MHA Today | June 24, 2016

June 24, 2016

MHA Today: News for Healthcare Leaders

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Herb Kuhn, MHA President & CEO

On June 14, the Centers for Medicare & Medicaid Services held a “special edition” of its open door forum series asking the nation’s critical access hospitals to weigh in on payment policy. During the call, CMS encouraged CAHs to articulate how the proposed policies would affect their hospitals. Let me explain why I think all 36 Missouri CAHs, as well as every CAH throughout the nation, should respond.

In the past, President Obama’s budget has recommended reducing CAHs’ cost-based payment rate from 101 percent to 100 percent. In recent years, Congress seldom adopts the president’s budget. However, items that appear in the budget can become more open to scrutiny by policymakers as the politics of budget-making unfold.

The call was designed to probe the potential impact of eliminating the “cost-plus” payment system. As rural hospitals know, that horse has already left the barn. Several years of sequestration have resulted in less than cost reimbursement. Reducing to 100 percent would result in an actual payment of 98 percent. And, anything less than a full-throated rejection from the rural hospital community would send the wrong message — that any cuts, no matter the size, wouldn’t jeopardize the already fragile rural health delivery system. CAHs are essential to rural citizens because they allow care close to home. Rural Missouri is older and sicker than urban and suburban parts of the state. The growing “silver tsunami” means more seniors will have limited access to health care without a strong CAH system — a system that helps retain and attract physicians and other health providers to communities throughout rural Missouri.

Medicare’s commitment is fundamental to CAHs’ survival. The original payment system reflected that commitment — recognizing that CAHs’ patient mix is weighed heavily toward Medicare beneficiaries. However, the proposed Medicare reductions would disproportionately erode CAH financials, and compound CAHs’ existing burden of caring for rural Missourians where uninsured rates are higher than other parts of the state.

The first goal is to beat back arbitrary payment cuts. To do this, CAHs should identify all of the negative impacts of the proposed cuts and share them with CMS. This includes direct financial impact as well as the influence of cuts on quality improvement programs, community health investments and other community supporting activities. CMS asked. CAHs must reply. Letters can be sent here through June 30.

There’s another matter, and it deserves equal attention.

The Medicare Payment Advisory Commission recently released a report investigating new opportunities for CAHs. It included consideration of how policy changes could improve efficiency and preserve access to emergency care in rural areas.

Presently, policy is essentially forcing a binary decision for CAHs — open or close, depending on financial strength. Unfortunately, when a rural hospital closes, it seldom returns. That means that large parts of rural Missouri, and the nation, could end up as health care deserts.

MedPAC, and some rural health advocates, have argued that the answer should be more than open or close. The decision framework should include delivery options that preserve essential services in sparsely populated rural communities that simply can’t sustain a full service hospital. Although a hospital may be too expensive to sustain in these communities, rural residents continue to require access to 24/7 emergency care, ambulatory care, ambulance services and other community-based health care services. There must be a balance to provide access to all Medicare beneficiaries, and all rural residents.

It’s unlikely that Congress will move on policies that reshape rural health care until 2017. However, after the election, there’s a good chance that federal entitlement reform will move to the front burner with the new administration and Congress. Between now and the election, the hospital community, policy experts and advocates have the opportunity to begin to shape the debate about future investments in rural health care.

Cuts, without a counterbalance to ensure access to necessary care, will have long-term consequences. The status quo must hold until new options can be designed. To do otherwise is to guarantee harm in the short term for Medicare beneficiaries, and long-term damage to rural health.

Let me know what you’re thinking.
Herb Kuhn, MHA President & CEO

Herb B. Kuhn
MHA President and CEO

In This Issue
Aetna Appeals Adverse Merger Decision
MHA Submits Comments On Proposed MACRA Physician Payment Regulations
CMS Proposes Rules To Make Antibiotic Stewardship Mandatory
Senate Introduces Family First Act On Foster Care
MLN Connects Provider eNews Available
SAMHSA Releases Protocol Addressing Men’s Behavioral Needs
American Heart Association/American Stroke Association To Host Free Webinars

state and federal health policy developments

Aetna Appeals Adverse Merger Decision

Staff Contact: Jane Drummond

Aetna filed an appeal of the decision by the Missouri Department of Insurance Director John Huff denying it a license to issue certain lines of insurance after its proposed merger with Humana. The appeal claims that the director’s decision incorrectly determined that the merger would have anticompetitive effects and was against the weight of the evidence presented by Aetna in support of the transaction. The petition calls for the court to conduct a new inquiry into the matter. The parties may present new evidence to the court in support of their respective positions or agree to rely on evidence submitted at the department’s May 16 merger hearing.

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Regulatory News
the latest actions of agencies monitoring health care

MHA Submits Comments On Proposed MACRA Physician Payment Regulations

Staff Contact: Daniel Landon

MHA has submitted a comment letter regarding CMS’ proposed regulations to implement the Medicare physician payment system created by the Medicare Access and CHIP Reauthorization Act of 2015. MHA previously issued an issue brief on the topic. Comments can be submitted electronically until 4 p.m. Monday, June 27.

