Announcements

The Society of Ohio Occupational Health Professionals (SOOHP) 2012 Spring Conference will be held March 15-16 at The Crowne Plaza Dublin Hotel in northwest Columbus.  Mark your calendar - an agenda and registration information will be available soon.

The 2012 OSHFM Fall Conference is scheduled for September 28 at The Crowne Plaza Hotel in Dublin.  A program agenda and registration information will be available late summer.

Other OHA educational events that will be of interest to OSHFM members -

Reducing Energy Costs - agenda and registration form

Continuous Compliance with Speaker Gary Slack - agenda and registration form

OSHHRA’s 2012 Conferences have been scheduled. The spring conference will be held March 16 at Quest Conference Center in north Columbus. The fall conference is scheduled November 8-9 at The Embassy Suites in Dublin. Registration information and agendas will be available on the OHA Education page soon.

OHA learned this week that CGI Federal, the Ohio Recovery Audit Contractor (RAC) for both Medicare and Medicaid, has slowly started to release backdated Medicare RAC review results, held since last summer because of the Medicare Administrative Contractor (MAC) conversion to CGS. CGI reports it is releasing small batches of backdated review results to CGS in a production mode, which will trigger Demand Letters to providers from CGS, and all appears well. If no glitches are found, CGS will speed up the process and states it should have all "blackout" review results to CGS within a few weeks.

OHA expressed concern that the release of a larger number than normal of review results, in combination with the new MAC responsibility to issue Demand Letters, will cause confusion, especially if, as is expected, the Demand Letters are not addressed to hospitals' usual RAC contacts. CGI responded that hospitals can track the release of review results on its provider portal website and, while it cannot issues copies of Demand Letters itself, the portal should alert hospitals to the release of review results, so they can contact CGS Customer Service, if necessary.

The Ohio Bureau of Workers’ Compensation (BWC) finalized its 2012 inpatient hospital prospective payment system (IHPPS) payments rates, to be effective with discharges Feb. 1, and proposed an outpatient PPS (OPPS) rule, scheduled for adoption April 1. Both are based on their Medicare counterparts and use many of the same grouping and pricing factors, with some BWC-specific payment adjustments. BWC also has its own payment formulae for graduate medical education and outlier payments.

BWC’s 2012 IHPPS final rule (OAC 4123-6-37.1) mirrors the FFY 2012 Medicare version, but, based on comments from the OHA Finance Committee, BWC will return Medicare’s cuts to the annual inflationary update related to productivity, future coding improvements and balancing the federal budget. BWC will keep the 2.9 percent cut related to past coding improvements, but not so much because it agrees with CMS on the issue of inappropriate payments related to coding creep, as much as adopting a 2.9 percent cut to the update keeps BWC inpatient hospital payments within its own budget targets for 2012. Hospitals exempt from the Medicare IHPPS are also exempt from BWC’s version and are paid on the basis of a Medicare hospital-specific, inpatient cost-plus methodology.

BWC’s 2012 OPPS proposed rule (4123-6-37.2) includes several changes from 2011, notably in its reduction of the BWC add-on to 1.81 percent ( it was 1.97 percent in 2011, which was the first year of a two-year transition to the BWC OPPS) and in the adoption of an outpatient claims processing code editor. However, BWC will return to the inflationary base all Medicare OPPS reductions for productivity, coding improvement and balanced budgets, so BWC's proposed 2012 add-on to the outpatient Medicare PPS payment rate amounts to 2.17 percent. Childrens hospitals, cancer hospitals, Critical Access Hospitals, and rural Sole Community and Essential Access Hospitals are all exempt from the BWC OPPS and instead will be paid on the basis of their Medicare hospital-specific, outpatient cost. OHA is reviewing the BWC 2012 OPPS proposed rule and will if necessary comment at a public hearing scheduled Feb 8.

Mike Abrams, Executive Vice President and CEO of the Iowa Medical Society, was announced as the Ohio Hospital Association’s next President and CEO. Abrams will begin his tenure in February, following the December 31 retirement of Jim Castle, OHA’s President and CEO for 23 years.

View OHA news release

In an unprecedented show of shared focus and commitment, 20 Central Ohio hospitals staged simultaneous Scrub Up! events at 12:05 p.m. on 12/05 to highlight the critical importance of hand hygiene to reduce infections and disease transmission. The Ohio Hospital Association’s (OHA) Quality Institute spearheaded the observance, which engaged staff and visitors of every hospital in six counties.

View OHA news release

In October, the Office of the Inspector General released findings from its survey of adverse events in hospitals. Organizations should make sure they have well documented processes to respond to serious events and monitoring of ongoing processes to prevent drift from corrective actions taken.

View survey results

On Nov. 4 CMS published the CY 2012 final rule for the Medicare Home Health Prospective Payment System (HHPPS). An OHA overview is available. CMS’ rule incudes a 2.4 percent reduction in the national standardized 60-day episode payment rate, set at $2,138.52 for CY 2012. The payment reduction is due to cuts to the annual inflationary update that CMS states is necessary to recover overpayments related to coding improvement, and an additional reduction, ordered in the ACA, to help balance the federal budget.

The final rule and OHA's analysis also include details on the HH PPS wage index and outliers, payments for home health encounters with four or fewer visits within a 60-day episode, non-routine medical supplies, services provides in rural areas, and changes to the Home Health Case-Mix Classification System weights.

In its CY 2012 final rule for the outpatient hospital and ambulatory surgical center (ASC) prospective payment system (OPPS), CMS includes a 1.9 percent payment update for hospital outpatient services paid under the OPPS and a 1.6 percent increase for ASCs. An OHA overview of the final rule is available.

The OPPS final rule continues the controversial debate over physician supervision requirements by adding additional seats for Critical Access Hospitals (CAHs) and small rural hospitals to an advisory panel that will recommend required supervision levels by CPT code. CMS will also extend its moratorium on enforcement of the supervision requirements to CAHs and small rural hospitals for another year, while the advisory panel is being reformed.

The final rule also updates OPPS quality reporting requirements and, for the first time, will require quality reporting from ASCs. CMS will keep its current OPPS wage index policy -- based on a modified version of the inpatient PPS formula -- while it studies other options. CMS will also adjust the payment formula for cancer hospitals and eliminate the hold-harmless add-on for Sole Community Hospitals.

Unrelated to the OPPS, the final rule also updates the Medicare Value-Based Purchasing (VBP) program by eliminating Hospital-Acquired Conditions and composite and efficiency measures from the 2014 program. CMS wil also adjust the relative weights of four quality measures used to calculate performance scores.

In today's Federal Register CMS published a final rule to support the creation of Medicare Accountable Care Organizations (ACOs) and an interim final rule that outlines its proposed waivers of shared savings arrangements as they relate to federal anti-kickback laws. An overview by Lawrence Goldberg, senior advisor for healthcare legislative and regulatory matters, Grant Thornton, is also available.

While much of the regulation is still controversial, the final rule positively responds to industry concerns about ACO management and administration in several ways.

