On June 20, 2017, CMS is hosting a Special Open Door Forum conference call to discuss implementation of the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act). According to a CMS announcement, the call will cover the goals of the IMPACT Act, RAND contract activities (including upcoming national testing), and identify opportunities

CMS has scheduled a September 15, 2016 Special Open Door Forum call on the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act). This call will provide an overview of the IMPACT Act’s requirement for standardization of patient assessment data across post-acute care settings, and solicit input on the ways the IMPACT Act can

On August 5, 2016, CMS is publishing its final rule to update Medicare prospective payment system (PPS) rates for inpatient rehabilitation facilities (IRFs) for FY 2017, which begins October 1, 2016. CMS estimates that payments to IRFs will increase by 1.9% overall ($145 million) in FY 2017 compared to FY 2016 levels based on all policies and updates in the final rule.  Specifically, CMS finalized a 1.65% increase factor, derived from a 2.7% IRF-specific market basket update that is reduced by a 0.3 percentage point multi-factor productivity adjustment and an additional 0.75 percentage point reduction required by the Affordable Care Act.  Rates will be further increased by approximately 0.3 percentage points due to an update to the outlier threshold.  Note that an IRF that does not submit required quality data to CMS under the IRF Quality Reporting Program (QRP) is subject to a 2.0 percentage point decrease in its annual update.
Continue Reading CMS Finalizes Medicare IRF PPS Update for FY 2017

CMS has published its final rule to update Medicare skilled nursing facility (SNF) PPS rates and policies for FY 2017. CMS projects that the final rule will increase overall payments to SNFs by $920 million, or 2.4%, compared to FY 2016 levels (and compared to the $800 million/2.1% increase forecast in the proposed rule). The final update is based on a 2.7% market basket increase that is reduced by a 0.3 percentage point multifactor productivity adjustment.
Continue Reading CMS Adopts Final SNF PPS Rates and Policies for FY 2017

The House Ways and Means Committee has approved an amended version of H.R. 5273, the “Helping Hospitals Improve Patient Care Act of 2016.”  While most of the provisions address Medicare payment policies pertaining to hospitals (including long term care hospitals (LTCHs) and hospital outpatient departments), certain other reimbursement policies, including Medicare Advantage and physician payment

CMS has published its proposed rule to update Medicare skilled nursing facility (SNF) PPS rates and policies for FY 2017. CMS projects that the proposed rule would increase overall payments to SNFs by $800 million, or 2.1%, compared to FY 2016 levels. This projected update is based on a proposed 2.6% market basket increase that would be reduced by a 0.5 percentage multifactor productivity adjustment. CMS does not propose making a forecast error correction for FY 2017, since the difference between its FY 2015 estimated market basket index increase (2.5 percentage points) and the actual change in the market basket (2.3 percentage points) did not exceed the 0.5 percentage point threshold to trigger an adjustment.
Continue Reading CMS Releases Proposed Rule to Update SNF PPS Rates and Policies for FY 2017

On May 12, 2016, CMS will host a conference call on “Understanding the IMPACT Act-Patient and Family Focused for Informed Decision Making.” The call is intended to allow patients, families, caregivers, advocacy groups, and other consumers to ask questions regarding the Improving Medicare Post-Acute Care Transformation Act (IMPACT Act) and standardizing the assessment

On April 14, 2016, CMS will host a call on the “Data Element Library” that will facilitate exchange and use of post-acute care assessment data under the Improving Medicare Post-Acute Care Transformation (IMPACT) Act. The CMS call will provide an overview of the Data Element Library, discuss the type of information that could be publicly

On February 4, 2016, CMS is hosting a provider call on Improving Medicare Post-Acute Care Transformation (IMPACT) Act requirements regarding the reporting of standardized patient assessment data by post-acute care (PAC) providers (skilled nursing facilities, home health agencies, inpatient rehabilitation facilities, and long-term care hospitals). During this call, CMS and the Office of the National

CMS published its final CY 2016 Medicare Home Health Prospective Payment System (PPS) rule on November 5, 2015.  CMS projects that overall Medicare payments to home health agencies (HHAs) will be reduced by 1.4% — or $260 million – in CY 2016 compared to 2015 levels as a result of the policies finalized in the rule. The final 2016 home health payment update is 1.9%, reflecting a 2.3% home health market basket update that is reduced by a 0.4% multifactor productivity adjustment. This update is offset, however, by: (i) a 0.97% reduction to account for estimated case-mix growth unrelated to increases in patient acuity (this “nominal case-mix growth” adjustment also will be applied in CYs 2017 and 2018), and (ii) a -2.4% rebasing adjustment (the third year of a four-year phase-in). The final CY 2016 national, standardized 60-day episode payment rate is $2,965.12; the rate for an HHA that does not submit required quality data is reduced by 2 percentage points to $2,906.92. 
Continue Reading Medicare Home Health PPS Payments to Fall by $260 Million in 2016

