MHA Today | July 1, 2016

July 1, 2016

MHA Today: News for Healthcare Leaders

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Editor’s Note: MHA Today will not be published Monday, July 4. Publication will resume Tuesday, July 5. Have a safe and wonderful Independence Day!


Herb Kuhn, MHA President & CEO

Earlier this week, comments on the physician payment program overhaul included in the Medicare Access and Children’s Health Insurance Program Reauthorization Act of 2015 were due to the Centers for Medicare & Medicaid Services. MACRA replaced the failed sustainable growth rate system with two new alternatives — an alternative payment model or a merit-based incentive payment system. Or, it could be said that CMS’ MACRA SGR replacements are APM and MIPS.

We all know that Medicare is an alphabet soup of acronyms. The running joke, for those who remember CMS’ predecessor, the Health Care Financing Administration, was that the acronym HCFA actually stood for “here comes further aggravation.” The accountable care organization acronym, ACO, has been castigated as, “another consulting opportunity.” Some of the suggested meanings of CMS cannot be spoken in polite company.

What will providers call MACRA, APM and MIPS? If the comments submitted to CMS are any indication — and without changes to reflect physician and provider community concerns — we can expect something pejorative.

Replacing the SGR was a major victory for Medicare and the physician community. MACRA has the potential to fix the payment system while aligning physician quality improvement and reporting programs with other volume to value provider-community efforts. However, whether the rule can deliver is open to question.

For example, the proposed rule would take effect in January 2017. This leaves very little time for providers to prepare. Moreover, the rule uses 2017 performance as the baseline for payment system changes beginning in 2019. The APM and MIPS are being delivered to a defuse community of providers on a timeline that will be difficult for them to meet. This could result in significant and unnecessary penalties.

Another implementation challenge includes the rule’s requirement that physicians consult a prescription drug monitoring program. Generally, this would not be a major obstacle, but in Missouri, this isn’t an option. Should physicians be penalized for Missouri’s continued rejection of a statewide PDMP? Certainly not. Especially since they’ve been partners in advocating for a program.

To be sure, CMS has their work cut out for them when they begin the process of reviewing the thousands of comments they received on this proposed rule. Congress handed them a very complex and difficult law to implement. Much of what they are designing is new and on a tight timeline. That’s why the agency will have to thoroughly review these comments and not have a “tin ear” to the sometimes difficult tone and vigor of some of the commenters. Further, it is important that regulators have a deep sense of self awareness of their program’s reach and impact.

Absent additional refinements to the rule, MACRA could expand measure reporting without ensuring the measures are aligned with other members of the provider community. In an era of value versus volume, misaligned measures create paperwork rather than performance. That’s a waste of resources. Further, efforts need to be taken to streamline reporting systems and bolster the number of APMs that will be available. Absent that, the program default will be that virtually all providers and the patients they serve will be lumped into the MIPS model.

There are numerous problems with the rule. In fact, the American Medical Association’s public comment letter exceeded 65 pages. CMS will need to address provider community concerns if they want a system that delivers better value.

Without changes, MACRA could quickly morph into a euphemism for frustration. In the future, the joke may be that MACRA means “Medicare’s approach curtails real achievement” or “more annoyed clinicians retire abruptly.”

CMS has a choice. Work on revisions or prepare for the inevitable MACRAnyms.

Let me know what you’re thinking.

P.S.: Earlier this year, MHA launched a special section on our website for MACRA issues and resources. We’ve already held webinars on the subject and more are scheduled.

P.P.S.: Last week, I opined on the invitation from CMS to critical access hospitals to share how proposed payment policies would impact their operations and communities. Several of Missouri’s 36 CAHs responded to the CMS invitation, sending excellent letters to CMS, as did the American Hospital Association.

Herb Kuhn, MHA President & CEO

Herb B. Kuhn
MHA President and CEO

In This Issue
CMS Releases 2015 Open Payments Data
HHS Announces Oncology Care Model
CMS Finalizes Rule Giving Access To Information For Better Patient Care
TJC Releases Antimicrobial Stewardship Standards
CMS Publishes Correction To Recently Updated Fire Safety Requirements
CMS Announces Open Door Forums
Tracy Resigns From Barnes-Jewish St. Peters Hospital And Progress West Hospital

Regulatory News
the latest actions of agencies monitoring health care

CMS Releases 2015 Open Payments Data

Staff Contact: Andrew Wheeler

The Centers for Medicare & Medicaid Services has released 2015 Open Payments Data. The data include the transfers of value by manufacturers of drugs, biologicals and medical supplies that are paid to physicians and teaching hospitals. For the open payments program year 2015, $7.52 billion in payments, and ownership and investment interest were paid to physicians. CMS further stated that 2.26 percent of all transactions were related to opioid medications.