• Patients will assigned to ACOs based on historical claims activity rather than after the fact, and ACOs will get quarterly updates on beneficiary activity so they have a better understanding of which patients will be included in their counts of costs and savings. Beneficiaries, however, retain complete provider freedom of choice.
• CMS changed several aspects of shared saving proposals, allowing all ACOs to share in “first-dollar” savings, removing the automatic 25 percent withhold of any bonus payment, removing IME and DSH payments from benchmark savings targets and spending estimates, and removing the risk of program losses in the third year of a contract with a track-one ACO.
• CMS will moderate requirements for electronic health record (EHR) meaningful use, ACO marketing guidelines and governance, and it reduced the required reportable quality measures by more than half.
• CMS will also allow limited up-front payments to some, relatively smaller organizations to assist with the high cost of creating an ACO.

Finally, in the related interim final rule, CMS and the Office of Inspector General proposed waivers from the Anti-Kickback Statute, the Physician Self-Referral (so-called Stark) Law and the Civil Monetary Penalty Law.

In today's Federal Register CMS published a final rule to support the creation of Medicare Accountable Care Organizations (ACOs) and an interim final rule that outlines its proposed waivers of shared savings arrangements as they relate to federal anti-kickback laws. An overview by Lawrence Goldberg, senior advisor for healthcare legislative and regulatory matters, Grant Thornton, is also available.

While much of the regulation is still controversial, the final rule positively responds to industry concerns about ACO management and administration in several ways.

• Patients will assigned to ACOs based on historical claims activity rather than after the fact, and ACOs will get quarterly updates on beneficiary activity so they have a better understanding of which patients will be included in their counts of costs and savings. Beneficiaries, however, retain complete provider freedom of choice.
• CMS changed several aspects of shared saving proposals, allowing all ACOs to share in “first-dollar” savings, removing the automatic 25 percent withhold of any bonus payment, removing IME and DSH payments from benchmark savings targets and spending estimates, and removing the risk of program losses in the third year of a contract with a track-one ACO.
• CMS will moderate requirements for electronic health record (EHR) meaningful use, ACO marketing guidelines and governance, and it reduced the required reportable quality measures by more than half.
• CMS will also allow limited up-front payments to some, relatively smaller organizations to assist with the high cost of creating an ACO.

Finally, in the related interim final rule, CMS and the Office of Inspector General proposed waivers from the Anti-Kickback Statute, the Physician Self-Referral (so-called Stark) Law and the Civil Monetary Penalty Law.

CMS published the FFY 2012 final rules for the Medicare Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) on Aug. 5, with a standardized conversion factor of $14,076, a 1.6 percent increase from 2011. CMS is decreasing the labor-related share of the conversion factor from 75.271 percent in 2011 to 70.199 percent in 2012. This change will increase payments to IRFs with a wage index less than 1.0. CMS will also continue to use the hospital wage index and the 2011 pre-rural floor and pre-reclassified hospital wage index in 2012. CMS will decrease the outlier threshold from $11,410 in 2011 to $10,660 in 2012, a decrease of 6.6 percent., which increases the number of cases eligible for outlier payments

For 2012, facility-level adjustment factors include:

• Rural Adjustment: Payments to IRFs in rural areas will continue to be increased by 18.4%.
• Low Income Patients: Payments to IRFs eligible for the LIP adjustment will continue to be increased under the following formula: (1 + Disproportionate Share Hospital (DSH) patient percentage) ^ 0.4613.
• Teaching Adjustment: Payments to IRFs eligible for the teaching adjustment will continue to be increased under the following formula: (1 + IRF’s full-time equivalent (FTE) resident to Average Daily Census (ADC) ratio) ^ 0.6876.

As required by the ACA, CMS is implementing a IRF PPS “pay-for-reporting” program, which will require IRFs to successfully submit quality data on selected measures. Beginning FFY 2014, providers that do not successfully participate in the program will be subject to a 2.0 percentage point reduction to the annual inflationary update factor for the applicable year. Similar to the quality measures collected under the Inpatient PPS, IRFs will be required to collect quality data for the two adopted measures on all patients, regardless of payer. For FFY 2014, CMS is adopting quality measures on Urinary Catheter-Associated Urinary Tract Infections (CAUTI) and Pressure Ulcers that are New or Have Worsened.

OHA offers an overview of the FFY 2012 IRF PPS final rule.

CMS released its FFY 2012 hospital inpatient and long-term care hospital (LTCH) prospective payment system (IHPPS) final rule on Aug. 1, with an unanticipated reduction in its proposed permanent payment cut for coding improvement. Initially pegged at 3.15 percent, CMS will instead reduce the IHPPS update factor by 2 percent, adding, according to the American Hospital Association, an additional $1.2 billion in payments to hospitals in FY 2012, compared to what was proposed last spring. Additional details and links to summaries of the IHPPS and LTCH PPS final rules are available in the August OHA Finance News.

CMS this week released its Skilled Nursing Facility Prospective Payment System (SNF PPS) final rule for FFY 2012, including a nearly $4 billion dollar cut in payments that CMS contends is necessary to recover past overpayments and "better align Medicare payments with costs." OHA has an overview of the final rule. CMS states its 2011 transition to a updated Resource Utilization Groups (RUG IV) classification system understated the extent to which SNFs would utilize therapy services, resulting in significant overpayments related to what was paid for similar admissions under the previous system, making it necessary to recalibrate SNF PPS case-mix indexes to restore overall payments on a budget-neutral basis.

This will result in a SNF PPS payment reduction of $4.47 billion, which was mitigated by a annual PPS inflationary of 1.7 percent, reflecting a 2.7 percent market-basket-based update, reduced by a 1 percent "productivity" adjustment, as mandated in the Affordable Care Act. The combined inflationary increase and FFY 2012 recalibration will yield a net reduction of $3.87 billion, or 11.1 percent.

The final rule also:

•  Clarifies circumstances when SNFs must report breaks of three or more days of therapy.
• Eliminates the distinction between facilities regularly furnishing therapy services on a five- or seven-day basis for purposes of setting the date for the End of Therapy (EOT) Other Medicare Required Assessment (OMRA).
• Streamlines procedures for documenting situations involving a brief interruption in therapy, where therapy resumes without any change in the patient’s RUG-IV classification level.
• Introduces a new Change of Therapy (COT) OMRA to capture those changes in a patient’s therapy status that would be sufficient to affect the patient’s RUG-IV classification and payment, even though they may not increase to the level of a significant change in clinical status.
• Provides for the allocation of a therapist’s time for group therapy (defined in the rule as a single therapist leading four patients in a common activity) to ensure that Medicare payments better reflect resource utilization and cost for these services, and specifically that the therapist’s time is being appropriately counted and reimbursed.
  

In addition to a proposed rule for the outpatient hospital and ambulatory surgical center (ASC) prospective payment system (PPS), the Centers for Medicare & Medicaid Services (CMS) last week released its proposed rule for the CY 2012 Medicare Home Health PPS, with a national standardized 60-day episode payment rate of $2,112.37, compared to $2,192.07 in CY 2011, a 3.6% decrease.  View an OHA overview. Comments are due Sept. 6.

