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Category: Rural Health

FFY2021 Medicare IPPS Proposed Rule & Other Recently Published Rules

IPPS Proposed Rule – FFY2021

CMS-1735-P drafted on 5/11/2020; Published in the Federal Register on 5/29/2020

On May 11, 2020, the Centers for Medicare & Medicaid Services (CMS) proposed a rule that focuses the agency’s efforts on a singular objective:  transforming the healthcare delivery system through competition and innovation to provide patients with better value and results.  The proposed rule updates Medicare payment policies and rates for hospitals under the Inpatient Prospective Payment System (IPPS) and the Long-Term Care Hospital (LTCH) Prospective Payment System (PPS), effective for discharges on or after October 1, 2020.

The policies in the IPPS and LTCH PPS proposed rule would bring significant changes to MS-DRG weights, along with associated cost report changes, as well as tightening of Medicare bad debt policies, standardization of data collection periods for quality programs, and easing of GME program closure policies.

Overall, the proposed rule is projected to result in an estimated increase of $2.0B (or 1.6%) in payments to providers, with smaller increases for urban, Medicare-dependent hospitals and larger increases for Mid-Atlantic and Pacific region hospitals.

Comments must be sent to CMS no later than 5pm EDT on July 10, 2010 at the applicable address provided in each section of the Proposed Rule or submitted electronically at http://www.regulations.gov.  When commenting, please refer to file code CMS-1735-P.


Medicare IPPS Base Rates

CMS is proposing a base rate increase of 3.2% for hospitals, mostly driven by a market basket increase of 3.0% and the reversal of the MACRA coding adjustment of 0.5%.  A new budget-neutrality factor adjustment was introduced this year to account for the change in Allogeneic Stem Cell Acquisition reimbursement to cost-based.

Click here for the full base rate calculation table and comparison to prior year.


MS-DRG v38 Changes

CMS has proposed their annual recalibration of the MS-DRG weights for FFY2021.  Transplants and one extensive burn DRG (927) have once again received the largest increases, while other heart assist devices and intracranial vascular procedures with hemorrhages have experienced significant reductions in weighting.  A listing of the largest changes in weighting between MS-DRGs v37 and v38 are noted below:

Click here for a table of the MS-DRG v37 to v38 comparison.

In addition, CMS has proposed the following new DRGs for FFY2021, some of which were further subdivisions of previous DRGs:

Note:  New MS-DRGs 521 and 522 will both be subject to the special transfer payment adjustment.

The proposed fixed-loss outlier threshold for FFY2021 is $30,006.


Proposed Market-Based MS-DRG Weights Beginning in FFY2024

In an effort to reduce the cost of healthcare, CMS has proposed a radical shift in how it hopes to compute the weighting for MS-DRGs in FFY2024 and beyond.  CMS believes that by moving from the cost-based DRG weight methodology that was introduced in FFY2007 to the proposed weighting methodology that would reflect the relative market value for inpatient services, it can reduce its reliance on hospital chargemasters for determining DRG reimbursement.

Building on the Hospital Price Transparency Rule (84 FR 65538, 11/27/2019), CMS believes that hospitals will be able to calculate median payer-specific negotiated charges for each MS-DRG, as they will already be required to gather and publish much of this data.  CMS recognizes that this cost report data would become publicly accessible, but because only the de-identified median values would be reported, any proprietary information would not be exposed.

CMS has proposed to begin gathering this data from hospitals by making changes to the Medicare cost report forms for cost reporting periods ending on or after January 1, 2021.  Hospitals will be required to tabulate and report for each MS-DRG the median payer-specific negotiated charges for all Medicare Advantage payers and for all combined third-party payers.  The required cost reporting changes will be proposed in more detail in the Information Collection Request approved under OMB No. 0938-0050.

CMS is seeking comment on this proposed weighting change and its relative burden of calculating, as well as other issues that may address payers that don’t pay under MS-DRGs and whether or not a transition period to these new market-based MS-DRGs should be provided.  Hospitals that do not negotiate payment rates, such as federally-owned facilities, Indian Health Service facilities, Critical Access Hospitals (CAHs), and hospitals located in Maryland, would be exempted from this proposed data collection.


Cost-based Reimbursement for Allogeneic Hematopoietic Stem Cell Acquisition Costs

CMS is proposing to begin reimbursing on a reasonable cost basis the acquisition costs associated with allogeneic hematopoietic stem cell transplants (i.e., when stem cells are obtained from a donor rather than the recipient).  Currently, these costs are included within the MD-DRG payment.  The proposed cost reimbursement will be similar to the methodology in which the acquisition costs for solid organs are reimbursed.  Providers will be billed and paid for these costs on an interim payment basis as a “pass-through” item.

Effective for cost reporting periods beginning on or after October 1, 2020, hospitals that provide these services will need to begin following these procedures:

  1. Gather and report acquisition costs on Line 77 of the Medicare cost report
    • (Note: This has been a requirement for services rendered on or after January 1, 2017.)
    • Acquisition costs include registry fees, tissue typing, donor evaluation, costs associated with the collection procedure, post-procedure evaluation of the donor, and the preparation and processing of stem cells
    • Overhead allocations associated with these costs will also be allowed. CMS is developing a worksheet similar to Worksheet D-4 to allow providers to capture these costs, as well as to report charges by routine and ancillary cost centers.
  2. Formulate a standard acquisition charge, and include this charge on the inpatient hospital bill for the MS-DRG using Revenue Code 815
  3. Tabulate the hospital’s Medicare share of costs by developing a ratio of the number of allogeneic hematopoietic stem cell transplants furnished to Medicare beneficiaries to the total number of those same procedures furnished to all patients

Toyon’s Take:  Because these amounts will now be reimbursed on a reasonable cost basis, it is important that hospitals verify that they are properly capturing all of these costs and statistics in order to ensure adequate reimbursement. 

For additional information or assistance with calculating these amounts, please contact Robert Howey at robert.howey@toyonassociates.com.


Clarification of Long-Standing Medicare Bad Debt Policies

In an effort to clarify the rules related to the demonstration of a reasonable collection effort, CMS is clarifying the policies related to claiming Medicare Bad Debts:

  • Similar Collection Efforts: CMS is stressing that the reasonable collection effort required for a non-indigent Medicare beneficiary must be similar to the effort made by the provider and/or collection agency acting on the provider’s behalf, puts forth to collect comparable amounts from non-Medicare patients.  The hospital needs to have a consistent collection policy for all payers.  Hospitals should be prepared for the MAC to sample and review both Medicare and non-Medicare patients during audits.
  • Timely Beneficiary Bills: A provider must issue a bill to the beneficiary or party responsible for the beneficiary’s personal financial obligations on or before 120 days after
    1. The date of the Medicare remittance advice; OR
    2. The date of the remittance advice from the beneficiary’s secondary payer, if any, whichever is latest

(Note:  Reasonable collection efforts include subsequent billings, collection letters and telephone calls, or personal contacts constituting a genuine collection effort.)

