MHA Today | October 5, 2018

October 5, 2018
MHA Today: News for Healthcare Leaders

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MHA Today is provided as a service to members of the Missouri Hospital Association. Additional information is available online at MHAnet.


Herb Kuhn, MHA President & CEO Last week’s column explored opportunities to identify and document social determinants of health through the transition to ICD-10 and expanded coding for SDOH. There’s another aspect of better care, health improvement and efficiency that is worth expounding on — the influence of the physician self-referral law, commonly known as the Stark Law, in care coordination.

In late August, MHA responded to a request from the Centers for Medicare & Medicaid Services to articulate concerns about the Stark Law. Our response outlined the law’s impediments to building a value-focused health care system through the law’s limits on hospital and physician collaboration, and innovation designed to improve patient care while reducing costs.

The original CMS response pre-dates the research on SDOH discussed last week. To help complete the picture, we sent an additional letter outlining how the Stark Law and the Anti-Kickback Statute pose barriers to improved care coordination for individuals with social complexity. Neither Stark nor the AKS provisions were created to align care. In fact, it’s safe to say that they had a nearly opposite goal. However, the movement toward better care coordination and risk sharing requires greater physician and hospital integration. ICD-10 has opened new opportunities to evaluate a patient’s social complexity, understand its influence on care and recovery, and mitigate the risks through better care coordination and health management.

As the system exists, federal policies incent coordination through value-based payment and risk sharing on one side, while creating barriers to integration on the other. Although there historically have been very good reasons to have protections, such as those presented in Stark and the AKS, there are now very good reasons to evaluate where those provisions need review. The incentives for volume and those for value-based reimbursement are very different. We are glad CMS is undertaking this review of the regulations that underpin these laws.

Hospitals are assuming greater responsibility for patients’ social complexity that aren’t related to clinical excellence – these exist regardless of care and cannot be solved by traditional health care interventions. At the same time, there are no funding mechanisms in place to support this assumption of risk. The new coding depth is helping understand the scope of the SDOH problem. Then, aligning incentives and removing outdated regulatory barriers to allow more effective stakeholder integration will be required to fully address socially complex patients.

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Tuesday, the American College of Emergency Physicians released new data on the incidence of violence in the nation’s emergency departments. The research pointed to exactly the type of problem the MHA board identified in 2017 and that MHA has been working to address through its S.A.F.E.R. initiative.

According to the ACEP report, 47 percent of emergency physicians report having been physically assaulted, with 60 percent of assaulted physicians saying the assault occurred within the past year. Nearly 80 percent of physicians indicate the violence is influencing patient care. Hospital violence isn’t limited to physicians or the ED. In MHA’s surveys, more than half of hospitals identify violence and violent behavior as a top-three internal threat. Statistically, health care workers are four times more likely to be victims of workplace violence than workers in other industries, according to the U.S. Bureau of Labor Statistics.

There’s clearly a cultural problem driving hospital violence. However, MHA is taking positive steps to support hospitals through policy solutions, partnerships and evidence-based practice changes. MHA staff toured the state to understand the problem and identify solutions. The conflict between worker and patient safety, governed by different rules and administrative agencies, was clearly identified. We’re advocating for change. Just last week, Congress adopted and President Trump signed into law an MHA-supported initiative, championed by Sen. Roy Blunt, to bring the Department of Labor and CMS together to develop new initiatives to protect health care workers.

Better relationships with law enforcement are essential. MHA and member hospitals have been working with the Missouri Department of Public Safety to increase mutual understanding between hospitals and law enforcement officers and agencies. Partnering with state agencies has fostered more regional training and refinement to current policies and guidance documents.

Finally, MHA is working to identify and share best practices for patient and workforce safety, including joint training with emergency medical personnel and law enforcement on de-escalation tactics. The ACEP research underscores that the problem is widespread and potentially growing. Violence in hospitals has significant implications for the hospital workforce and improved patient care. It is never appropriate to harm a caregiver, and cultural change will be necessary to reduce the harm caused by this physical and verbal violence.

As I discuss this issue with others who don’t work in health care, I share the example of driving through a construction zone. The signage is clear – if you hit a highway worker, you are at risk of a significant fine and the loss of your license. There is no equivocation. Why? Because we want people to slow down so we can protect these individuals when they are doing their job. My message to others is simple – we need that same kind of understanding and need for protection for those who work every day to provide relief when someone is injured or ill.

Fostering safe environments to give and receive quality care is important. We’ve made progress, but more needs to be done.