CMS is cutting Medicare payments to home health facilities as required in the Affordable Care Act to reduce the estimated 2.5 percent inflationary update for 2012 by 1 percent to help balance the federal budget and by an additional 5.06 percent to offset what CMS alleges are undeserved payment increases in past years related to coding improvements.

The proposed rule also outlines the 2012 HH PPS wage index, per visit rates outside the 60-day standardized amounts, low-utilization payment adjustments and a conversion factor to calculate payments for non-routine medical supplies. Finally, CMS is proposing to re-balance overall HH PPS payments in a budget neutral manner and move payments away from high therapy visits to non-therapy visits.

CGI Federal has confirmed details about the blackout for Medicare Recovery Audit Contractor (RAC) activity during the J15 Medicare Administrative Contractor (MAC) conversion. In the past, CMS has authorized a 6-month moratorium of Medicare RAC activity surrounding any FI/MAC conversion in order to lessen the chance of problems with other MAC responsibilities. However, CMS is now stating that most earlier MAC conversions did not require the entire six months, so it is adjusting its approach for the Ohio/Kentucky Part A MAC conversion, scheduled for Oct. 17.

The OH/KY Part A RAC/MAC “blackout” will start on July 20 and continue until on or about Jan. 15, 2012, unless that period is shortened as outlined below. During the blackout CGI's RAC operations and interaction with Part A providers will continue as normal, including records requests, reviews, review results and discussions. However, during the period from July 20 to the Oct. 17 OH/KY Part A MAC conversion all interaction between CGI and National Government Services (NGS) will stop, which means all Demand Letters on post July 20 review results will stop as well. Between July 20 and Oct. 16 NGS will continue to process remittances, demand letters recoupments and appeals on any review results transmitted by CGI prior to July 20, up to the point NGS operations convert to CGS, at which time NGS will transmit any unfinished business to CGS.

At some point after Oct. 17 and before Jan 15, if CGS feels it has the conversion under control, CGS will notify CGI and CMS that it can accept review results generated on and after July 20. If CMS approves, CGI will transmit the backlog of review results to CGS, and all Demand Letters, remittances, recoupments and appeals will be re-started as normal, oldest first, with CGS at the helm. If for some reason CGS does not notify CGI and CMS that it is ready before Jan 15, CGI will not transmit any post-July 20 review results to CGS until or after Jan. 15, 2012.

As such, excepting the issuance of Demand Letters, none of CGI's activities, responsibilities or timelines will change during the “blackout.” At the same time, no “935” recoupment activities, including the issuance of Demand Letters, remittance advices, appeals and interest calculations will re-start on the backlog until Jan 15, unless CGS, CGI and CMS concur on an earlier date.

OHA will stay in close touch with CGI and CGS to ensure its members are kept up to date, especially should the "935" process be re-started by CGS earlier than Jan 15, 2012.

On May 6, CMS released the FFY 2012 Medicare Skilled Nursing Facility Prospective Payment System (SNF PPS) proposed rule.  The proposed rule covers SNF payment policy and rates and consolidated billing requirements, and will go into effect on Oct. 1. Comments are due June 27. An OHA overview is available.

Overall SNF payment rates will be increased by only 1.5 percent, which CMS calculated by reducing the 2.7 percent marketbasket update by 1.2 percentage points, to account for productivity increases as ordered by Congress in the Accountable Care Act. OHA's overview has a table with the resulting federal per diem payment rates for nursing and therapy.  CMS is not proposing any changes to the consolidated billing rules.

CMS believes the "parity adjustment" installed in 2011 to maintain budget neutrality between Resource Utilization Groups (RUGS) III and IV inadvertently raised SNF PPS payments and CMS is asking for comments on two options to respond. In addition, CMS is asking for comments on how it might develop a Healthcare Acquired Conditions policy, similar to the one in place for inpatient acute care hospitals.

Expect a final rule later this summer. OHA will follow up with details.

CMS released the Inpatient Psychiatric Facilities Prospective Payment System (IPF PPS) final rule for Rate Year (RY) 2012 in the May 6 Federal Register. The IPF PPS RY 2012 starts with discharges July 1, 2012, but CMS will change the start of the 2013 program to Oct. 1 to coincide with the federal fiscal year and other provider payment systems. An OHA overview of the 15-month 2012 IPF PPS, including onformation about the facility and patient-level adjustments is available. 

The IPF PPS employs a national, per diem base rate, adjusted by a psychiatric DRG, an area wage index and the presence of one or more facility or patient-specific factors. CMS will increase the base rate for 2012 by 3.2 percent. Reduced by .25 percent, as ordered by Congress in the ACA and further adjusted to account for wage index budget neutrality, the new 15-month base rate for RY 2012 is  $685.01. The outlier threshold is proposed at $7,340.

MARK YOUR CALENDAR - The OONE 2012 Fall Conference will be held November 7-9 at The Embassy Suites Dublin Hotel in northwest Columbus.  A program agenda and registration information will be available in early fall 2012.

The Centers for Medicare & Medicaid Services' round of annual provider prospective payment systems updates continues with its April 29 proposed rule on the 2012 Inpatient Rehabilitation Facility PPS (IRF PPS). OHA has on overview and Lawrence Goldberg of Grant Thornton has a detailed review on its website. Comments are due June 21. A final 2102 rule is expected by Aug. 1, and the 2012 IRF PPS goes into effect for discharges on and after Oct. 1, 2011.

On the surface, it appears Medicare payments to IRF PPS facilities will increase by nearly 5 percent next year, but that increase in the federal base-rate conversion factor is high mainly due to the need to maintain budget neutrality in the light of significant reductions for productivity, and to smaller facility-specific adjustments for low-income payments, teaching and outliers. Rural facilities will see a sight payment increase as will most facilities in Ohio with area wage indexes below 1.0.

The proposed rule also calls for the start of an IRF quality "pay for reporting" program by 2014, conceptually similar to the one in place for acute hospitals but using IRF-specific measures.

The Centers for Medicare & Medicaid Services (CMS) started its annual rulemaking season April 19 with the FFY 2012 Medicare hospital inpatient and long-term care hospital (LTCH) prospective payment systems (IHPPS) proposed rule. A display copy is available now and the Federal Register version is scheduled for publication May 5. View overviews of the CMS IHPPS and LTCH proposals. Lawrence Goldberg with Grant Thornton also has a detailed review on its site. Comments are due June 20. The 2012 Medicare IHPPS goes into effect for discharges on and after Oct. 1, 2011.

CMS is also out with Medicare 2012 PPS proposed rules for inpatient rehabilitation facilities, skilled nursing facilities, inpatient psychiatric facilities and hospice wage index calculations. See the May OHA Finance News for reviews of all of the CMS proposals.