  • Determining Uncollectibility: A provider must make reasonable and customary attempts to collect a bill for at least 120 days from (and including) the date the first bill is mailed to the beneficiary.  If the debt remains unpaid on the 121st day from the date the first bill is mailed, the provider can cease collection efforts and write off the unpaid balance.  If a partial payment is received within the 120-day collection effort period, the 120-day time period resets on the date the partial payment is received.  The hospital must continue to bill the beneficiary for 120 days.
  • QMB Liability: For Qualified Medicare Beneficiaries (QMB), the State Medicaid program must be billed.  If the State does not provide a Medicaid RA, CMS is considering adopting a policy that the provider could obtain and submit to its MAC some form of alternative documentation to evidence a State’s Medicare cost-sharing liability (or absence thereof).  CMS welcomes suggestions from stakeholders regarding the best alternative documentation to the Medicaid RA that a provider could obtain and submit.
  • Write-Off Procedures: All Medicare bad debt, including Medicare/Medicaid crossover claims, must not be written off to a contractual allowance account but must be charged to an expense account for uncollectible accounts (e.g., bad debt or implicit price concession).  This would be effective for cost reports beginning on or after October 1, 2020.  CMS had previously stated that this would be effective for cost reports beginning on or after October 1, 2019, so it appears that providers will be granted additional time to implement these internal procedures.
  • Presumptive Charity: CMS is also proposing clarification to the definition of presumptive charity.  For a hospital to define an indigent non-dual eligible beneficiary, the provider must apply its customary methods under the following requirements:
    1. The beneficiary’s indigence must be determined by the provider;
    2. The provider must take into account a beneficiary’s total resources, which include but are not limited to, an analysis of assets (i.e., only those convertible to cash and unnecessary for daily living), liabilities, and income and expenses (Note: Extenuating circumstances affecting the determination of the beneficiary’s indigence must also be considered.); AND
    3. The provider must determine that no source other than the beneficiary would be legally responsible for the beneficiary’s medical bill (e.g., legal guardian).

Toyon’s Take: The provider must maintain and be ready to provide documentation describing the method by which indigence was determined.  Once indigence is determined and there has been no improvement in the beneficiary’s status, the bad debt may be deemed uncollectible without applying a collection effort.  Providers should review their Financial Assistance Policy, and if presumptive charity is being used as a method to determine indigence, we recommend sending a comment to ensure that CMS will allow this as a reasonable method in determining indigence.

For additional information, please contact Dylan Chinea at dylan.chinea@toyonassociates.com


Changes to Wage Index

Based on the CMS proposed changes for FFY2021, the occupational-mix adjusted national average hourly wage is estimated to be $45.07, representing an increase of 2.10% from the prior year.

CMS proposed and finalized a policy in FFY2020 to reduce wage index high-to-low disparities by increasing the values for low wage index hospitals below the 25th percentile (or a WIF of 0.8420 in FFY2021). In FFY2020, CMS anticipated that it would continue this policy for at least four years, acknowledging that providers in these lower-quartile states would improve employee compensation within four years as a result of the higher wage index. Accordingly, CMS is proposing to continue this policy in FFY2021. Consistent with the finalized policy in FFY2020, in FFY2021 CMS will “fund” this policy by applying a uniform budget neutrality adjustment. The proposed low wage index hospital policy budget neutrality factor is 0.998241 (compared to 0.997987 in FFY2020).

In FFY2020, CMS also proposed and finalized a change to the rural floor calculation by removing urban-to-rural reclassifications from the statewide rural floor. CMS is proposing to continue this policy in FFY2021 so that state rural floors would be calculated without including the wage data of urban hospitals that have reclassified as rural.

As a result of the policy changes noted above, CMS finalized a cap of 5% on the decrease of any hospital’s wage index from FFY2019 to FFY2020. While this cap was set to expire in FFY2020, CMS is proposing to continue to apply this cap in FFY2021 and apply a budget neutrality adjustment for this proposed transition policy in the same manner as FFY2020. The reason for the cap in FFY2021 is a result of the Office of Budget & Management (OMB) updates noted below.

CMS Proposed Changes to Core-Based Statistical Areas (CBSAs)

The wage index is calculated and assigned to hospitals on the basis of the labor market in which the hospital is located, based on OMB-established CBSAs. The current OMB delineations are based on OMB Bulletin No. 13-01 issued on February 28, 2013, which revised a number of CBSAs starting with FFY2015 due to changes in 2010 Census data. Normally, Census data only impacts CBSA delineations every 10 years; however, OMB Bulletin No. 18-04 issued on September 14, 2018, contained material changes to the OMB statistical area delineations. Specifically, under these revised OMB delineations, new CBSAs would be created, urban counties would become rural counties, rural continues would become urban counties, and some existing CBSAs would be split apart. In addition, the revised OMB delineations affect various hospital reclassifications, the out-migration adjustment (accounting for employee commuting patterns), and the treatment of hospitals located in certain rural counties known as “Lugar” hospitals.

CMS is proposing to incorporate the revised OMB delineations from OMB Bulletin No. 18-04 in FFY2021 to “increase the integrity of the IPPS wage index system by creating a more accurate representation of geographic variations in wage levels.”

The proposed changes to current CBSA designations due the revised OMB delineations include the following:

  1. Urban counties that would become rural
  2. Rural counties that would become urban
  3. Urban counties that would move to a different urban CBSA

Click here for tables listing the proposed changes to the counties noted in #1 – 3 above.

As mentioned above, and to mitigate any potential impact to a CBSA’s wage index due to the revised OMB delineations, CMS is proposing a transition policy to apply a 5% cap on any decrease to a hospital’s proposed FFY2021 wage index from the hospital’s final wage index from FFY2020. This policy would be made budget neutral consistent with the last fiscal period in which revised OMB delineations were applied (FFY2015). The proposed budget neutrality as a result of this transition policy is 0.998580.

Click here for a comparison of current and prior WIFs for each hospital, which includes the proposed transition policy cap of 5%.