Let me know what you think.

Herb Kuhn, MHA President & CEO

Herb B. Kuhn
MHA President and CEO

In This Issue
Federal Funding Streams Focus Of MHA Advocacy
CMS Strengthens Oversight Of Accrediting Organizations
DEA’s Prescription Drug Take Back Day Partner Toolkit Is Live
TJC Announces ORYX Reporting Requirements Webinar
Christie Dempsey Named To AONE Board

state and federal health policy developments

Federal Funding Streams Focus Of MHA Advocacy

Staff Contact: Brian Kinkade

MHA is aggressively advocating that the state pursue two federal funding opportunities of significant interest to hospitals. The first would provide 90 percent federal matching funds for hospital investments in health information technology. This funding stream could leverage the investment in MHA’s Enterprise ADT Solution by providing funds for the development, testing and implementation of alerting and analytics tools, and for connection costs to establish or expand health information network capacity. Last week, MHA and the state signed a memorandum of understanding wherein the state has agreed to file the application for funding that MHA develops. The MOU greatly increases the chance of the project moving forward in a timely manner. Second, MHA is encouraging the state to include Institutions of Mental Disease services for persons with opioid use disorder in the MO HealthNet benefit package. The opioid legislation that was passed by Congress includes a provision that gives states the option of providing 30 days of IMD care for adults ages 21-64 under their Medicaid programs. MHA has been encouraging the state to pursue IMD coverage for OUD since the Trump administration signaled its support for such projects last winter. The congressional action means states can now pursue the coverage option without the administrative burden associated with Medicaid waivers.

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Regulatory News
the latest actions of agencies monitoring health care

CMS Strengthens Oversight Of Accrediting Organizations

Staff Contact: Sarah Willson

The Centers for Medicare & Medicaid Services announced in a news release significant changes regarding its oversight of Accrediting Organizations like The Joint Commission, DNV and others. Three primary changes being made include the public posting of AO performance data, a redesigned process for AO validation surveys and the release of the Annual Report to Congress. The 130-page FY 2017 Report to Congress is posted online.

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Quality and Population Health

DEA’s Prescription Drug Take Back Day Partner Toolkit Is Live

Staff Contact: Shawn Billings

The Drug Enforcement Administration has published a digital toolkit of resources to promote the upcoming National Prescription Drug Take-Back Day on Saturday, Oct. 27. The website provides access to a variety of materials, including posters, pamphlets, ads, billboards, and social media art pre-sized for Twitter, Facebook, and Instagram.

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TJC Announces ORYX Reporting Requirements Webinar

Staff Contact: Sherry Buschjost

The Joint Commission will provide key updates to the 2019 ORYX performance measure reporting requirements in a webinar scheduled at 11 a.m. Tuesday, Oct. 23. Additional information, including a registration link, is available.

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Christie Dempsey Named To AONE Board

Staff Contact: Sarah Willson

The American Organization of Nurse Executives membership elected Christina Dempsey, MSN, R.N., senior vice president and chief nursing officer, Press Ganey Associates, Inc., Springfield, Mo., as the new Region 6 board representative. Dempsey currently serves as the Nurse Industry Executive Leader on the Missouri Organization of Nurse Leaders board, a personal membership group of MHA. AONE is a subsidiary of the American Hospital Association.

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Did You Miss An Issue Of MHA Today?

October 1, 2018
GAO Reports On Number And Characteristics Of Rural Hospital Closures
October Is National Cybersecurity Awareness Month

October 2, 2018
MHA Submits Comments Opposing Medicaid Regulation To Cut Drug Payments
Medicaid Obesity Treatment Regulation Draws Comment

October 3, 2018
CMS Releases 2Q2018 IQR And OQR Submission Resources
CMS Updates Inpatient And Outpatient CART

October 4, 2018
Congress Enacts Opioid Legislation
MHA Distributes Analysis Of Final Medicare Inpatient PPS For FFY 2019
CMS Changes Medicare Integrity Manual For Local Coverage Determinations
MLN Connects Provider eNews Available
CMS Provides Claims Detail Reports For OP-35 and OP-36
2019 Reporting Period eCQM Flows Available
Trustee Orientation Manual Template Available

Consider This ...

October is Breast Cancer Awareness Month. Breast cancer is the most commonly diagnosed cancer in women – One in eight women in the United States will be diagnosed with breast cancer in their lifetime.

Source: National Breast Cancer Foundation, Inc.