Again this year, CMS’ most controversial action involves the expansion of a reduction in IHPPS operating rates to take back what CMS states were inappropriate Medicare payments related to hospitals’ more sophisticated diagnoses and procedure coding. In 2012, CMS ups the ante by taking a one-year 2.9 percent cut for past “overpayments” and an additional permanent 3.15 percent cut for anticipated future “coding improvements.” Even taking into account a 1.1 percent, court-ordered increase to the 2012 rates to correct wage index rural-floor adjustments, CMS’ payment cut for “coding improvements,” combined with a 1.2 percent cut ordered by Congress in the Accountable Care Act to recover “productivity Improvements” and another 0.1 percent cut also ordered in the ACA to help balance the Medicare budget will all add up to a nearly half billion dollar reduction in 2012 inpatient Medicare payments to hospitals as compared to 2011.

The 2012 IHPPS proposed rule also contains a small increase payments for capital expenditures, a slight increase in the number of quality measures that must be reported for a full update in 2013—with more substantial changes in line for 2014 and 2015, some updates to the list of hospital-acquired conditions and codes, a higher threshold for the application of outlier payments, and other more general updates to the calculations of area wage indexes and payments to critical access and sole community hospitals.

Finally, the 2012 IHPPS proposed rule also expands on the rules that will drive both the Hospital Readmissions Reduction Program and the Inpatient Value-Based Purchasing (VBP) Program. (See the May OHA Finance News for additional information on the hospital VBP Program final rule.)

The Centers for Medicare & Medicaid Services (CMS) has published its guidelines for Medicare Accountable Care Organizations (ACOs). A CMS fact sheet is available, as is an OHA overview and a separate review of an FTC proposed rule addressing antitrust enforcement policies related to ACO operation. The voluntary program is rooted in Sec. 3022 of the Accountable Care Act and is being designed to spark new alliances within health care systems to lower health care cost growth while still meeting quality and patient satisfaction performance targets. CMS estimates up to four million Medicare beneficiaries will join ACOs within three years, saving the Medicare Program up to half a billion dollars.

CMS envisions a program in which hospitals, doctors and practitioner networks, suppliers and other health care professionals will form legal entities under state laws and rules to care for large groups of enrolled beneficiaries, using integrated, evidence-based guidelines and processes, with a focus on delivering quality primary care, educating patients and eliminating waste. CMS is proposing the use of quality performance measures to evaluate the effectiveness of each ACO, based on detailed data to be submitted in an electronic format. CMS would calculate a performance score for each of several subsets of the measures and is also proposing several options to use the scores to reward successful ACOs by sharing a percentage of program savings, compared to what would have been spent to care for beneficiaries had the ACO not been in place. Eventually CMS will want ACOs to share the risk of program losses, as well.

CMS has a separate webpage for shared savings programs and is holding a series of webcasts and conference call listening sessions. OHA’s Finance Committee and Board of Trustees is evaluating CMS’ ACO proposals and once a final rule is released, OHA will sponsor continuing education for its members, so watch for additional details.

The Ohio Department of Job and Family Services (ODJFS) will launch its new Medicaid Information Technology System (MITS) Aug. 2 . MITS is a comprehensive software upgrade to the state Medicaid eligibility and claims processing systems that will have wide ranging effects on how ODJFS edits and pays fee-for-service Medicaid bills, including on-line, real time bill review, editing and adjustments. MITS will not affect Medicaid managed care bill processing.

Delayed since November, ODJFS reports tests are now showing consistent results on a set of comparative readiness criteria, so it is planing to go live with the new system Aug. 2.  ODJFS has a MITS webpage with additional information and links to updates and newsletters. The department has also prepared a list of tasks providers should check and an outlibne of important MITS transition dates  as part of their conversion planning. ODJFS will continue training sessions across the state in July.

Upcoming OSHRM Events:

The OSHRM/SOHA 2012 Winter Conference has been scheduled for March 9 at The Blackwell Center on OSU Campus. 
Program Agenda
Registration Form

The OSHRM/SOHA 2012 Fall Conference is scheduled September 14 at The Crowne Plaza Dublin Hotel.  A program agenda and registration information will be available in early August.

The OONE 2011 Fall Conference is scheduled November 2, 3 and 4 at Cherry Valley Lodge in Newark, Ohio.  A program agenda and registration information will be available late-summer.

The U.S. Department of Energy’s (DOE) Waste Isolation Pilot Plant will have radioactive waste shipments transported along I-70 during June and July, and wants to ensure Ohio hospitals within 10 miles are prepared for any potential emergency response activities. The Ohio Department of Health’s Bureau of Radiation Protection (ODH-BRP), with the Council of State Governments and the DOE, will provide training options from April to June for hospitals to treat radiologically-contaminated or exposed patients.

Hospitals may choose from the following training options:
1) 7.5 hour radiological training for hospital staff performed by DOE contractor:
       -Topics: Radiological basics, facility preparation, decontamination and patient care
       -CEU’s available for doctors, nurses and radiological technologists
       -Free survey meter(s) - courtesy of ODH-BRP
2) 1-2 hour Presentation by ODH-BRP:
       -Brief summary of shipment and packaging and patient care
       -Free survey meter(s)
3) 30-minute ODH-BRP meeting with the radiation safety officer, emergency room director and any interested parties from administration:
       -Hard copies of ODH-BRP presentation
       -Free survey meter(s)

The ODH-BRP has the capability to assist in triaging when large numbers of patients are affected and is available 24 hours a day for consultation at 614.644.2727.

Contact Robert Leidy of BRP at 330.643.3290 or Program Administrator Stephen Helmer at 614.728.3611 for additional information or to schedule training.

This month Cigna Government Services (CGS) began its formal outreach to Ohio hospitals with a powerpoint presentation and a set of frequently asked questions outlining its planned conversion to the Medicare Jurisdiction 15 (J-15) Medicare Administrative Contractor (MAC). The CMS J-15 MAC covers Ohio and Kentucky and includes all Medicare Part A and B claims processing, beneficiary outreach, audit & reimbursement and medical review activities for all provider types, excepting hospice and freestanding home health. CMS released conversion details in CMS CR 6999 and CIGNA is encouraging providers and their vendors and trading partners to join its listserv for news and updates.

CIGNA is assuming an aggressive transition schedule that will move all Medicare Part B operations in Kentucky, including physicians and other practitioners, from Palmetto GBA on April 30. Ohio Part B will transition on June 18. Responsibility for all Medicare Part A business for both states will transition from National Government Services on Oct. 17, and includes hospitals and other facility-based health care providers. CIGNA states much of its Part A operations will be managed under a subcontract by Riverbend GBA.

In the months leading up to the cut-over, CIGNA will notify Ohio providers via listserv about electronic funds transfer, claims submission and outreach and education. In general, most provider action items will take place within a 90 day window leading up to the transition for that provider type. CIGNA's Local Coverage Determination (LCD) medical coverage and review policies are already available, as is a crosswalk from the NGS versions, but CIGNA reminds hospitals they will not go into effect in Ohio or Kentucky until Oct. 17.

CMS has also confirmed that all Medicare Recovery Audit Contractor (RAC) activities will cease for a six-month period around the cut-off date for each provider type. For Ohio hospitals that would run approximately July 17, 2011, through Jan. 17, 2012. OHA is seeking details on the RAC moratorium and will report again when more is known.