Toyon’s Take:  The transition policy as proposed by CMS to apply the revised OMB delineations is appropriate and consistent with past year’s where CMS had to apply similar revisions to the CBSA designations. The impact to urban hospitals as a result of the revised OMB delineations is minimal with the exception of hospitals in the Northeast, primarily New York-New Jersey, as a number of counties were redefined to new CBSA designations and “moved out” of New York City which historically has produced a higher wage index for such hospitals. The impact to these hospitals specifically will be mitigated in FFY2021 as proposed due to the transition policy; however, beyond FFY2021 the impact could be significant. Hospitals in these areas need to pay close attention to their wage index filings and consider any reclassification opportunities, and also, if a hospital in these areas has an existing MGCRB reclassification, it should review the reassignment policy as proposed by CMS to ensure the hospital is reclassified to the expected geographic area.

Other Proposed Changes Impacting Wage Index

  • CMS acknowledges an increase in the number of wage index appeals relating to MACs’ disallowance of wages and hours that hospitals believe are associated with Part A administrative physician time but which the MACs believe are not properly documented as such, or are associated with Part B billable activities, which would not be allowable for wage index reporting.
    • While CMS does not propose any changes to how hospitals are to document Part A administrative physician time, it provides clarification and specific instructions as stated in the PRM.
  • CMS is proposing changes to existing regulations to allow MGCRB appeals to be submitted electronically, by fax, or by other electronic means.
  • Applications to the MGCRB for FFY2022 reclassifications, as well as cancellations and terminations, are due by September 3, 2020. All applications and supporting documents must be submitted via the Office of Hearings Case and Document Management System (OH CDMS) consistent with FFY2021 applications.
  • A new measurement of occupational mix is required for FFY2022. The Calendar Year (CY) 2019 Occupational Mix Survey was originally due July 1, 2020 via email attachment or overnight delivery to hospitals’ MACs; however, CMS is granting an extension until August 3, 2020 for hospitals nationwide. Refer to the final CY 2019 Occupational Mix Survey Hospital Reporting Form available on the CMS website at: https://www.cms.gov/medicaremedicare-fee-service-paymentacuteinpatientppswage-index-files/2019-occupational-mix-survey-hospital-reporting-form-cms-10079-wage-index-beginning-fy-2022

For additional information regarding wage index changes or updates, please contact Ryan Sader at ryan.sader@toyonassociates.com.


UC DSH Payments

CMS is proposing a decrease to Medicare UC DSH payments by $534M (or 6.4%), to $7.8B in FFY2021.  This decrease is driven by a $1.2B decrease in CMS’s estimation of national DSH payments for FFY2021, as compared to FFY2020.  National DSH payments are calculated under the former “empirical” method without accounting for changes from the ACA (i.e., Medicare UC DSH) in the determination of Factor 1 for UC DSH payments.

CMS has four significant proposals for UC DSH in FFY2021:

  • The most recent available single year of audited W/S S-10 will be used for Medicare DSH UC payments for all subsequent fiscal years. CMS proposed to add a new paragraph regarding this change under 42 CFR 412.106, “Special Treatment: Hospitals that serve a disproportionate share of low-income patients.”
  • Hospital UC DSH payments (Factor 3) are determined from one base-year of W/S S-10 UC costs from FFY2017 cost reports
  • To avoid the duplication of UC costs, hospitals acquired under a merger partway through the surviving hospital’s cost reporting period will not have their respective W/S S-10 UC cost data annualized
  • The trim methodology for all-inclusive rate providers (AIRP) will be modified. CMS proposes to recalculate UC costs for AIRPs, with UC costs greater than 50% of total operating costs, by applying a cost-to-charge ratio from the most recent available prior year cost report whereby UC costs are not greater than 50% of total operating costs.

Toyon is in the process of updating our national analysis to assist our clients with the evaluation of FFY2017 data used for FFY2021 UC DSH payments.  We will be providing this analysis over the coming weeks.

Toyon’s Take:  CMS’s projection of the uninsured population for Factor 2 includes insurance enrollment estimates through 2018.  Given the extraordinary events of COVID-19, projecting national uninsured rates may necessitate a more recent consideration of the timeliness of these estimates.

CMS’s proposal to use a single year of UC cost as the basis of UC DSH payments (Factor 3) is a significant change to the UC DSH reimbursement system.  Including this year’s audit of FFY2018 data (likely to be used for FFY2022 UC DSH payments), CMS and its MACs audited UC cost from W/S S-10 the last three years.

It is anticipated these audits will be an annual cycle of reported UC cost on the Medicare cost report.  The UC cost audits are also aligned when hospitals are preparing UC DSH listings on current year cost reports.  While annual audits are in place, Toyon recommends hospitals report current year UC DSH listings with the intent of amending these listings before or during the W/S S-10 audit. Moreover, from our work with MACs, it is Toyon’s understanding amended cost reports are NOT required to revise UC costs (rather this data is being documented independently resulting from the MAC audit schedules into the CMS HCRIS database).  

CMS’s use of FFY2017 data for FFY2021 payments also indicates the Agency’s decision to bypass the use of UC cost data from FFY2016.  As providers submit UC DSH listings for FFY2018 and subsequent years, Toyon recommends hospitals consider the appropriateness of reporting reversals related to FFY2016 UC cost write-offs.  In other words, it may not be appropriate to remove cost that CMS did not use in the development of UC DSH payments.

Click here for the DSH Supplemental PUF data.

Click here for the Analysis of UCC DSH Factor 1.

For additional information, please contact Fred Fisher at fred.fisher@toyonassociates.com.


High Percentage ESRD Discharge Hospitals

As noted previously, CMS proposed three new MS-DRGs for kidney transplant services with hemodialysis (MS-DRG 019, 650, and 651).  Accordingly, CMS has proposed to add these three MS-DRGs to the list of excluded MS-DRGs set forth in 42 CFR 412.104(a) when tabulating the additional payment for hospitals that have a higher percentage of Medicare ESRD beneficiaries.  In addition, CMS will be removing from the list of excluded MS-DRGs two DRGs that are no longer applicable.

An updated table of the excluded MS-DRGs is shown below:


Graduate Medical Education Changes for Residents in Closed Programs

To address concerns from stakeholders that their policy for allowing hospitals to seamlessly absorb displaced medical residents from closed programs is too restrictive, CMS is proposing to ease the current policy to match actual industry practice more closely.  The current CMS policy is that the definition of a displaced resident is one that is physically present at the hospital training on the day prior to or the day of the hospital or program closure.