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CMS Proposes Rules To Make Antibiotic Stewardship Mandatory

Staff Contact: Sarah Willson

Last week, the Centers for Medicare & Medicaid Services published proposed rule changes for hospitals, critical access hospitals and laboratories. One of the more notable proposals would make antibiotic stewardship programs mandatory. ASPs are viewed by many as a way to prevent antibiotic misuse and the spread of drug-resistant disease. Only 40 percent of U.S. hospitals have an antibiotic stewardship program and an estimated 30 to 50 percent of prescribed antibiotics are unnecessary or inappropriate. In the U.S., drug-resistant diseases caused 23,000 deaths and 2 million illnesses each year. MHA plans to review the proposed rules and comment. Member hospitals are encouraged to share comments with MHA. The deadline for commenting is 5 p.m. Monday, Aug. 15.

The Centers for Disease Control and Prevention, in an effort to help providers and protect patients, provides a resource on antibiotic stewardship.

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Senate Introduces Family First Act On Foster Care

Staff Contact: Sarah Willson

Late last week, Senate Finance Committee Chairman Sen. Orrin Hatch (R-Utah), Ranking Member Sen. Ron Wyden (D-Ore.), and committee members Chuck Grassley (R-Iowa) and Michael Bennet (D-Colo.) introduced the Family First Prevention Services Act (S.3065) in the Senate. The Senate bill is a companion to the House bill of the same name (H.R.5456), which was approved June 21 on a voice vote by the U.S. House of Representatives. Among the legislation’s provisions (in both the House and Senate) is one that would create a new definition and category of provider to be known as a “Qualified Residential Treatment Program.”

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MLN Connects Provider eNews Available

Staff Contact: Andrew Wheeler

The Centers for Medicare & Medicaid Services issues updates to MLN Connects Provider eNews. eNews includes information about national provider calls, meetings, events, announcements and other MLN educational product updates. The latest issue provides updates and summaries of the following.

  • Comments on the MACRA proposed rule due June 27
  • Hospice quality reporting: annual payment update
  • Medicare will use private payer prices to set payment rates for clinical diagnostic laboratory tests starting in 2018
  • HHS announces major initiative to help small practices prepare for the quality payment program
  • Chronic care management payment correction for RHCs and FQHCs
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Quality and Population Health

SAMHSA Releases Protocol Addressing Men’s Behavioral Needs

Staff Contact: Sarah Willson

The Substance Abuse and Mental Health Services Administration has released a Treatment Improvement Protocol specifically addressing the unique behavioral health needs of men. This TIP covers many topics relating to adult men (defined here as individuals ages 18 and over) and their use of, abuse of, and/or dependence on substances. American men die at a younger age on average than women; are also more likely than women to have a substance use disorder, to be incarcerated, to be homeless as adults, to die of suicide, and to be victims of violent crime. Conversely, men are less likely than women to seek medical help or behavioral health counseling for any of the problems they face.

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American Heart Association/American Stroke Association To Host Free Webinars

Staff Contact: Sarah Willson

The American Heart Association/American Stroke Association will host two free webinars: “2016 International Stroke Conference Highlights” 11 a.m., Wednesday, Aug. 3, and “Acute Stroke Ready Hospital Certification” 1 p.m., Thursday, Aug. 25. Registration is required.

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Did You Miss An Issue Of MHA Today?

June 23, 2016
DOL Persuader Rule To Take Effect July 1
CMS Announces IPFQR Webinar

June 22, 2016
Governor Approves Expanded Access To Naloxone
U.S. House Republicans Unveil “Repeal and Replace” Plan
CMS Releases The 2016 Medicare Trustees Report
MO HealthNet Posts Reminder Of Quit Smoking Benefits
TJC Proposes New Outcome Standards For Behavioral Health
TJC Releases Updates On Texting And Antimicrobial Stewardship
CDC Recommendations For Zika IgM Antibody Testing

June 21, 2016
MHD Posts Updates To DME Coverage
MHD Extends Registered Behavior Technician Credential Deadline
HHS Announces $100 Million To Help With MACRA Payment Provisions
CMS Releases Life Safety Survey And Certification Memo
TJC Revises CT Elements Of Performance Standards
CDC Issues Preparedness Plan For Locally-Acquired Zika Cases

June 20, 2016
Congressional Committee To Assess National Trauma System
CMS Issues Final Rule Setting Lab Test Payment Rates
CMS Proposes Changes To Payment Error Rate And Eligibility Determination Standards
HIDI HealthStats — Mental Health In Missouri

Consider This ...

As of June 16, 2016, there were 265 pregnant women with any lab evidence of Zika virus infection in the U.S. and Washington, D.C.

Source: Centers for Disease Control and Prevention