CIGNA does not plan to have a physical presence in Ohio or Kentucky and will instead operate out of its Nashville home base. CIGNA plans a robust provider outreach and education schedule, nonetheless, and has already scheduled a session with the Central Ohio Patient Accounts Managers (COPAM) on April 19 in Columbus. COPAM is presenting the session in conjunction with Ohio HFMA and AAHAM chapters and will publish registration material on its website. OHA will also sponsor statewide MAC educational events later this summer. Details and locations are being organized and will be available soon.

CMS has delayed the April 1 deadline for states to implement their Medicaid Recovery Audit Contractor programs, according to a recent CMS bulletin. The agency expects to announce the new implementation date later this year in a final rule for the program. CMS issued its proposed rule last year. 

The Ohio Department of Job and Family Services (ODJFS) has a RAC RFP out to interested contractors and states it is possible it will award multiple contracts to cover different types of review projects. ODJFS will insist contractors include under and overpayments. The Medicaid RAC will work like the Medicare RAC, except that timelines, records requests, appeals and recoupments will be managed by ODJFS, rather than the Medicare FI/MAC, and while there is nothing in the CMS proposed rule that enforces the Medicaid RAC rules on managed care, there is also nothing to stop Medicaid managed care plans from adopting similar programs and projects.

The Medicaid RAC will not replace or act as a substitute for either the Medicaid Integrity Program (MIP) or the Payment Error Rate Measurement (PERM) program, although the three audit programs are supposed to be checking with each other and with CMS and ODJFS so they are not reviewing the same accounts for the same issues. The CMS Region 5 MIP, which includes Ohio, is already in operation with AdvanceMed and Health Integrity under contract with CMS as the Review and Audit Medicaid Integrity Contractors (MICs).

OHA  has help with software tracking systems able to expand beyond Medicare RAC activity to Medicaid and potentially other payers at a very competitive price. For additional information contact Dorothy Aldridge.

The OSHRM/SOHA 2011 Winter Conference will be held February 25 at The Blackwell on OSU Campus.  A program agenda and registration information will be available very soon.

The Ohio Bureau of Workers' Compensation  will start a Medicare-based, hospital outpatient prospective payment system (OPPS) Jan. 1, 2011.  In a new OPPS webpage, BWC outlines the state-fund OPPS program with links to rules, formulae and educational resources. BWC also has a comparative overview of the Medicare and BWC OPPS' available.

From Jan. 1, 2011, through March 31, 2012, BWC will pay acute care hospitals 197 percent of what Medicare pays for the same outpatient service and 253 percent of the Medicare rate at childrens hospitals. Critical Access Hospitals are exempt.  For the first quarter of calendar year (CY) 2011, BWC will use Medicare's 2010 OPPS pricing and grouping methodology. Effective April 1, 2011, BWC will adopt Medicare's CY 2011 version. Thereafter, annual updates to the BWC OPPS will occur on April 1.

In the second year of BWC's transition to its OPPS -- April 1, 2012, through March 31, 2013 -- BWC will pay acute care hospitals 181 percent of what Medicare pays for the same service and pay childrens hospitals 253 percent of what Medicare pays. After April 1, 2013, the acute care rate will drop to 166 percent of what Medicare pays, while childrens hospitals will stay at 253 percent.   

The revised BWC state-fund OPPS has no direct effect on self-insured employers, but other BWC rules give them the right to adopt the state-fund methodology if they choose. 

 

Last week the Centers for Medicare and Medicaid Services (CMS) released two annual Medicare prospective payment system final rules, one for the CY 2011 hospital and ambulatory surgical center Outpatient Prospective Payment System (OPPS) and a second for the Home Health PPS (HH PPS). Both rules incorporate modifications to the payment systems mandated by the Affordable Care Act (ACA) of 2010, and the final CY 2011 OPPS rule also implements changes mandated by the ACA about how the Medicare program will reimburse for Medicare Graduate Medical Education (GME) under the Inpatient PPS. OHA has detailed overviews of the OPPS and HH PPS rules available online. Lawrence Goldberg (Grant Thornton) also has a OPPS review. 

2011 OPPS payment rates will be increased by 2.35 percent -- making the conversion factor $68.876, up $1.635 from 2010. CMS added four new outpatient quality reporting measures, revised its physician supervision requirements (again), and decreased the outlier threshold. Home Health PPS payment rates will be markedly lowered, even with a 2.1 percent inflationary update, because CMS is enforcing a 3.79 percent cut to account for "coding improvement." Combined with another cut in HH PPS outlier payment rates, overall Medicare payments to home health agencies are expected to drop 5.2 percent next year.

Unrelated to either payment system, CMS also included several updates to the inpatient hospital PPS system in the OPPS final rule to change the way it reimburses hospitals for graduate medical education. Both rules are expected to be published in the Nov. 29 Federal Register.

In its Spring 2010 and Summer 2010 editions of the Ohio Medicaid Quality Monitor, Permedion, the Ohio Department of Job and Family Services' (ODJFS) quality review contractor, outlines its concerns that hospitals are inappropriately using unlisted CPT procedure codes on outpatient Medicaid bills. 

ODJFS initially brought the issue to the OHA Finance Committee's attention during the public rule review that preceded the implementation of the 2010 outpatient hospital fee schedule.  While examining the payment-to-statewide-cost of various code sets in the fee schedule, ODJFS discovered that codes for unlisted surgery and for services billed under Paragraph K of OAC 5101:3-2-21 were being reimbursed at an high rate compared to others. See the January OHA Finance News for additional background on the 2010 Medicaid outpatient hospital fee schedule.  

While part of the payment anomaly can be attributed to the fact that these services are paid on the basis of a percentage-of-charge, ODJFS stated it is concerned that services being billed with unlisted CPT codes, particularly those related to dental services, may not be covered in a hospital setting. The Finance Committee replied that most of the dental care being billed by hospitals relate to services delivered in an emergency setting or to patients requiring non-routine sedation. 

ODJFS nonetheless stated it intends to carefully review both unlisted procedure codes and the services being billed under Paragraph K to determine whether they are being over-paid. The Spring 2010 Permedion newsletter represents the start of that process and hospitals are advised to review it respond appropriately.  

CGI Federal, the Medicare Recovery Audit Contractor for the region which includes Ohio, announced this week it will immediately begin reviews on 18 newly approved projects that involve the medical necessity of selected inpatient DRG payments. The projects are expected to be posted to CGI's Web page today and hospitals are advised to plan accordingly.

The American Hospital Association is warning states to watch the new projects closely, since problems with medical necessity reviews occurred during the three-year RAC demonstration, including a key concern that RAC auditors lacked adequate clinical  expertise and Medicare-coverage experience to determine whether hospital care was reasonable and necessary.

OHA is also planning its first annual Ohio RAC Summit, for Wednesday, Nov. 3 at the Bridgewater Conference Center in Columbus. Mark your calendars for this one-day session featuring updates from CGI, CMS and National Government Services, as well as sessions on the CMS PEPPER report and updated RAC best practices. Additional information and registration materials will be posted to OHA's RAC Web page soon.