In reality, residents begin their searches and programs begin accepting those residents soon after announcements are made that the hospital or program will be closing.  This allows residents to transfer to their new programs at a mutually convenient time with minimal disruption to their training.

CMS is proposing that the key day would now be the day that the closure was publicly announced (e.g., via a press release or formal notice to the ACGME), rather than the actual day of closure.  CMS is also proposing that the definition of a displaced resident be expanded to include individuals who have matched with the closed program but have not yet started training.  The revised definition of displaced residents is summarized in the table below:

These proposed changes would apply to the FTE cap transfer for displaced residents as well.  It is unclear when CMS intends this new policy to be effective, but presumably it would be effective immediately.

As an additional effort to reduce the amount of personally identifiable information (PII) in resident cap transfer agreements, CMS is also proposing to no longer require the full social security number of each resident but rather only the reporting of the last four digits.

For additional information, please contact Tom Hubner at tom.hubner@toyonassociates.com.


Rate Updates for Sole Community Hospitals (SCH) and Medicare-Dependent Hospitals (MDH)

CMS is proposing that the hospital-specific rates for SCHs and MDHs be updated by the following percentages, depending on the hospital’s ability to meet the different qualifying criteria:


Rural Referral Center (RRC) Annual Qualifying Data

Hospitals have different options to meet the RRC criteria set forth at 42 CFR 412.96.  For those that do not qualify under the 275-bed rule, other optional factors must be met.  Some of those factors are updated annually by CMS and include the following proposed amounts:


PRRB Procedural Flexibility

Since mid-2018, providers have been able to file appeal documents electronically with the Office of Hearings Case and Document Management System (OH CDMS).  Over 65 percent of all new appeals are now filed electronically, and CMS is proposing the following changes to enhance these numbers and reduce the administrative burden on the PRRB.

Proposed Changes:

  • “Date of Receipt” to be changed to mean date of electronic delivery for applicable documents
    • PRRB will continue to apply to receipts the presumed 5 days after the date of issuance
  • “In writing or written” defined to mean either hard copy or electronic submission
  • No earlier than FFY2021, the PRRB may update the Board instructions to require that all new submissions for new and pending appeals be filed electronically using OH CDMS
  • Subpoenas must now be sent via certified mail to ensure accordance with existing laws

For additional information, please contact Karen Kim at karen.kim@toyonassociates.com.


Changes to Quality Programs

While CMS is proposing several changes to the hospital quality reporting and payment programs, none of these changes represent significant structural or procedural changes to the programs.

Hospital Inpatient Quality Reporting (IQR)

CMS is proposing to progressively increase, over a 3-year period, the number of quarters for which hospitals are required to report eCQM data, from the current requirement of one self-selected quarter of data to four quarters of data.

In addition, CMS has proposed reducing the number of hospitals selected for validation from up to 800 to up to 400 hospitals.

Furthermore, CMS is proposing to require the use of electronic file submissions via a CMS-approved secure file transmission process for chart abstracted measure validation.  This proposal would nullify the existing submission of paper copies of medical records or copies on digital portable media, such as CDs, DVDs, or flash drives.

Hospital Value Based Purchasing (HVBP)

CMS is not proposing to add or remove any measures for the FY2023 and FY2024 program years. 

Hospital Readmission Reduction (HRR)

CMS is not proposing to remove or adopt any additional measures at this time.  However, in an effort to simplify rulemaking, CMS is proposing the automatic adoption of applicable periods beginning with the FFY2023 program year.  The period of data collection will become a rolling three-year period applicable to the FFY payments two years after the applicable period ends, as noted below:

Hospital Acquired Conditions (HAC)

Similar to the HRR program, CMS is proposing the automatic adoption of applicable periods beginning with the FFY2023 program year, as noted below:


Other Rules, Transmittals, and Articles Recently Published

Inpatient Psych Facility PPS FFY2021 Proposed Rule [CMS-1731-P]

(Display Copy available 4/10/2020; FR Publish Date 4/14/2020)

Fact Sheet Link

Federal Register Link

  • Per diem base rate increase from $798.55 to $817.59.
  • Will apply the most recent CBSA delineations and will have a 2-year transition for all providers negatively impacted by WIF changes.

 

Inpatient Rehab Facility PPS FFY2021 Proposed Rule [CMS-1729-P]

(Display Copy available 4/19/2020; FR Publish Date 4/21/2020)

Fact Sheet Link

Federal Register Link

  • Standard payment conversion factor increase from $16,489 to $16,847.
  • Will apply the most recent CBSA delineations and will have a 2-year transition for all providers negatively impacted by WIF changes.

Long-Term Care Hospital PPS Proposed Rule [CMS-1735-P]

(Display Copy available here 5/11/2020; FR Publish Date 5/29/2020) – Published as part of the IPPS Acute Care Hospital Proposed Rule

Fact Sheet Link

Federal Register Link

  • LTCH-PPS payments expected to increase by 0.9% or $36M.
  • Payments for cases that will complete the statutory transition to the lower payment rates under the dual rate system are expected to decrease by approximately 20%. This accounts for the LTCH site neutral payment rate cases that will no longer be paid a blended payment rate with the end of the statutory transition period, which represent 25% of all LTCH cases.

 

Skilled Nursing Facility FFY2021 PPS Proposed Rule [CMS-1737-P]

(Display Copy available 4/10/2020; FR Publish Date 4/15/2020)

Fact Sheet Link

Federal Register Link

  • Increase in unadjusted Federal per diem rates of 2.3%
  • Proposal to update the SNF VBP program and to change code mappings for case-mix groups

 

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IMPORTANT COVID-19 FUNDING UPDATE | MAY 22, 2020

 

  • This Sunday, May 24, is the deadline for attesting to CARES provider relief payments received on April 10.
 

Toyon’s COVID-19 Funding Resources (updated for interactive national modeling of funding)
Toyon University’s COVID-19 Funding and Documentation Presentation

  • Wednesday, June 3, is the deadline to submit COVID-19 expenses for
    additional provider relief funding. Providers may be eligible for payments
    from the remaining
    funds through targeted distributions.
     
  • Toyon estimates $27.6
    billion in unallocated
    funding.
 

