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Tag: 1115 waiver

FFY 2024 Inpatient Prospective Payment System Proposed Rule
Webinar: May 9, 2023 – 10 a.m. PDT

Please join Toyon on Tuesday May 9, from 10-11:30 a.m. PDT for our presentation of the FFY 2024 Inpatient Prospective Payment System (IPPS) Proposed Rule. Interested participants can register here for the webinar.

Toyon’s service line leaders will discuss key changes in the Proposed Rule, including:

  • Market Basket and updates to FFY 2024 payment rates
  • Wage Index, with emphasis on changes to “rural floor” indices
  • Disproportionate Share (DSH) funding and allowable 1115 waiver days
  • Request for Information on safety-net hospitals
  • Graduate Medical Education and Allied Health reimbursement

Provider Impact Analysis
Please see Toyon’s estimated Medicare FFY 2024 IPPS payments for your hospital(s) here. Estimates can be rendered by selecting your hospital(s) in the top left of the dashboard under “Provider.” The estimated FFY 2024 payments are compared to FFY 2023 and are broken down by each component of the Medicare rate as provided by CMS.

Please contact Fred Fisher at 888.514.9312 or fred.fisher@toyonassociates.com with any questions or for additional information.

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FFY 2023 IPPS PROPOSED RULE COMMENTS DUE JUNE 17, 5 PM EDT

This Friday June 17th at 5 PM, comments are due on CMS’s proposed FFY 2023 IPPS rate setting.   In commenting – 

  • Refer to file code CMS–1771–P.  
  • Submit electronically through this regulation link then select the COMMENT button at left, below the title; or
  • Submitted by mail to: Centers for Medicare &Medicaid Services, Department of Health and Human Services, Attention: CMS–1771–P, P.O. Box 8013, Baltimore, MD 21244–1850.

Please feel free to see Toyon’s comments here on our website.  Providers may also download a word version of these comments with designated [highlighted] areas to populate for your hospital or health system.  

Toyon’s comments are focused on reimbursement issues, as well as cost reporting proposals requiring additional clarification, as summarized in the table below.

# Issue FFY 2023 Proposal Summarized  Comment
1

Market Basket

2.7% Update

3.1% Market Basket -0.4% ACA Adjustment

8.0% Update

Based on recent Medicare cost increases[1]

2 Outliers

$43,214 

Fixed Loss Threshold  (40% increase from PY)

Reduce threshold in anticipation of fewer COVID-19 hospitalizations in FFY 2023
3

UC DSH Factor 1

-$542M

Reduction to FFY 2023 UC DSH Payments

-$542M

Reduction to FFY 2023 UC DSH Payments

Increase Factor 1 discharge adjustment considering forecasts of increased Medicare utilization

4 UC DSH Factor 2

65.71%

-0.03 from prior yr

-0.07 from penultimate yr

65.71%

-0.03 from prior yr

-0.07 from penultimate yr

Increase Factor 2 to reflect projections of increases to the national uninsured population

5 Empirical DSH Section 1115 Waiver Days Medicaid patients regarded as eligible from 1115 Waiver w/ essential health benefits (EHB) Clarification on premium assistance days “for which the premium assistance is equal to or greater than 90 percent of the cost of the coverage”
6 NP95 Respirator Payments Reimbursement for the incremental cost of using wholly domestically produced N95 respirators Supported and request CMS reimburse for all patients (not only Medicare) in bi-weekly lump sum payments

Please feel free to email Fred Fisher at fred.fisher@toyonassociates.com with any questions.

[1] Analysis of Medicare cost per discharge change from FFY 2019 to FFY 2020 per Medicare cost report data from the Healthcare Cost Report Information System (HCRIS).  Medicare cost per Worksheet D-1 Part II, Line 49, Column 1.  Medicare discharges per Worksheet S-3 Part I L14.00 C13.00.

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Medicare Graduate Medical Education and Organ Acquisition Payment Policy Changes

On Monday December 27, CMS published Federal Register / Vol. 86. No. 245 [CMS–1752–FC3. This Final Rule with comment period includes new teaching slots for graduate medical education, modifications to organ acquisition reimbursement, and postpones potential changes related to Section 1115 waiver days for empirical DSH payments. February 25 is the deadline to submit comments to CMS for the issues (discussed below) whereby CMS is seeking feedback. 

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