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CMS' final rule on its FFY 2011 Medicare inpatient hospital prospective payment system (IHPPS) was publised in the Federal Register Aug. 16, including a 2.9 percent cut to recover what CMS alleges was a past increase in operating and capital payments related to better ICD.9.CM coding, rather than the cost of the care (2.5 percent to long-term care hospitals). A brief CMS fact sheet is available as is a detailed review by Lawrence Goldberg (Grant Thornton). The 2011 IHPPS final rule is expected to be published in the Federal Register on Aug. 16 and go into effect Oct. 1.

CMS' 2.9 percent "coding creep" cut was by far the most controversial and contested part of the 2011 final rule and is expected to be the subject of intense Congressional lobbying this summer and fall. According to American Hospital Association (AHA) estimates, it will reduce Medicare payment to hospitals nationwide by $3.7 billion in 2011 ($125 million estimated in Ohio), with another cut of the same size scheduled for FFY 2012. Overall, and due specifically to the coding cut, AHA states the average acute care hospital will be paid .4 percent less in 2011 than it was in 2010.

Other aspects of the final rule include:

• Sets of additional quality reporting measures for FFY 2011, 2012 & 2013, totaling 60 measures once all are effective.
• Three updates to payment policy for Critical Access Hospitals, including what many think is the
  first step off a slippery slope of tying the allowance of state hospital tax payments to "related" returns.
• Further tinkering with the three-day, "DRG Window" inpatient admission bundling rules, with CMS now saying all outpatient non-diagnostic care in the three days before an inpatient admission will be considered related -- a complete reversal of policy re-stated a year ago -- unless the hospital specifically documents that it is not, using a yet-to-be released format.
• Lower thresholds for IHPPS outlier payments for acute care hospitals.
• Better payments to "low-volume" and Medicare-dependent hospitals

CMS' Jurisdiction 15 (J15) Medicare Administrative Contractor (MAC) award to CIGNA Government Services is again on hold. Both National Government Services (NGS), the current Medicare FI for the region, and Hignmark Medicare Services filed  protests last week, which means the US Government Accountability Office may not issue a decision until mid-fall.

CMS posted a brief overview of its decision to award the J15 MAC to CIGNA Government Services, LLC earlier this month. The MAC contract includes nearly all Medicare parts A and B, provider and beneficiary  operations in Ohio and Kentucky, and was first awarded to Highmark in January 2009. Two firms protested, the award, one of them reportedly CIGNA, and CMS re-bid the contract. Following the re-bid, CMS announced it had reversed its initial decision and gave the job to CIGNA. Now that award has been officially protested, so the process is once again on hold.   

The J15 MAC also includes home health and hospice claims administration for Colorado, Delaware, District of Columbia, Iowa, Kansas, Maryland, Missouri, Montana, Nebraska, North Dakota, Pennsylvania, South Dakota, Utah, Virginia, West Virginia and Wyoming.

NGS says it it is likely any MAC transition will run well into 2011, regardless, so it is Medicare business usual for Ohio hospitals and doctors. OHA will continue to monitor the situation and report again as details are released. 

Medicare released its FFY 2011 Inpatient Rehabilitation Facility Prospective Payment System (IRF PPS) notice in the July 22 Federal Register. The updates go into effect for IRF discharges on and after Oct. 1, 2010. CMS is not requesting comments related to the update notice as it contains only rate updates, with no major policy changes.

CMS set the IRF PPS "marketbasket" at 2.5 percent, but will reduce it by 0.25 percentage points as ordered by Congress in the PPACA. Including other adjustments for budget neutrality, the IRF standard payment conversion factor for 2011 will be $13,860, up from $13,627 in 2010, a 1.7 percent increase.

CMS is proposing no changes to the current facility-level rural, low-income patient (LIP), and teaching adjustments under the IRF PPS. CMS will maintain for FFY 2011, the facility-level adjustments established for FFY 2010. To ensure outlier payments continue to comprise 3.0% of total IRF PPS payments, will increase the outlier threshold to $11,410, which will reduce the number of rehabilitation cases eligible for outlier payments. Finally, CMS will decrease the labor-related share of the federal rates from 75.779 percent in FFY 2010 to 75.271 percent in FFY 2011.

The Coalition to Protect America's Health Care has launched a national television ad campaign to tell Congress to extend the enhanced FMAP.

Visit www.protecthealthcare.org

On July 2, CMS released its annual proposed rule to update the Medicare Outpatient Prospective Payment System (OPPS) for calendar year 2011. The rule covers both outpatient hospital and ambulatory surgical center (ASC) services. A display copy is available now and the formal filing is scheduled for the Aug. 3 Federal Register. A detailed review by Lawrence Goldberg (Grant Thornton) is also available. Comments are due Aug. 31.

The proposed inflationary update to the OPPS APC conversion factor for hospitals is 2.4 percent, which will be reduced by .25 percent as ordered by Congress in the Affordable Care Act (ACA). The 2011 ASC inflationary update is pegged at 1.6 percent, which CMS proposes to completely eliminate in line with a required productivity adjustment, also ordered in the ACA, which coincidentally equals 1.6 percent. Hospitals that did not submit required quality data in 2010 will suffer an additional 2 percentage point reduction. CMS is also proposing six new quality reporting data measures for 2011 -- increasing the total to 17 -- another seven for 2012, and six more to go into effect in 2103. CMS will randomly pick 800 hospitals next year and validate the accuracy of their quality data, with the threat of additional payment reductions if CMS does not agree with the majority of the results.

In addition to the usual laundry list of changes to Ambulatory Patient Groups, CMS continues to tinker with its physician supervision requirements by proposing to require two levels of supervision for "non-surgical extended duration" services, including outpatient observation. The proposed rule also expands CMS' program of reduced coinsurance and deductible amounts for a list of basic preventative services.

Finally, the proposed rule includes policy and reimbursement changes for cancer hospitals, covered ASC services, partial hospitalization programs, inpatient-only procedures and outlier payments.

In a June 17 comment letter, OHA joined the American Hospital Association (AHA) and dozens of other state hospital associations in opposing CMS' plan to substantially cut Medicare payments under the 2011 and 2012 Medicare inpatient hospital prospective payment systems (IHPPS) to account for what CMS alleges are overpayment related to coding improvement on Medicare bills. The CMS proposal could cost Ohio hospitals as much as $250 million over two years.

OHA data shows hospitals are not overpaid under the current system, but that they were underpaid using the prior diagnosis-related grouping system. OHA also protested CMS' plan to disallow the cost of state hospital tax assessment programs as a cost of doing business for Critical Access Hospitals.

CMS published the initial IHPPS proposed rule rule May 4.  A follow-up proposed rule to cover the provisions of the Patient Protection and Affordable Care Act (PPACA) of 2010 was published June 2.  Lawrence Goldberg has detailed reviews of both rules in his Washington Bulletins on the Grant Thornton Web site. 