Toyon is pleased to provide this update on
developing details from the CARES Act Public Health and Social Services Emergency Fund (PHSSEF). For more information, or to contact any of our team members, please feel free to check Toyon’s website.
Important Deadlines: May 24 and June 3
This Sunday, May 24 is the deadline for providers receiving CARES PHSSEF payments on April 10 to attest the terms and conditions (T&C)

Providers that do not attest to the T&C and retain the funds past 45 days will retain payments and be included in HHS’s public release of providers and payments. In HHS’s updated FAQs, the agency states:

“Generally, HHS does not intend to recoup funds as long as a provider’s lost revenue and increased expenses exceed the amount of Provider Relief funding a provider has received.”

Providers must also submit revenue detail by June 3 to receive additional funding from the PHSSEF Distribution.
Please visit Toyon University’s COVID-19 Funding and Documentation Presentation for a discussion on submitting expenses and revenue loss. In HHS’s updated FAQs, HHS indicates this information may be used for other funds, such as the High Impact Fund. HHS states:

“Providers should update their capacity and COVID-19 census data to ensure that HHS can make timely payments in the event that the provider becomes a high-impact provider. Providers can continue to update their information through the same method they used previously.”

Also, providers are required to accept HHS’s T&C and submit revenue information to be considered for additional relief payments.

Toyon’s estimation of unallocated funds (to eligible hospitals) from the CARES Act PHSSEF is below. It is noted some of this funding will be used as part of provider relief funding for skilled nursing facilities (SNF) and HRSA’s Uninsured Program.

$50,000 Payments to RHCs for COVID-19 testing | expenses
Also included in HHS’s provider relief funding update is a distribution of $225 million to RHCs for COVID-19 testing. Payments are based on the number of certified clinic sites. HHS also released RHC T&Cs here. 

Provider relief for Skilled Nursing Facilities
As part of the CARES provider relief funding, HHS is distributing $50,000 to each SNF plus a variable distribution between $2000 per bed for smaller SNFs (5 and 25
beds) and $1,8000 per bed for larger SNFs (more than 200 beds). HHS also released SNF T&Cs here.


Thank you

Toyon is committed to apprising providers with important reimbursement updates and will keep you updated with the latest on UC DSH and COVID-19 funding and documentation.  Please feel free to visit Toyon’s COVID-19 Resources for updates on hospital funding estimates, recommendations on documenting cost and revenue losses associated with this public health emergency. Toyon’s website provides information on how to contact Toyon’s team members.   

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FFY2020 Final Rule

IPPS Final Rule – FFY2020

CMS-1716-F drafted on 8/2/2019; Published in the Federal Register on 8/16/2019

On August 2, 2019, the Centers for Medicare & Medicaid Services (CMS) issued a final rule that focuses the agency’s efforts on a singular objective: transforming the healthcare delivery system through competition and innovation to provide patients with better value and results. The final rule updates Medicare payment policies and rates for hospitals under the Inpatient Prospective Payment System (IPPS) and the Long-Term Care Hospital (LTCH) Prospective Payment System (PPS), effective for discharges on or after October 1, 2019.

The policies in the IPPS and LTCH PPS final rule would represent historic changes to the way rural hospitals are paid and help ensure access to a world-class healthcare system with access to potentially life-saving diagnostics and therapies by unleashing innovation in medical technology and removing barriers to competition.

Overall, the final rule is projected to result in an estimated increase of $3.8B (or 3%) in payments to providers, ranging from 0.8% increases for urban hospitals in the New England Region up to 3.4% increases for smaller, rural hospitals.Medicare IPPS Base Rates 
CMS is increasing the base rate 2.7% for hospitals, mostly driven by a market basket increase of 3.0%.

Click here for the full base rate calculation table and comparison to prior year.

Medicare IPPS Base Rates 
CMS is increasing the base rate 2.7% for hospitals, mostly driven by a market basket increase of 3.0%.

Click here for the full base rate calculation table and comparison to prior year.

MS-DRG v 37 Changes
As expected, CMS is recalibrating the MS-DRG weights for FFY2020. Heart transplants and extensive burn DRGs appear to be getting a boost, while external heart assist devices and pancreas transplants are seeing significant reductions in weighting. DRG 319 and 320 (Endovascular Cardiac Valvular Disorders) are new in FFY2020. Below is a listing of the largest changes in weighting between v36 and v37 of the MS-DRGs:
Click here for a table of the MS-DRG v36 to v37 comparison.

Post-Acute Care Transfer Policy Changes

Effective 10/1/2019, DRGs 273 & 274 (Percutaneous Intracardiac Procedures) will no longer be subject to the transfer policy.

 New Technology Add-On Payment Calculation

In an effort to recognize the rising costs of new technology, CMS has finalized that the existing new technology add-on payment calculation (currently at a 50% limit) be increased to equal the lesser of:

1.)    65% of the cost of the new medical device or technology; OR

2.)    65% of the amount by which the cost of the case exceeds the standard DRG payment

3.)    75% for antimicrobials designated by the FDA as Qualified Infectious Disease Products (QIDPs)

Note: Unless the discharge qualifies for an outlier payment, the additional Medicare payment would be limited to the full MS-DRG payment plus 65% of the estimated costs of the new technology or device.

As a result of this increase, the maximum payment for CAR-T Cell Therapies (KYMRIAHTM and YESCARTATM) would increase from $186,500 to $242,450, which may help to increase the use of this new technology.

Wage Index Changes

CMS has calculated an occupational-mix adjusted national average hourly wage of $44.15. Of note, 164 hospitals will receive the rural floor in FY 2020. This is approximately 99 fewer hospitals receiving the rural floor in FY 2020 than in FY 2019. This is due to the revised calculation for FY 2020 (and subsequent fiscal years) that excludes the wage data of hospitals that have reclassified as rural under 42 CFR 412.103. Eleven urban providers in Massachusetts are expected to receive the rural floor wage index value, which will increase payments overall to the hospitals in Massachusetts by an estimated $25M. This is in comparison to FFY2019 where twenty-nine urban providers in Massachusetts received its rural floor wage index value, increasing payments overall to the hospitals in Massachusetts by an estimated $123M.

CMS remains concerned that the current wage index system exacerbates disparities between high and low wage index hospitals. In addition, CMS also wants to address concerns that the rural floor calculation has been manipulated by a limited number of states to achieve higher wage index factors at the expense of hospitals in other states. As a result, CMS has finalized several significant changes to the wage index calculation.

