IHA Daily Briefing: Oct. 5

IHA Advocacy Alert on OPPS Site-Neutral Cuts
Wilhelmi on Panel Seeking Solutions to State's Challenges
New Requirement to Post Charges Starts Jan. 1
CMS Issues Medicare IPPS Final Rule Correction
CMS Revises Policies on LCDs
Briefly Noted

IHA Advocacy Alert on OPPS Site-Neutral Cuts
U.S. Representatives Peter Roskam (R-6) of Illinois, chair of the House Ways and Means Health Subcommittee, and Mike Thompson (D) of California, are asking their House colleagues to sign a letter to the Centers for Medicare & Medicaid Services (CMS) to reconsider proposals to cut payments for evaluation and management services and expand certain site-neutral payment policies to grandfathered off-campus hospital provider-based departments. AHA estimates that implementation of these proposals would cut hospital payments under the Outpatient Prospective Payment System (OPPS) by $760 million in calendar year 2019 ($29 million for Illinois hospitals).

IHA is urging members to contact your U.S. Representative now and ask him/her to sign the House letter to CMS on OPPS site-neutral cuts. To call or send an email message to your U.S. Representative, click here.

The deadline for Representatives to sign the Roskam-Thompson letter is Oct. 10. Background and talking points can be found here.

Wilhelmi on Panel Seeking Solutions to State’s Challenges
IHA President and CEO A.J. Wilhelmi was part of a lively, wide ranging panel discussion, “Election 2018: Seeking Solutions,” held earlier this week (Oct. 2) at the Union League Club in Chicago. The event was the 11th and final event in a statewide series of NPR Illinois/AARP forums and was broadcast live on NPR Illinois and Facebook.

Panelists discussed the major issues of the 2018 election: the state’s fiscal challenges, including the state’s $130 billion pension liability - education, and healthcare, and a recently released AARP poll of Illinois voters. Nearly half of those polled said they have considered leaving the state in the past year, and two-thirds said they are angry or extremely angry about the state’s fiscal issues.

Other panelists included: Edwin Eisendrath, CEO, Chicago Sun-Times; Zaldwaynaka “Z” Scott, President, Chicago State University; Rosanna Marquez, AARP Illinois State President; and Joseph Mancino, Mayor of the Village of Hawthorn Woods and Chairman of the Metropolitan Mayors Caucus.

Wilhelmi noted that businesses look for predictability and stability in the state budget and government, so while the budget process has been difficult, it is encouraging that two consecutive budgets have been approved in 2017 and 2018, following the state’s record-long two-year impasse.

Wilhelmi said that people may not be aware that Medicaid is a joint state-federal partnership with federal matching funds, so reducing Medicaid – with the loss of federal funds – is not an efficient way to cut. He also pointed out that Illinois hospitals have sustained more than $1 billion in state Medicaid cuts and more than $5 billion in federal Medicare cuts since 2010 and cautioned that further cuts would hurt patients.

Each of the panelists was asked what advice they would give the next Governor. Wilhelmi said, “Listen to the people, shoot straight and be honest, find common ground…there are significant challenges, but we can solve them.”

To view or listen to a replay of the hour-long forum, click here.

New Requirement to Post Charges Starts Jan. 1
Effective Jan. 1, 2019, all hospitals must post their "standard charges" in a "machine readable format" on the internet and update it at least annually. The Center for Medicare & Medicaid Services' (CMS’) Medicare Inpatient Prospective Payment System final rule (see page 41686) included updated requirements to make public a list of standard charges for hospital compliance.

In response to numerous questions raised by hospitals, CMS has issued a Frequently Asked Questions. However, CMS does not directly answer the important question many states have asked as to whether compliance could include reference to a statewide website of average bundled charges for the most frequently requested services, similar to the Illinois Hospital Report Card Act website that already provides hospital-specific average charges for more than 50 services. CMS' response is that participation in an online state price transparency initiative does not exempt a hospital from the requirements.

Read IHA’s memo for more details.

CMS Issues Medicare IPPS Final Rule Correction
The Centers for Medicare & Medicaid Services (CMS) issued a Correction Notice on Wednesday, addressing certain provisions included in the Medicare Inpatient Prospective Payment System (IPPS) FFY 2019 final rule. A summary of these corrections is available on IHA’s website. Because the impact of these changes is relatively minor, IHA will not be re-issuing the final 2019 hospital-specific, IPPS impact reports that you were sent during the week of Sept. 17. IHA will communicate to you if there are any additional corrections on other provider payments for 2019 from CMS.

CMS Revises Policies on LCDs
On Wednesday, the Centers for Medicare & Medicaid Services (CMS) revised its Medicare Program Integrity Manual which addresses Medicare Administrative Contractors (MACs) Local Coverage Decisions (LCDs) processes. Among the revisions contained in the New Coverage Rules are:

  • A step-by-step description of the LCD process;
  • Clinical evidence supporting LCD decisions, including rationale;
  • Informal meetings with MACs;
  • New LCDs request process;
  • Restructured and re-purposed Carrier Advisory Committee meetings, including the addition of other clinicians besides physicians (e.g., nurses) eligible to participate in the group. IHA has been both a member of and participant in this group’s meetings (usually held three times a year) for the past several years;
  • Retirement of proposed policies older than one year if not finalized within that time;
  • Better communication; and
  • An LCD reconsideration process, consistent with the National Coverage Decisions reconsideration process.

Last month, the U.S. House passed H.R. 3635, the Local Coverage Clarification Determinations Act of 2018, which includes several of those provisions CMS has included in the Program Integrity Manual. That bill is currently under review in the Senate.

Briefly Noted
The U.S. Bureau of Labor released its September employment report showing 134,000 jobs were added for the month. Healthcare added 26,000 jobs in September with hospitals accounting for 12,000 of those jobs. Over the year, healthcare employment has increased by 302,000. The unemployment rate nationwide was 3.7 percent, the lowest since 1969.