This marks the third time that CMS has called for huge cuts in hospital payments to offset alleged past increases it states are attributed to better diagnosis and procedure coding rather than increases in the cost of the care. To explain its position CMS released Understanding the Documentation and Coding Adjustment.  Hospitals successfully blocked similar CMS proposals so far, but it is not clear how CMS or Congress will respond this year and AHA predicts a major fight . 

Other Medicare policy and payment proposals for 2011 include the usual 2 percentage point cut to hospitals that did not submit required data on quality measures, 10 new and one retired quality measure (bringing the total to 55), but no new Hospital Acquired Conditions, at least not for next year.

CGI Federal, the Region B Recovery Audit Contractor (RAC) started rolling out the third, 45-day cycle of Additional Documentation Requests (ADRs) this month, increasing the pressure on providers by announcing higher limits on the number of requests it can make each cycle for most Medicare hospitals.  The Centers for Medicare & Medicaid Services (CMS) authorized RACs to request up to 300 medical records each 45-day period if an instutional provider had more than 100,000 claims in 2009, although CGI states it is still not requesting as many records as CMS allows. A brief CMS presentation on the revised limits is available. CGI states there will be additional information on its Web site later this month that will lay out how it calculates each hospital's records limits. 

For other Ohio RAC developments, including a report on problems with the link between the RAC activities and the Medicare Remittance Advice, go to the April OHA Finance News.  CMS also posted a PowerPoint presentation on its RAC adjustment "Section 935" Limitation on Recoupment process. 
   

CMS has put its proposed rule for the 2011 Medicare Skilled Nursing Facility Prospective Payment System (SNF PPS) on hold.

In a May 24 announcement, CMS stated the Patient Protection and Affordable Care Act (PPACA) mandates it delay the start of most of Version 4 of its new SNF PPS case mix classification system -- the Resource Utilization Groups (RUG) IV) -- until FFY 2012, and requires version 3.0 of the Minimum Data Set (MDS 3.0) Resident Assessment Instrument be implemented as planned in FY 2011.  As such, CMS must hold the 2011 SNF PPS proposed rule as it builds the required payment infrastructure.

CMS states it will publish interim Oct. 1, 2010, payment rates in a future Federal Register, using both MDS 3.0 and RUG-IV in its entirety. Then, if necessary, it will adjust payments at some point in the future, once the software for the PPACA-required hybrid RUG classification system is ready.   CMS states this approach will allow  it to make payments with the least disruption for providers and beneficiaries. Watch for additional information this summer.  

CMS hosted a national conference call on RUG IV June 23 to review  coding procedures with emphasis on the appropriate “look-back” periods to be used when coding the MDS 3.0, and how SNFs should separately report individual, concurrent and group therapy for accurate payment.  A PowerPoint slide presentation from the 6/23 call is available. Two additional provider calls are being scheduled for August 2010 to explain other payment issues, including the transition from RUG-III to RUG-IV and the additional changes needed to install a hybrid RUG-III grouper (HR-III) mandated by statute. 

 

Hospitals across Ohio are receiving the second round of Recovery Audit Contractor (RAC) Additional Documentation Requests (ADRs) on Complex Review projects. CGI Federal, the Region B RAC for most of the great lakes states, started distributing “Round Two” ADR letters earlier this month on a rolling basis to Ohio Medicare providers, and in most cases, results from the first round of RAC Complex Reviews are also coming in. Hospitals are advised to keep watch for both.

CMS is also holding the first of a series of national “RAC 101” teleconferences April 28 from 1-2:30 p.m. For details and dates on additional calls go to the CMS Web page for recent RAC updates.

Other Ohio RAC developments, including a report on problems with the link between the RAC activities and the Medicare Remittance Advice. go to the April OHA Finance News.

National Government Services (NGS), the regional Medicare Part A Fiscal Intermediary, is predicting it may be well into 2011 before the Centers for Medicare & Medicaid Services(CMS) moves forward with plans to combine all beneficiary, medical review and provider operations into one Medicare Administrative Contractor (MAC) for Ohio and Kentucky.

CMS has had several regional MAC contracts on hold for some time, including the OH/KY Jurisdiction 15, initially based on a threatened legal challenge to its decision to award the J-15 MAC contract to the Philadelphia-based Highmark Medicare Services, later because of a conflict with the rollout of the Region B Medicare Recovery Audit Contractor (RAC), and now, reportedly due to CMS' desire to see what Congress does with national Medicare payment and coverage reform.

NGS states it is still in the running for the J-15 MAC award and will report again as soon as additional information is released from CMS. Regardless, NGS is telling OHA it will be handling Medicare Part A claims processing and medical review, including RAC appeals, for the rest of 2010 and probably well into 2011.

The Ohio Bureau of Workers' Compensation (BWC) will delay the start of its transition to a hospital outpatient prospective payment system (OPPS) until 2011, citing complaints from OHA and a number of member hospitals about the negative effects of the proposed BWC OPPS on 2010 budgets.

Last summer, BWC unveiled a plan to adopt the Medicare OPPS as its payment methodology for outpatient hospital services for the state-fund Health Partnership Program (HPP), effective April 2010. BWC also announced its intention to cut $30 million a year in state-fund outpatient hospital payments by setting the BWC OPPS rate at 166 percent of what Medicare pays for the same service at a general acute care hospital and 253 percent of the Medicare rate at a childrens' hospital. Critical access hospitals would be exempt from the BWC OPPS, just as they are from Medicare's.

OHA's Finance Committee opposed the move in a series of meetings with BWC staff, protesting that the imposition of an OPPS is unnecessary, overly expensive and, in conjunction with planned payment cut, highly redistributive within hospitals and systems. BWC insisted its OPPS plan was sound and cost effective, but initially responded to OHA by bumping the implementation back one month and adding a two-year transition, during which hospital payments would be based on a blend of old and new payment systems.

At this point, however, while still defending its decision to move to an OPPS, BWC states it will compromise with hospitals concerned about meeting 2010 budgetary targets set before the bureau's plans were finalized by holding off on OPPS until Winter 2011, and then starting the promised two-year transition, which will push full OPPS implementation back to 2013. OHA will follow the story as it develops and report again when additional details are released.

The Lobbying Expenditure Law requires OHA to notify its membership of the percentage of membership dues related to lobbying activities that, depending on an institution’s tax status, would be non-deductible under the law. OHA sent a letter with 2010 details to hospital CFOS by e-mail Friday, Feb. 19. 

ODJFS revised its Medicaid outpatient hospital fee schedules for 2010, reversing an Oct. 1, 2009, increase to specific CPT codes and services in the hospital emergency department and surgery fee schedules. Instead, ODJFS will inflate all non-charge-based outpatient hospital fee schedule payments by 5 percent, effective with services delivered Jan. 1, 2010, and after (see the October 2009 OHA Finance News for additional background) . The updated hospital fee schedules are included as attachments to HHTL 3352-09-07, which includes all changes to OAC 5101:3-2-21. The department also released HHTL 3352-10-01 with all 2010 hospital payment and policy updates.

