 392 – Esophagitis W/O MCC 292 – Heart Failure & Shock W CC 291 – Heart Failure & Shock W MCC 194 – Pneumonia W CC 690 – Kidney and Urinary Infection W/O MCC 683 – Renal Failure W CC 190 – COPD W MCC 193 – Simple Pneumonia & Pleurisy W MCC Total Number of Discharges Final 2014 Weight Final 2015 Weight Percentage Change 435,351 395,147 197,891 196,728 2.1463 1.8527 0.7395 0.9938 2.1137 1.8072 0.7388 0.9824 -1.52% -2.46% -0.09% -1.15% 193,972 179,988 173,875 153,012 151,963 145,156 1.5031 0.9771 0.7693 0.9655 1.1708 1.4550 1.5097 0.9688 0.7794 0.9512 1.1743 1.4491 0.44% -0.85% 1.31% -1.48% 0.30% -0.41% 47 DSH Payments • CMS is required by the ACA to reduce hospital DSH payments based on the expectation that there will be a decreased number of uninsured individuals. • Based on the 2014 final rule and 2015 final rule: ― Hospitals will receive 25% of the DSH amount calculated under the traditional formula. ― The remaining 75% reduced to reflect the impact of insurance expansion under the ACA and redistributed to hospitals as a new and separate uncompensated care (UCC) payment based on each hospital’s UCC ratio relative to the total for all DSH-eligible hospitals. 48 Continued, DSH Payments • Distributing the uncompensated care (UCC) payment pool: Use low-income patient days as proxy • Medicaid days + Medicare SSI days (based on 2011/12 data) • Numerators of traditional DSH % calculation • CMS cites unreliable data on Worksheet S-10 as hospitals are not consistent in reporting bad debt and charity care in terms of hospitals’ costs (% of charges) vs. payment from government or other payors. Calculate uncompensated care payment factor • Hospital's low-income patient days relative to all DSH hospital low-income patient days 49 Continued, DSH Payments • Review the cost report split between the traditional methodology and the revised methodology. • Ensure the hospital is continuing to identify additional Medicaid eligible days. • Review the data reflected on S-10 for accuracy as this will likely be used in the future for distribution of the 75% pool. • In the final rule, CMS stated its commitment to making the necessary revisions and S-10 clarifications. • Prepare the DSH worksheets for all PPS hospitals for each year even if hospital has not qualified historically. • Review the calculation for 340B Drug Program benefit. 50 Two-Midnight Policy • Finalized in FY 2014 IPPS rule. • Under the two-midnight rule, CMS will generally consider hospital admissions spanning two midnights as appropriate for payment under the IPPS. • Hospital stays or less than two midnights will be generally be considered outpatient cases, regardless of clinical severity. – CMS reiterates that there may be rare and unusual circumstances not yet identified that justify IP admission and payment absent an expectation of care spanning two midnights. CMS continues to encourage comments at [email protected], with “Suggested Exceptions to the Two-Midnight Benchmark” in the subject line. 51 FY 2015 Quality Payment Adjustment Factors • VBP Program – Proxy factors on CMS Table 16 are unreliable since they are based on FY 2014 program performance and fail to take into account the new measures, domains, and domain weighting rules. • Readmissions Reduction Program – CMS proxy factors on Table 15A are believed to be pretty solid since based on data for all measures and from correct time • HAC Reduction program – CMS did not release updated “penalty flags” but Table 17 from IPPS proposed rule is believed to be fairly reliable. • CMS to release final tables for all adjustments by Oct. 1. 52 Final Rule Tables • Table 1A-1E • Tables 2-4 • Table 5 • Table 14 • • • • Table 15A Table 16A Table 17 Table 18 Operating & Capital Rates CBSA Delineations & Wage Index Values MS-DRG Weights List of Hospitals with <1,600 Medicare Discharges (used for Low Volume Adjustment) Readmission Factors VBP Program Proxy Factors Hospital-level HAC Reduction Program Medicare DSH Uncompensated Care Payment Factor 53 OPPS 2015 Proposed Rule 54 OPPS Comment Topics • Tracking services provided in off-campus provider-based departments. • Comprehensive APCs • Packaging proposals for Ancillary Services, Prosthetic Supplies and Add-on Code APCs • The reduction in partial hospitalization program payments • Modification of process for accepting new and revised CPT codes. • Hospital OQRP changes • Final rule expected by Nov. 1 effective Jan. 1, 2015 55 Michigan Health Link (Dual Eligibles) • Phased-in implementation of pilot project expected to begin January 1, 2015. • Hospitals responsible to negotiate payment parameters in their contracts. • Nine plans in Macomb/Wayne, two in 8 SW counties, one in UP • No guarantee of Medicare rates for I/P & O/P • Ambiguity in rate for SNF payments 56 Revised DSH Policy • Based on its final policy released October 2012, MSA adopted a multiple-step DSH process beginning with FY 2011 DSH payments: – Step 1: Initial DSH calculation – Step 2: Interim DSH settlement – 2 years after payment – Step 3: Final DSH audit-related redistribution – 3 years after payment 57 DSH Payments and Audits • Beginning with FY 2011 DSH payments: • payments will be recalculated and redistributed using actual hospital data during Step 2. (Key change from past) • hospitals subject to DSH payment recoveries if audits indicate DSH payments exceeded their actual DSH limits. • Audit reports available on MSA’s website for FY 2010 and prior years. • FY 2011 draft report due to MSA by Sept. 30. 58 DSH Audits – Cont. • All Medicaid DSH payments must be considered included in the calculation including: – $45 million regular DSH pool – $60 million tax funded OP Uncomp DSH pool – Gross-payments not net – Indigent Care Agreement (ICA) DSH – Governmental hospital DSH 59 Summary of Hospital QAAP • Available in MHA Advisory Bulletin # 1353 dated 11/25/13. • Provides overview regarding payment allocation for each of the four programs. – Medicaid Access to Care Initiative (MACI) - FFS – Hospital Rate Adjustment (HRA) - HMO – Outpatient Uncompensated Care DSH – Inpatient Psych HRA • The same tax base is used for all four programs. • Data updated annually for both payments and tax. – Can result in change in hospital net benefit/loss. 60 ICD-10 Business-to-Business Testing • Despite implementation delay to Oct. 1, 2015, MDCH testing efforts continue. • MHA strongly encourages hospitals to test ICD-10 claims processing with all payers. • MDCH offering ICD-10 compliant B2B testing for providers pursuing CMS Level II compliance. • Providers should test ICD-10 claims and inquiry transactions using the CHAMPS B2B system. – Work with clearinghouses or billing agents – Submit claims using Michigan’s Single Sign-on (SSO) process 61 62 Medicare Advantage Plans • As of July 2014, 30 plans in Michigan, with 564,000 or approximately 31% of Michigan’s 1.8 million Medicare beneficiaries enrolled. − Up to 21 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. − Aug. 11 MHA Monday Report. 63