CMS is finalizing their proposal to reduce disparities by increasing the values for low wage index hospitals below the 25th percentile (or a WIF of 0.8457). The increases for the low wage index hospitals would be equal to half the difference between the original final wage index value for the hospital and the final 25th percentile value (e.g., 0.756 = 0.6663 + (0.8457 – 0.6663)/2). CMS would like this policy to be effective for a period of at least 4 years in an effort to allow employee compensation increases sufficient time to be reflected in the wage index calculation. CMS intends to visit the duration of this policy in future rulemaking as it gains experience under the policy.

CMS has also finalized their proposal to change the rural floor calculation, including the removal of urban-to-rural reclassifications under 42 CFR 412.103. Beginning in FFY2020, state rural floors would be calculated without including the wage data of urban hospitals that have reclassified as rural.

In order to mitigate the negative impacts to hospitals with significant decreases as a result of CMS policy changes, CMS will place a cap of 5% on the decrease of any hospital’s wage index from FFY2019 to FFY2020, allowing the effect of these policy changes to be phased in over 2 years. However, no such cap to limit the decrease in a hospital’s wage index would be applied during the second year.

Overall Medicare spending will not increase as a result of this policy. CMS is accomplishing this through a budget neutrality adjustment of .998838 to the standardized amount that is applied across all IPPS hospitals, rather than a decrease to the wage index for hospitals above the 75th percentile as proposed.

Click here for a comparison of current and prior WIFs for each hospital. These tables are an estimate compiled from Table 2 of the IPPS Final Rule, as CMS has noted that there are errors in Table 3.

Toyon’s Take:

In recent years, CMS has hinted at addressing what it describes as “wage index disparities;” however, no specific changes were proposed and finalized until this year. The finalized changes are noteworthy and were heavily commented on by hospital associations and the provider community in the Final Rule. The finalized changes have significant reimbursement benefit to states that fall below the 25th percentile in terms of its wage index value as well as negative impacts to the standardized amount for all IPPS hospitals. Hospitals should challenge the AWI policies finalized in the FFY 2020 IPPS Final Rule. Hospitals should first appeal to the Medicare Provider Reimbursement and Review Board (PRRB). All appeals are due within 180 days of issuance of the final rule, which is January 29, 2020. Subsequent appeals must be filed annually to preserve appeal rights for each year the policy is in place. CMS has noted its intent to keep the reduction in the standardized amount in effect for a minimum of 4 years (FFYs 2020 – 2023); the rural floor policy is final. Toyon has developed a model analyzing the finalized changes to the wage index using FFY2020 Final Rule data sources. We are happy to share our analysis specific to your hospital.

Other Finalized Changes Impacting Wage Index

  • The overhead rate calculation would now be equal to the following:
    • (Lines 26 through 43 – Lines 28, 33, 35) / ((((Line 1 + Lines 28, 33, 35) – (Lines 2, 3, 4.01, 5, 6, 7, 7.01, 8, and 26 through 43)) – (Lines 9 and 10)) + (Lines 26 through 43 – Lines 28, 33, 35)).
    • The change made by CMS was to eliminate the removal of the sum of overhead contract labor (Lines 28, 33, 35) from the Revised Total Hours calculation in the denominator
      • So (Lines 9, 10, 28, 33, and 35) will now simply be (Lines 9 and 10).
  • The rounding of values for the wage index calculation would be changed as follows:
    • “Raw data” from any individual line item or field would not be rounded.
    • Summed or averaged wage amounts would be rounded to 2 decimals.
    • Hours would be rounded to the nearest whole number.
    • Ratios, percentages, or inflation factors would be rounded to 5 decimals.
    • Actual unadjusted and adjusted wage indexes would continue to be rounded to 4 decimals.
  • A new methodology for calculating the wage index for urban areas without wage data would be calculated by dividing the total urban salaries plus wage-related costs in the state by the total urban hours in the state, all of which would then be divided by the national average hourly wage.
  • Applications to the Medicare Geographic Classification Review Board (MGCRB) for FFY2021 reclassifications, as well as cancellations and terminations, were due by September 3, 2019. All applications and supporting documents must be submitted via the Office of Hearings Case and Document Management System (OH CDMS). Because this new system is available, CMS is eliminating the requirement to copy CMS on these MGCRB filings. More information can be found at https://www.cms.gov/regulations-and-guidance/review-boards/MGCRB/electronic-filing.html.
  • Likewise, applications to CMS for rural redesignations may also now be submitted electronically, by fax, or by other electronic means, as well as by mail.
  • Rural redesignation cancellation requirements specific to RRCs previously required that the hospital be paid as a rural hospital for at least one 12-month cost reporting period before the status can be cancelled. CMS believes that these requirements are no longer relevant, now that hospitals may have simultaneous MGCRB and 42 CFR 412.103 reclassifications. As a result, CMS is revising these provisions to make any cancellations effective for all hospitals at the beginning of the next Federal fiscal year following the cancellation request, if requested within 120 days of the Federal fiscal year end, which is June 2 of each year.

For additional information, please contact Ryan Sader at ryan.sader@toyonassociates.com.

UCC DSH Payments

CMS has finalized a modest increase to Medicare DSH UC payments by $78M, to $8.35B in FFY2020. This increase is partially driven by a statutory elimination of the 0.2% reduction factor in the determination of DSH UC funding.

After consideration of the public comments on whether to use FY2015 or FY2017 uncompensated care data from W/S S-10 as the base year for FFY2020 DSH UC payments, CMS determined that the best available data on uncompensated care costs is from FY2015, in part because CMS has conducted audits of the data. CMS will use a single year of data as opposed to the prior method that used an average of three years of data.

Toyon’s Take: During the CMS and MAC reviews of FY2015 W/S S-10 uncompensated care data, many issues were identified, resulting in hospitals having to entirely resubmit data. This was primarily due to the cost reporting instructions in place during FY2015, which can be challenging to understand and are often subject to interpretation. This points to an industry-wide issue (beyond the hospitals selected for review) and indicates that FY2015 may continue to include aberrant data.

For FY2017 uncompensated care amounts, there is a new set of reporting instructions. There is considerable industry agreement that these instructions are less challenging than instructions in place for FY2015.

Recommended Action: If your hospital has revisions to its FFY 2017 WS S-10 data, Toyon strongly urges these revisions are submitted to your MAC before December 31, 2019. This is the deadline for MACs to submit FFY 2017 S-10 revisions for hospitals under audit.

Click here for the DSH Supplemental PUF data.

Click here for the Analysis of UCC DSH Factor 1.

Toyon has a new national analysis tool to assist hospitals with the evaluation of uncompensated care and the relationship to current and projected DSH UC payments. For additional information, please contact Fred Fisher at fred.fisher@toyonassociates.com.

