CMS Announces System to Collect Hospice Care Data Beginning July 1, 2014

On April 8, 2014, CMS published a notice announcing that it is establishing a new “system of records” to collect data to support the Hospice Quality Reporting Program. The new “Hospice Item Set” (HIS) is a standardized mechanism for abstracting data from a patient’s medical record to confirm that the appropriate assessments were made and concerns were addressed for the following domains of care: (1) Pain; (2) Respiratory Status; (3) Medications; (4) Patient Preferences; and (5) Beliefs & Values. The notice is effective on May 8, 2014, and comments will be accepted until that date. Beginning July 1, 2014, hospices will be required to submit two HIS records for each patient admitted to their organization: an HIS-Admission record and an HIS-Discharge record. 

FTC Workshop on Health Care Competition (March 20-21)

The Federal Trade Commission (FTC) has scheduled a workshop on March 20-21, 2014 to examine developments in the U.S. health care industry, including those related to implementation of health care reform legislation and other trends related to cost, quality, access, and care coordination. Specifically, the workshop will address the following five topics:

  1. Professional Regulation of Health Care Providers -- how accreditation, credentialing, licensure, and scope of practice rules may affect competition and consumers.
  2. Innovations in Health Care Delivery -- including retail clinics and telemedicine that may offer significant cost savings while maintaining or improving quality of care and expanding consumer access to care.
  3. Advancements in Health Care Technology – implications of technology such as electronic health care records, health data exchanges, technology platforms for health care payers and providers, and certain other consumer-oriented technological advances.
  4. Measuring and Assessing Quality of Health Care – how developments in measuring and assessing health quality may impact competition and health care choices.
  5. Price Transparency of Health Care Services – how improved price transparency impacts costs to consumers and its potential to facilitate price coordination among health care providers.

CMS to Host "Physician Compare Town Hall Meeting" (Feb. 24)

On February 24, 2014, CMS is hosting a town hall meeting to discuss the future of the Physician Compare website and how to improve the information presented to consumers. For instance, CMS is seeking feedback on additional measures that might help consumers identify quality care, and measures to accurately and completely represent the various Medicare specialties. CMS is also considering including additional information such as Board Certification and other medical qualifications.  Related resources are posted on the CMS website.  CMS is accepting written comments on this topic until March 3, 2014.

CMS Call: ESRD Quality Incentive Program Payments (Jan. 15)

A January 15, 2015 CMS call will focus on the 2016 Medicare End-Stage Renal Disease (ESRD) Quality Incentive Program (QIP). Among other things, the call will cover the final measures, standards, scoring methodology, and payment reduction scale that are applied to the payment year 2016 program.

Medicare Home Health PPS Rates Cut 1.05% Under Final 2014 Rule

Under the final Medicare home health PPS (HH PPS) rule released on November 22, 2013, payments in 2014 will be cut by 1.05% (about $200 million) compared to 2013 levels (and compared to a -1.5% cut forecast in the proposed rule). This reduction reflects a 2.3% home health payment update, which is more than offset by a -0.62% ICD–9 grouper refinement and a -2.73% ACA-mandated rebasing adjustment to the national, standardized 60-day episode payment rate and other applicable payment amounts. The ACA rebasing adjustment is intended to reflect factors such as changes in the number of visits, the mix of services, the level of intensity, and the average cost of providing care in an episode.

CMS estimates that the difference between the 2013 average payment per episode and the average cost per episode is 13.09%; CMS is recouping this difference over four years (from CY 2014 to CY 2017). The final rule also revises the Home Health Quality Reporting Program, including adding quality measures relating to hospital readmissions and Emergency Department visits with the first 30 days of a home health stay; CMS will begin reporting feedback to HHAs on performance on these measures in CY 2014, and they will be added to Home Health Compare for public reporting in CY 2015. On the other hand, the final rule reduces the number of process measures reported on the certification and survey provider enhanced reports (CASPER) by eliminating the stratification by episode length for nine process measures. The rule also clarifies cost allocation of home health agency survey expenses; for that portion of costs attributable to Medicare and Medicaid, CMS will assign 50% to Medicare and 50% to Medicaid. The official version of the rule will be published in the Federal Register on December 2, 2013.  