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HHS Announces Oncology Care Model

Staff Contact: Andrew Wheeler

The U.S. Department of Health & Human Services announced that it has selected nearly 200 physician group practices and 17 health insurance companies to participate in the Oncology Care Model. The model will begin Friday, July 1, include more than 3,200 oncologists and cover 155,000 Medicare beneficiaries. Participants will provide treatment following nationally recognized clinical guidelines for patients undergoing chemotherapy. The beneficiaries who are in the model also will receive coordinated appointments with providers to ensure timely diagnostic services and treatment, 24/7 access to care, the ability to arrange for diagnostic scans and follow-up with other medical teams, and more. CMS has listed no participating providers in the state of Missouri.

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CMS Finalizes Rule Giving Access To Information For Better Patient Care

Staff Contact: Andrew Wheeler

The Centers for Medicare & Medicaid Services finalized a new rule allowing providers, employers and others to access data that can be used to make more informed decisions about care delivery and quality improvement. The rule allows organizations that are approved as qualified entities to confidentially share or sell analysis of Medicare and private sector claims data. CMS Chief Data Officer Niall Brennan stated, “Increasing access to analyses and data that include Medicare data will make it easier for stakeholders throughout the health care system to make smarter and more informed health care decisions.”

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TJC Releases Antimicrobial Stewardship Standards

Staff Contact: Sarah Willson

Several weeks ago, The Joint Commission announced the addition of an antimicrobial stewardship standard. The content of the standard has been released and is slated to take effect Jan. 1, 2017. This comes as the Centers for Medicare & Medicaid Services announced its plans to make such a program mandatory.

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CMS Publishes Correction To Recently Updated Fire Safety Requirements

Staff Contacts: Jackie Gatz or Sarah Willson

In yesterday’s Federal Register, The Centers for Medicare & Medicaid Services issued a correction to its recently updated fire safety standards for hospitals, which adopted the National Fire Protection Association’s 2012 Life Safety Code. The correction, effective Tuesday, July 5, states that hospital outpatient surgical departments must meet life safety code provisions applicable to ambulatory health care occupancies regardless of the number of patients served.

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CMS Announces Open Door Forums

Staff Contact: Jim Mikes

The Centers for Medicare and Medicaid Services’ Rural Health Open Door Forum is scheduled at 1 p.m. Thursday, July 7. Dial 800/837-1935 and enter passcode 1537376 to participate. CMS will address the proposed changes to the conditions of participation for hospitals and critical access hospitals to promote innovation, flexibility and improvement in patient care. CMS also will discuss the new Medicare payment system for clinical diagnostic laboratory tests based on private payor rates.

The next Skilled Nursing Facility/Long-Term Care Open Door Forum is scheduled at 1 p.m. Thursday, July 14. Dial 800/837-1935 and enter passcode 41652346 to participate. Topics include payroll-based journal reporting, value-based purchasing and the SNF waiver for the comprehensive joint replacement initiative.

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CEO Announcements

Tracy Resigns From Barnes-Jewish St. Peters Hospital And Progress West Hospital

Staff Contact: Carol Boessen

Larry Tracy, President of Barnes-Jewish St. Peters Hospital and Progress West Hospital in O’Fallon, resigned effective July 1. He accepted the President role at Memorial Hospital of South Bend in Indiana. Tracy had served as President of the two BJC HealthCare hospitals since April 2013. Lee Fetter, BJC HealthCare Group President, will serve as Interim President at both hospitals until a permanent replacement is named. A list of CEO changes is available online.

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Did You Miss An Issue Of MHA Today?

June 30, 2016
Governor To Suspend Women’s Health Program In Response To New State Laws
MLN Connects Provider eNews Available

June 29, 2016
Governor Vetoes Tort Reform Bills
CMS Releases Proposed CY 2017 Home Health Payment And Policy Update
HHS Proposes Medicare Appeals Procedures

June 28, 2016
State Extends Medicaid Managed Care RFP Deadline
CMS Issues Proposed CY 2017 Home Health Payment And Policy Update
CMS Requires EIDM System Users To Recertify Accounts
NHSN Updates 2016 Self-Paced Interactive Trainings
NHSN Posts Meeting Slides

June 27, 2016
MHA Distributes Financial Indicators Analysis
CMS Issues Proposed CY 2017 ESRD PPS Payment And Policy Update
HIDI HealthStats — Mental Health In Missouri
MHA Updates July 2016 Star Rating Hospital-Specific Reports
CMS Announces IPFQR Data Submission Period
CMS Releases Quality Reporting Checklists And HCAHPS Review And Correction Period
DHSS Posts Informational Webinar Resources

Consider This ...

Up to 1 in 20 U.S. school children may have fetal alcohol spectrum disorders.

Source: Centers for Disease Control and Prevention