Today the Centers for Medicare & Medicaid Services (CMS) published a proposed rule that would modify the discharge planning conditions of participation (COPs) for hospitals, including long-term care hospitals and inpatient rehabilitation facilities, critical access hospitals, and home health agencies (HHAs). The proposed rule would implement the discharge planning requirements of the Improving Medicare Post-Acute Care Transformation Act of 2014 (IMPACT Act).  The proposed changes are designed to promote “consumer-centered health care” by requiring the affected provider types to, among other things, solicit patient input with respect to discharge planning, and to share information among relevant parties, including the patents/caregivers, the physician, and the post-acute provider to whom the patient is discharged if applicable.
Continue Reading CMS Publishes Proposed Rule on Hospital/HHA Discharge Planning Requirements

On October 21, 2015, CMS is hosting a provider call to discuss the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014.  The call will cover:

  • Legislative requirements of the IMPACT Act related to the use of standardized data, quality measures, and resource use and other measures for skilled nursing facilities, inpatient rehabilitation facilities, long-term

On August 6, 2015, CMS published its final rule to update Medicare PPS rates for inpatient rehabilitation facilities for FY 2016, which begins October 1, 2015.  CMS estimates that rates will increase by 1.8% overall ($135 million) under the final rule compared to FY 2015 levels.  This increase reflects a 2.4% market basket update (using a new IRF-specific market basket) that is reduced by a 0.5 percentage point multi-factor productivity adjustment and an additional 0.2 percentage point reduction required by the Affordable Care Act, with an additional 0.1% decrease resulting from an update to the outlier threshold.  The standard payment conversion factor for discharges for FY 2016 will be $15,478, compared to the FY 2015 conversion factor of $15,198. In this final rule CMS adopts for the first time a IRF-specific market basket to replace the 2008-based market basket for rehabilitation, psychiatric, and long-term care facilities.
Continue Reading CMS Finalizes Medicare IRF PPS Rates/Policies for FY 2016

On August 4, 2015, CMS published its final rule updating Medicare skilled nursing facility (SNF) PPS rates and policies for FY 2016.  CMS projects that the final rule will increase overall payments to SNFs by $430 million, or 1.2%, as compared to FY 2015 levels.  This update reflects a 2.3% market basket increase that is reduced by a 0.6 percentage point market basket forecast error adjustment and a 0.5 percentage point multifactor productivity adjustment.
Continue Reading CMS Publishes Final FY 2016 Update to SNF PPS Rates, Policies

CMS has released its proposed calendar year (CY) 2016 Medicare home health prospective payment system (HH PPS) update, which CMS estimates would reduce overall Medicare payments to home health agencies (HHAs) by $350 million in 2016, compared with 2015 levels. This decrease reflects a 2.3% home health payment update percentage (derived from a 2.9% market basket update minus a 0.6% multifactor productivity adjustment), that is more than offset by (i) a 1.72% proposed reduction to account for nominal case-mix coding intensity growth, and (ii) a -2.5% rebasing adjustment (the third year of a four-year phase-in). The proposed CY 2016 national, standardized 60-day episode payment rate would be $2,938.37; the rate for an HHA that does not submit the required quality data would be reduced by 2 percentage points to $2,880.92. The proposed rule also would recalibrate HH PPS case-mix weights and update the CY 2016 home health wage index. CMS also is proposing to establish a new Home Health Value-Based Purchasing (HHVBP) Model, which is intended to shift from volume-based payments to a framework that promotes the delivery of higher quality care to Medicare beneficiaries. Under this proposal, CMS would randomly select nine states representing each geographic area in the nation (the states initially selected under this methodology are Massachusetts, Maryland, North Carolina, Florida, Washington, Arizona, Iowa, Nebraska, and Tennessee – but this is subject to change in the final rule). All Medicare-certified HHAs delivering services within those states would be required to compete for payment adjustments based on quality performance (both achievement and improvement). CMS explains that it is proposing to mandate participation by HHAs in the selected states because “in our experience, Medicare-providers are generally reluctant to participate voluntarily in models in which their Medicare payments could be subject to possible reduction,” which in turn causes self-selection bias in statistical assessments that may present challenges in evaluating the model. The baseline year for the new program would be 2015, and the first performance year would be 2016. The maximum quality-based payment adjustment (upward or downward) would be 5% in each of the first two payment adjustment years (2018 and 2019), 6% in the third payment adjustment year (2020), and 8% in the fourth and fifth years (2021 and 2022). The proposed rule includes a detailed discussion of the initial set of proposed HHVBP measures, which encompass both process and outcome measures, and the scoring/payment adjustment methodology. There would be no aggregate increase or decrease in payments to HHAs competing in the model, but CMS projects an estimated $380 million in total savings from CY 2018 through 2022 attributable to a reduction in unnecessary hospitalizations and skilled nursing facility usage as a result of these home health quality improvements. CMS invites comments on the elements of the proposed HHVBP Model.
Continue Reading CMS Proposed Medicare Home Health PPS Rule Would Reduce HHA Payments by $350 Million in 2016