Graduate Medical Education Changes

In an effort to address barriers to training residents in rural areas, CMS will allow hospitals to include residents training in a Critical Access Hospital (CAH) in its FTE count, as long as the nonprovider setting requirements at 42 CFR 413.78(g) are met.  This represents a change in CMS’s policy since it was initially implemented in FFY2014.  CMS is updating the definition of a “nonprovider” setting to include CAHs.

Effective with portions of cost reporting periods beginning October 1, 2019, hospitals may include FTE residents training at a CAH, on the condition that the hospital incurs the residents’ salaries and fringe benefits.  This change does not impact the continuing ability of CAHs to alternatively incur the costs of training residents in an approved program and receive payment based on 101% of their reasonable cost.

In addition, CMS announced an additional round of Section 5506 FTE cap redistributions (Round 15):

Applications for these additional FTE slots are due to CMS by October 31, 2019.

For additional information, please contact Tom Hubner at tom.hubner@toyonassociates.com.

Low Volume Hospitals

CMS is revising the regulations at 42 CFR 412.101 to add a subsection (e), which will now allow Indian Health Services (IHS) hospitals to qualify by measuring only the distance between other IHS and Tribal hospitals when assessing the mileage criterion. CMS is also allowing these hospitals to reopen cost reports in order to apply for the low volume adjustment back to FFY2011, subject to the reopening rules at 42 CFR 405.1885.

Rate Updates for Sole Community Hospitals (SCH) and Medicare-Dependent Hospitals (MDH)

CMS is finalizing the updates to the hospital-specific rates for SCHs and MDHs by the following percentages, depending on the hospital’s ability to meet the different qualifying criteria:

Rural Referral Center (RRC) Annual Qualifying Data

Hospitalshave different options to meet the RRC criteria set forth at 42 CFR 412.96. For those that do not qualify under the 275-bed rule, other optional factors must be met. Those factors are updated annually by CMS and include the following finalized amounts:

PRRB Appeal Changes

In an effort to address the large number of cases before the PRRB, CMS is considering actions to assist in the reduction of the current PRRB case backlog:

  • Develop standard formats and more structured data for submitting cost reports and supporting documentation.
  • Create more clear standards for documentation to be used in auditing of cost reports.
  • Enhance the MCReF portal by creating more automation for letter notifications and increased provider transparency during the cost report submission and audits.
  • Utilize artificial intelligence (AI) protocols based on historical audit data to drive audit processes.
  • Triage the current PRRB case inventory and expand the providers’ options for resolving issues through the reopening process.

Procedural Changes Specific to Appealing Empirical DSH Updates

CMS has determined that a significant number of appeals are related to hospitals’ disproportionate patient percentage (DPP), specifically concerning updating the Medicaid fraction. To address this, CMS is proposing that regulations be developed to govern the timing of the data for determining Medicaid eligibility.

These routine updates would be handled via reopening, with CMS issuing directives to the MACs requiring them to reopen cost reports for this issue at a specific time and realistic period during which the provider could submit updated data.

CMS is also considering allowing hospitals a one-time option to resubmit cost reports with updated Medicaid eligibility information, similar to SSI realignments. CMS would need to undertake rulemaking in order to determine the timeframe for exercising this option.

CMS has reviewed public comments on these procedural changes and will take the comments into consideration in future rulemaking.

For additional information, please contact Karen Kim at

karen.kim@toyonassociates.com.

PRRB Appeal Changes

In an effort to address the large number of cases before the PRRB, CMS is considering actions to assist in the reduction of the current PRRB case backlog:

  • Develop standard formats and more structured data for submitting cost reports and supporting documentation.
  • Create more clear standards for documentation to be used in auditing of cost reports.
  • Enhance the MCReF portal by creating more automation for letter notifications and increased provider transparency during the cost report submission and audits.
  • Utilize artificial intelligence (AI) protocols based on historical audit data to drive audit processes.
  • Triage the current PRRB case inventory and expand the providers’ options for resolving issues through the reopening process.

Procedural Changes Specific to Appealing Empirical DSH Updates

CMS has determined that a significant number of appeals are related to hospitals’ disproportionate patient percentage (DPP), specifically concerning updating the Medicaid fraction. To address this, CMS is proposing that regulations be developed to govern the timing of the data for determining Medicaid eligibility.

These routine updates would be handled via reopening, with CMS issuing directives to the MACs requiring them to reopen cost reports for this issue at a specific time and realistic period during which the provider could submit updated data.

CMS is also considering allowing hospitals a one-time option to resubmit cost reports with updated Medicaid eligibility information, similar to SSI realignments. CMS would need to undertake rulemaking in order to determine the timeframe for exercising this option.

CMS has reviewed public comments on these procedural changes and will take the comments into consideration in future rulemaking.

For additional information, please contact Karen Kim at

karen.kim@toyonassociates.com.

Quality Program Changes

While CMS is finalizing several of the proposed changes to the hospital quality reporting and payment programs, none of these changes represent significant structural or procedural changes to the programs.

Hospital Inpatient Quality Reporting (IQR)

CMS is making the following adjustments to the program:

  • Adopt the Hybrid Hospital-Wide All-Cause Readmission (Hybrid HWR) measure, beginning with two voluntary reporting periods running from 7/1/2021 to 6/30/2022 and from 7/1/2022 to 6/30/2023.
  • Adopt the Safe Use of Opioids – Concurrent Prescribing electronic clinical quality measure (eCQM), with a clarification and update, beginning with CY 2021 reporting period/FY 2023 payment determination.
  • Remove the Claims-based Hospital-Wide All-Cause Unplanned Readmission measure (HWR claims-only measure) beginning with the FY2026 payment determination.
  • Extend current eCQM reporting and submission requirements for both the CY2020 reporting (FY2022 payment) and the CY2021 reporting (FY2023 payment) periods.
  • Change eCQM reporting and submission requirements for the CY2022 reporting (FY2024 payment) period, such that hospitals would be required to report one self-selected calendar quarter of data for three self-selected eCQMs and the proposed Safe Use of Opioids eCQM.
  • Continue requiring that EHRs be certified to all available eCQMs used in the Hospital IQR program for the CY2020 and subsequent reporting periods.

CMS is not finalizing its proposal to adopt the Hospital Harm – Opioid-related Adverse Events eCQM.