ODJFS also states it will "open" UB-04 Revenue Code 0636 to allow hospitals to submit detail coding for drugs, effective April 1. RC 0636 is not required, but if it is used, hospitals will have to include a HCPCS J Code with it. 

OHA is still waiting on word regarding a possible requirement for additional detailed coding of pharmacy items. In December, ODJFS stated it would hold back any requirement to use National Drug Codes (NDCs) while it explores other, less expensive and cumbersome options with CMS. OHA continues to recommend hospitals cease all activity on NDCs until further notice.

The Quality Institute of the Ohio Hospital Association is accepting proposals for presentations to be held at the 3rd Annual Quality Collaborative Summit  June 16 at OHA’s Annual Meeting at the Hilton Columbus at Easton.

The Quality Institute calls for speakers and poster presenters on the following four educational topics:

• Infection Control
• Falls
• HCAHPS (Patient Satisfaction)
• Readmissions
  

View RFP for more information.

The SOOHP Annual Conference will be held March 25-26, 2010, at The Doubletree Hotel in Worthington. 

Brochure
Registration Form
Online Registration

The final nomination deadline for OHA’s 2010 Albert E. Dyckes Health Care Worker of the Year Award is Monday, Feb. 1. Supporting material for nominations is available, including:

• A submission checklist
• Nomination writing tips
• Health Care Worker of the Year facts
• A PDF document of nomination questions (to review questions before submitting the online nomination)

Nominations must be submitted online by Feb. 1. All nominees will be celebrated at the OHA Recognition Dinner June 15 at the Hilton Columbus at Easton during OHA’s Annual Meeting.

CMS released the CY 2010 Home Health Prospective Payment System final rule (HH PPS) Nov. 10. The 2010 rule updates the base HH PPS rates by 2 percent, but also continues CMS' 2.75 percent reduction to the HH PPS rates to account for what it alleges are payment increases related solely to coding improvements. The rule also caps outlier payments and implements a new version of the OASIS patient assessment tool, the OASIS-C, beginning Jan. 1, 2010. A detailed review by Lawrence Goldberg, Grant Thornton is available.

The National Uniform Billing Committee (NUBC) recently approved a series of changes to the UB-92 Point of Origin code set (formerly “Source of Admission”). These changes become effective for discharges on or after July 1, 2010. This data element is reported in Form Locator 15 of the UB-04 and in CL102/Loop ID 2300 of the 837 Institutional implementation guide.

1) Three codes are eliminated and will no longer be valid for use:

• Code 7 - Emergency Room
• Code B - Transfer from Anther Home Health Agency (Replaced with new Condition Code 47)
• Code C - Readmission to Same Home Health Agency

2) The definitions to Codes 1 and 2 have been modified. Code 2 now includes both clinic and physician office points of origin.

3) Also effective 7/1/10 is new Condition Code P7 to indicate that the patient was admitted directly from this facility’s Emergency Room/Department; it is FOR PUBLIC HEALTH REPORTING ONLY.

CMS released the CY 2010 Home Health Prospective Payment System final rule (HH PPS) Nov. 10.  The 2010 rule updates the base HH PPS rates by 2 percent, but also continues CMS' 2.75 percent reduction to the HH PPS rates to account for what it alleges are payment increases related solely to coding improvements. The rule also caps outlier payments and implements a  new version of the OASIS patient assessment tool, the OASIS-C, beginning Jan. 1, 2010. A detailed review by Lawrence Goldberg, Grant Thornton is available.

The Medicare Outpatient Prospective Payment System (OPPS), which covers outpatient hospital and ASC services, was updated in  the Nov. 20 Federal Register. Hospitals that report the 11 required outpatient quality data measures will receive an overall 2.1 percent update. ASCs will get 1.2 percent. The rule also covers several policy changes on the coverage of additional pulmonary and cardiac rehab services and newly clarified guidelines for physician supervision that will allow an on-campus hospital exemption to the direct supervision requirement to continue. Off-campus hospital services will be subjected to more stringent supervision guidelines. CMS has additional details on the 2010 OPPS on its Web site and a detailed analysis from Lawrence Goldberg, Grant Thornton, is also available.

CMS released revised inpatient rehab hospital coverage guidelines in Transmittal 112 on Oct. 23.  Reflecting changes contained in the Aug. 7, FFY 2010 Inpatient Rehabilitation Facility PPS Final Rule, the latest updates go into effect on Jan. 1, 2010,  and include new documentation, screening and evaluation, and supervision requirements, as well as updated medical necessity criteria.  Copies of the overhead presentation from a CMS Nov. 12 special conference call on the new IRF requirements are available.   

The Health Coalition on Liability and Access issued a report on “The State of Medical Liability Reform” in which it showed how patient access to care was improved in states with tort reform as compared to states without tort reform.

CMS will not cut Medicare inpatient hospital (IH) PPS and long-term acute hospital (LTCH) payments to account for "coding creep" in FFY 2010. In its final rule, CMS states its data is not detailed enough to warrant the cut in 2010, but it will continue to analyze inpatient payment data and re-visit the policy in FFY 2011. Both OHA and the American Hospital Association strongly opposed CMS' earlier statement that the cut was necessary to reverse payment increases due to better ICD.9.CM coding, rather than the cost of care. CMS will also continue to pay teaching hospitals for capital expenditures, strengthen hospitals' quality reporting requirements and make several other changes to IH PPS and LTCH coverage and payment policy. A detailed review by Lawrence Goldberg, Grant Thornton, is available, as are CMS alerts on the hospital payment and quality provisions

CMS will implement the 2010 update to the Medicare Skilled Nursing Facility Prospective Payment System (SNF PPS) Oct. 1, 2009. A final rule was released Aug. 11.  CMS' continued "refinement" of the Resource Utilization Group (RUG) III discharge classification system will result new payment cuts to SNFs estimated at $609 billion, even with a full market-basket increase in 2010. CMS states it will implement RUG IV in 2011, which is expected to further increase the number of PPS groups and continue to drive down SNF reimbursement. A review of the FY 2010 SNF PPS final rule by Lawrence Goldberg, Grant thornton, is available.   

OHA is launching a redesigned Web site Sept. 15. The new site will contain many new features, including:

• A tool for employees to select their area of interest and have access to pertinent educational activities, news, etc...;
• The ability to sign up for RSS feeds on a variety of subjects;
• Photos showcasing hospitals and employees;
• Important announcements featured in a special section.

The new site will be more interactive and bring important news and information to hospitals, legislators, elected officials, the media and public in a more accessible way.

CMS released its rate year 2010 final notice with updates to the Inpatient Psychiatric Hospital Prospective Payment System (IPF PPS) on May 1, 2009. The notice, effective with discharges July 1, 2009, and after, includes a 2.1 percent increase in overall IPF PPS payments, upping the federal per day base rate to $651.76. The notice also slightly increases the portion of the base rate to which an area wage index is applied and makes minor adjustments to the drg groupings and comorbidity payments. A review of the notice by Lawrence Goldberg, Grant Thornton, is available.