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Insights

I often watch for and talk about signals. Humans have evolved to detect everything from the obvious to the subtle — from the sounds of stalking prey so we weren’t eaten by lions on the savannah to the modern equivalent in the minute facial expressions of our colleagues that signal approval or disapproval around the conference room table. Signals help us respond quickly and avoid danger.

There are a lot of signals being sent related to the federal 340B prescription drug discount program. As a Condition of Participation in the Medicaid program, the 340B law requires pharmaceutical manufacturers to sell outpatient drugs at discounted prices to qualifying providers, including community health centers and various types of hospitals. Not every hospital participates — 66 of Missouri’s 140 hospitals are 340B participants, and the hospitals are spread throughout the state.

Six of the big players in the 340B program have refused to continue 340B discounts for qualifying health care providers, including contract pharmacies. Both the Trump and Biden administration disagree with the drug manufacturers’ reading of the use of contract pharmacies and have indicated that the discounts should apply under the 340B law. However, there’s a lot of money at stake. The manufacturers are arguing that the federal government doesn’t have authority to enforce its position, and the issue likely will be resolved through litigation.

Attacks by drugmakers on the program are not particularly new. This most recent action follows previous claims of fraud and mismanagement, and demands for excessive and unrealistic reporting by 340B providers to discourage participation and cast doubts on the program.

The big drugmakers aren’t the only threat. The MO HealthNet Division is moving toward reducing the amounts it pays for 340B drugs to “actual acquisition cost” on Thursday, July 1. At the same time, it is moving to enforce payment limits on physician-administered drugs that are administered by hospitals in outpatient settings. Despite our advocacy efforts spearheaded by a group of nearly 30 hospital pharmacists, MHD is pursuing emergency rulemaking to implement the change. It potentially could cost hospitals $20 million annually.

There’s another threat — reduced utilization during COVID-19. Low-income patients used hospital services less during the pandemic and could jeopardize hospitals’ ability to participate in the 340B program without specific action by Congress to adjust for the change.

So, what is the signal?

Pharmacy is a growing cost in health care. However, it is increasingly clear that pharmaceutical manufacturers, and now the state’s Medicaid program, are less and less willing to share the burden of these costs.

The safety net can’t be built exclusively on cost-shifting. As with debates on Medicaid expansion and the Federal Reimbursement Allowance, hospitals are willing to be a partner in improving access to care. We cannot bear this burden alone.

The signals are clear: Big pharma’s strategy is profit growth on low-income patients and MHD’s is mere expenditure reduction. Neither strategy produces value — they simply shift costs to other payers to the detriment of the 340B pharmacy program and to our state’s health care safety net.

Let me know what you think.

Herb B. Kuhn
MHA President and CEO

In This Issue

MHA Distributes Analysis Of The Proposed FFY 2022 LTCH PPS
UnitedHealthcare Will Implement Emergency Visit Assessment Attestation In Most States
MLN Connects Provider eNews Available
SAMHSA Releases Supplemental Research Bulletin On Preliminary Effects Of COVID-19 Pandemic
CMS Reminds Hospitals Of HCAHPS Submission Deadline
CORH Opens Application Portal For Vulnerable Rural Hospital Assistance Program

Regulatory

MHA Distributes Analysis Of The Proposed FFY 2022 LTCH PPS

Staff Contact: Andrew Wheeler

MHA released a summary and analysis of the federal fiscal year 2022 Medicare proposed Long-Term Care Hospital Prospective Payment System update. Hospitals have until Monday, June 28, to review their hospital-specific data and submit comments to the Centers for Medicare & Medicaid Services. The analysis includes financial effects of market basket updates, market basket reductions mandated by the Affordable Care Act, budget neutrality adjustments, wage index updates, MS-LTC-DRG updates and changes to site-neutral payment reductions. Results are illustrated in national, Missouri, health system and individual hospital groupings. In aggregate, the state will see an estimated increase of 3.6% for services paid under the LTCH PPS. Although footnoted, the effects of the Medicare sequestration are not included. The analysis is available online for authorized users of HIDI Analytic Advantage.

UnitedHealthcare Will Implement Emergency Visit Assessment Attestation In Most States

Staff Contact: Andrew Wheeler

UnitedHealthcare announced its intent to enhance its “capabilities to assess emergency department facility commercial claims to determine if the ED event was emergent or nonemergent.” UHC will implement the program in most states to the fully insured market. If the patient encounter is determined to be nonemergent, the benefits will be reduced or eliminated for the encounter, as directed by the member’s certificate of coverage. If an ED visit is determined to be nonemergent, providers will have the opportunity to complete an attestation if the visit met the prudent layperson standard. The new policy is effective Thursday, July 1.

MLN Connects Provider eNews Available

Staff Contact: Andrew Wheeler

The Centers for Medicare & Medicaid Services issued 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.

- Medicare Administrative Contractors resume medical review on a post-payment basis
- Clinical diagnostic laboratories
  - Key dates for new & reconsidered test codes
  - Private payer rate-based Clinical Laboratory Fee Schedule resources
- Medicare Shared Savings Program: submit notice of intent to apply by Monday, June 7

COVID-19 Updates

SAMHSA Releases Supplemental Research Bulletin On Preliminary Effects Of COVID-19 Pandemic

Staff Contact: Kelsey Hussey or Shawn Billings

The Substance Abuse and Mental Health Services Administration released a Supplemental Research Bulletin, “A Preliminary Look at Effects of the COVID-19 Pandemic.” This edition reviews research through November 2020 on how the COVID-19 pandemic has affected U.S. mental health and substance use. It also presents research on populations experiencing greater impacts, including youth, women, health workers, and racial and ethnic minorities.

The pandemic continues to inflict unprecedented changes on areas of life, including geographic, social and spiritual communities; education and work; health care; leisure activities; entertainment; and travel. Research suggests these changes will affect coping and resilience. The bulletin concludes with suggestions from experts for supporting communities over time and improving systems of care.

Quality & Population Health

CMS Reminds Hospitals Of HCAHPS Submission Deadline

Staff Contact: Sherry Buschjost

The submission deadline for the Hospital Consumer Assessment of Healthcare Providers and Systems patient perspectives on care survey data for first quarter 2021 discharges (Jan. 1 – March 31) is Wednesday, June 30. The Centers for Medicare & Medicaid Services encourages all hospitals, whether they self-administer the HCAHPS survey or use a vendor, to submit data well before the deadline to allow time to address any submission issues. The review and correction period is July 1‑7, during which participating hospitals and survey vendors may access and review the HCAHPS data review and correction report. Errors in data accepted into the warehouse by the June 30 deadline can be corrected; however, new data are not accepted during the review and correction period.

Noteworthy

CORH Opens Application Portal For Vulnerable Rural Hospital Assistance Program

Staff Contact: Dana Dahl

The Center for Optimizing Rural Health opened its application portal for the Vulnerable Rural Hospital Assistance Program. The Health Resources and Services Administration-funded program is open to all rural and critical access hospitals in the U.S. The application portal is open until Saturday, July 31, and selected hospitals will be notified in August 2021. Additional details and FAQs are available.

MHA Today | June 4, 2021

MHA Today is provided as a service to members of the Missouri Hospital Association.

Insights

In This Issue