IHA Daily Briefing: Sept. 5

Thursday, September 5, 2019
IDPH Seeks Timely Reporting of Fetal, Infant Deaths
CMS Issues Rule to Reduce Fraud in Programs
AHA Releases Hospital Merger Benefits Report
Briefly Noted

IDPH Seeks Timely Reporting of Fetal, Infant Deaths
The Illinois Department of Public Health (IDPH) is asking for hospital assistance in the timely reporting of fetal and infant deaths, as well as the appropriate disposition of fetal and infant remains. All birth and death records must be registered with the Local Registrar within seven days of the occurrence without exception.

Hospitals play an important role in ensuring that timeframe is met. Failure to adhere to these timeframes slows down and creates inaccuracies in other federal and state mandated reporting putting, amongst other things, funding for disease management programs at risk.

Reporting requirements vary depending on certain factors such as gestational age, live birth and wishes of the mother. Hospitals should review their policies to ensure they are consistent with state law. To assist hospitals, IDPH has developed the following chart that outlines what hospitals must do under certain circumstances.

Hospitals with questions about specific cases should contact IDPH’s Division of Vital Records at dph.vitals@illinois.gov or 800-237-1945.

CMS Issues Rule to Reduce Fraud in Programs
The Centers for Medicare & Medicaid Services (CMS) today issued a final rule (with comment period), developed to stop fraud by keeping unscrupulous providers out of Medicare, Medicaid and Children's Health Insurance Program (CHIP). CMS says the final rule, Program Integrity Enhancements to the Provider Enrollment Process, creates several new revocation and denial authorities to bolster its efforts to stop waste, fraud and abuse. The rule allows CMS to identify individuals and organizations that pose an undue risk of fraud, waste or abuse, based on their relationships with other previously sanctioned entities.

According to a CMS press release, the rule also includes other authorities that will improve CMS’ fraud-fighting capabilities. Similar to the affiliations component, these authorities provide a basis for administrative action to revoke or deny, as applicable, Medicare enrollment if:

  • A provider or supplier circumvents program rules by coming back into the program, or attempting to come back in, under a different name (e.g. the provider attempts to “reinvent” itself);
  • A provider or supplier bills for services/items from non-compliant locations;
  • A provider or supplier exhibits a pattern or practice of abusive ordering or certifying of Medicare Part A or Part B items, services or drugs; or
  • A provider or supplier has an outstanding debt to CMS from an overpayment that was referred to the Treasury Department.

CMS says the new rule also gives the agency the ability to prevent applicants from enrolling in the program for up to three years if a provider or supplier is found to have submitted false or misleading information in its initial enrollment application and it can now block providers and suppliers who are revoked from re-entering the Medicare program for up to 10 years.

Comments are due to CMS by Nov. 4, 2019.

AHA Releases Hospital Merger Benefits Report
Yesterday, AHA released a report—Hospital Merger Benefits: Views from Hospital Leaders and Econometric Analysis - An Update—with findings that confirm the significant value hospital mergers can generate for patients and their communities. The updated report reinforce and strengthen the 2017 report which concluded that hospital mergers result in benefits that accrue to patients in the form of better care and reduced costs.

Key report findings show that:

  • Mergers decrease costs. Due to increased scale, acquisitions decrease costs and are associated with a statistically significant 2.3% reduction in annual operating expenses;  
  • Mergers often facilitate quality improvement through updating clinical operations across a health system, implementing consistent best practices and enhancing the promise of technology and data analytics; and
  • Revenues per admission at acquired hospitals decline  by a statistically significant 3.5% relative to non-merging hospitals, which suggests that "savings that accrue to merging hospitals are passed on to patients and their health plans."

The report includes findings from structured interviews with 10 health systems, which identified a number of areas in which mergers and acquisitions have eased cost pressures and expanded access. The update also supplements previous econometric analysis with data on cost, quality and revenue measures for hospital transactions from 2015 to 2017.

AHA says the newest analysis demonstrates that mergers can lead to enhanced quality through the expansion of clinical best practices, as evidenced by statistically significant declines in the rates of readmission and mortality rates following mergers. The study highlights how scale is increasingly critical to maintain and enhance the infrastructure necessary to address social determinants of health, adopt population health strategies and promote value-driven care.

In addition, integration can ensure that local access to care and breadth of services are maintained for patients, and in some cases expanded. Mergers can offer financial stability for struggling hospitals through operational efficiencies associated with shared costs for expensive IT infrastructures and purchasing, access to a robust network of system resources, equipment and facility upgrades. Newly integrated systems are also able to provide patients with access across the full continuum of care. This leads to more regular and convenient access to physicians, including specialists.     

Briefly Noted
IHA has updated its “Overview of General Assembly’s Spring 2019 Session” to include numerous healthcare-related bills signed by the Governor over the past few months.

The Illinois Dept. of Healthcare and Family Services has issued several notices in July and August that may impact hospitals.  See IHA’s memo for a comprehensive list of notices and links for more information.