Hospital Value Based Purchasing (HVBP)

CMS will now require that the HVBP program use the same data used by the HAC program for purposes of calculating the Centers for Disease Control and Prevention (CDC) National Health Safety Network (NHSN) Healthcare-Associated Infection (HAI) measures beginning with the CY2020 data collection, when the hospital IQR program will no longer collect data on those measures.

CMS is not adding or removing any measures for the FY2022 and FY2023 program years. However, CMS will be establishing new performance standards for FY2024 and FY2025.

Hospital Readmission Reduction (HRR)

CMS will adopt the following adjustments to the program:

  • Establish the performance period for the FY 2022 program year.
  • Adopt a measure removal policy that aligns with the policies for other quality programs.
  • Update the definition of “dual-eligible” as a beneficiary who has full benefit status in both the Medicare and Medicaid programs for the month the beneficiary was discharged, except for those beneficiaries who die in the month of discharge, who will be identified using the previous month’s data.
  • Adopt a process to make nonsubstantive changes to the payment adjustment factors, which would include updated naming or locations of data file or minor discrepancies, but which would not include different methodologies to use data or the use of a different component in the methodology.
  • Update 42 CFR 412.152 and 412.154 to reflect policies finalized in previous Rules.

Hospital Acquired Conditions (HAC)

CMS will make the following adjustments to the program:

  • Adopt a measure removal policy that aligns with the policies for other quality programs.
  • Clarify policies for validating CDC NHSN HAI measures.
  • Adopt the collection periods for the FY2022 program year.
    • CMS PSI 90 measure – 24-month period from 7/1/2018 to 6/30/2020
    • CDC NHSN HAI measures – 24-month period from 1/1/2019 to 12/31/2020.

Update 42 CFR 412.172(f) to reflect policies finalized in the FFY2019 IPPS Final Rule.

Quality Program Changes

While CMS is finalizing several of the proposed changes to the hospital quality reporting and payment programs, none of these changes represent significant structural or procedural changes to the programs.

Hospital Inpatient Quality Reporting (IQR)

CMS is making the following adjustments to the program:

  • Adopt the Hybrid Hospital-Wide All-Cause Readmission (Hybrid HWR) measure, beginning with two voluntary reporting periods running from 7/1/2021 to 6/30/2022 and from 7/1/2022 to 6/30/2023.
  • Adopt the Safe Use of Opioids – Concurrent Prescribing electronic clinical quality measure (eCQM), with a clarification and update, beginning with CY 2021 reporting period/FY 2023 payment determination.
  • Remove the Claims-based Hospital-Wide All-Cause Unplanned Readmission measure (HWR claims-only measure) beginning with the FY2026 payment determination.
  • Extend current eCQM reporting and submission requirements for both the CY2020 reporting (FY2022 payment) and the CY2021 reporting (FY2023 payment) periods.
  • Change eCQM reporting and submission requirements for the CY2022 reporting (FY2024 payment) period, such that hospitals would be required to report one self-selected calendar quarter of data for three self-selected eCQMs and the proposed Safe Use of Opioids eCQM.
  • Continue requiring that EHRs be certified to all available eCQMs used in the Hospital IQR program for the CY2020 and subsequent reporting periods.

CMS is not finalizing its proposal to adopt the Hospital Harm – Opioid-related Adverse Events eCQM.

Hospital Value Based Purchasing (HVBP)

CMS will now require that the HVBP program use the same data used by the HAC program for purposes of calculating the Centers for Disease Control and Prevention (CDC) National Health Safety Network (NHSN) Healthcare-Associated Infection (HAI) measures beginning with the CY2020 data collection, when the hospital IQR program will no longer collect data on those measures.

CMS is not adding or removing any measures for the FY2022 and FY2023 program years. However, CMS will be establishing new performance standards for FY2024 and FY2025.

Hospital Readmission Reduction (HRR)

CMS will adopt the following adjustments to the program:

  • Establish the performance period for the FY 2022 program year.
  • Adopt a measure removal policy that aligns with the policies for other quality programs.
  • Update the definition of “dual-eligible” as a beneficiary who has full benefit status in both the Medicare and Medicaid programs for the month the beneficiary was discharged, except for those beneficiaries who die in the month of discharge, who will be identified using the previous month’s data.
  • Adopt a process to make nonsubstantive changes to the payment adjustment factors, which would include updated naming or locations of data file or minor discrepancies, but which would not include different methodologies to use data or the use of a different component in the methodology.
  • Update 42 CFR 412.152 and 412.154 to reflect policies finalized in previous Rules.

Hospital Acquired Conditions (HAC)

CMS will make the following adjustments to the program:

  • Adopt a measure removal policy that aligns with the policies for other quality programs.
  • Clarify policies for validating CDC NHSN HAI measures.
  • Adopt the collection periods for the FY2022 program year.
    • CMS PSI 90 measure – 24-month period from 7/1/2018 to 6/30/2020
    • CDC NHSN HAI measures – 24-month period from 1/1/2019 to 12/31/2020.

Update 42 CFR 412.172(f) to reflect policies finalized in the FFY2019 IPPS Final Rule.

Other Rules, Transmittals, and Articles Recently Published

Inpatient Psych Facility PPS Final Rule [CMS-1712-F]

(Display Copy available here 7/30/2019; FR Publish Date 8/06/2019)

Fact Sheet Link

Federal Register Link

  • Per diem base rate increase from $782.78 to $798.55.
  • Elimination of 1-year lag in WIF, aligning it with concurrent IPPS WIF.

Inpatient Rehab Facility PPS Final Rule [CMS-1710-F]

(Display Copy available here 7/31/2019; FR Publish Date 08/08/2019)

Fact Sheet Link

Federal Register Link

  • Standard payment conversion factor increase from $16,021 to $16,489.
  • Elimination of 1-year lag in WIF, aligning it with concurrent IPPS WIF.

Long-Term Care Hospital PPS Final Rule [CMS-1716-F]

(Display Copy available here 08/02/2019; FR Publish Date 8/16/2019) – Published as part of the IPPS Acute Care Hospital Final Rule

Fact Sheet Link

Federal Register Link

  • LTCH-PPS payments expected to increase by 1% or $43M.
  • Finalized the proposal to modify the “Discharge to Community” measure to exclude nursing home residents who already reside in the nursing home.

Skilled Nursing Facility PPS Final Rule [CMS-1718-F]

(Display Copy available here 7/30/2019; FR Publish Date 08/07/2019)

Fact Sheet Link

Federal Register Link

Increase in unadjusted Federal per diem rates of 2.4%.

 

 
 
 
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