CMS Call on IRF Quality Reporting Requirements (Nov. 14)

On November 14, 2013, CMS is hosting a call on ACA quality reporting program requirements for inpatient rehabilitation facilities.  According to the CMS announcement, the call will address issues and concerns IRF providers experienced during the first reporting period and how they can be avoided, along with resouces available to IRFs to assist with reporting.

CMS Special Open Door Forum on LTCH Quality Reporting (Nov. 21)

A November 21, 2013 CMS call will provide an update on data collection and reporting requirements, time frames, and submission deadlines under the Medicare Long-Term Care Hospital (LTCH) Quality Reporting Program.

CMS Call on 2015 Value-Based Payment Modifier (Sept. 24)

On September 24, 2013, CMS will host a call for providers on “Program Year 2012 Quality and Resource Use Report – Mapping a Route to Success for the 2015 Value-Based Payment Modifier.” The call will focus on the 2012 Quality Resource Use Reports (QRURs), which illustrate how a group would be impacted by the final Physician Value-Based Payment Modifier policies. The QRURs will be available to authorized representatives of group practices with 25 or more eligible professionals on September 16, 2013. The provider call will cover how to interpret and use the data in the report.

CMS Finalizes FY 2014 Medicare IPPS, LTCH Rates

On August 19, 2013, the Centers for Medicare & Medicaid Services (CMS) published a final rule updating FY 2014 Medicare payment policies and rates under the acute inpatient prospective payment system (IPPS) and the long-term care hospital (LTCH) prospective payment system (PPS). The following are highlights of the lengthy rule:

  • The final rule increases IPPS operating payment rates by 0.7% for hospitals that successfully participate in the Hospital Inpatient Quality Reporting (IQR) Program (for hospitals that do not successfully, the update is reduced by 2.0 percentage points). This reflects the hospital market basket of 2.5%, which is reduced by 0.5 percentage points for multi-factor productivity and an additional reduction of 0.3 percentage points under the Affordable Care Act (ACA). The rate is further decreased by 0.8% for a documentation and coding recoupment adjustment required by the American Taxpayer Relief Act of 2012 and by a 0.2% adjustment to offset the effect of the policy on inpatient admission and medical review criteria for hospital inpatient services (discussed below).
  • The final rule addresses a number of hospital quality initiatives. For instance, CMS is implementing the ACA’s Hospital-Acquired Condition (HAC) Reduction Program, under which hospitals that rank among the lowest-performing 25% with regard to HACs will be paid 99% of the IPPS payment that otherwise would be made, effective beginning in FY 2015. The rule finalizes the quality measures and scoring methodology for the HAC Reduction Program, along with the process for hospitals to review and correct data. In addition, the rule updates the Hospital Readmissions Reduction Program to, among other things, increase the maximum payment reduction to up to 2% and add hip and knee surgery and chronic obstructive pulmonary disease to the list of conditions used to determine the reduction, effective in FY 2015. CMS also has revised the methodology to better account for planned readmissions. Further, CMS has updated the Hospital Value-Based Purchasing (VBP) Program, which adjusts IPPS payments based on how well a hospital performs or improves performance on a set of quality measures. For FY 2014, CMS is adding new measures to the program, and increasing the applicable reduction to base operating DRG payment amounts to 1.25%, which increases the total estimated amount available for value-based incentive payments to approximately $1.1 billion. The rule also revises Inpatient Quality Reporting program measures.
  • CMS is finalizing (with modifications) its proposed changes in criteria for determining the appropriateness of inpatient admissions. In brief, under this policy, CMS will provide that, in addition to services designated by CMS as “inpatient only,” surgical procedures, diagnostic tests, and other treatments will be presumed to be appropriate for Medicare Part A inpatient hospital payment when the physician admits a patient based on the expectation that the patient will require a stay of at least two midnights. As noted, CMS adopted its proposed 0.2% rate cut to offset the expected effect of the policy on inpatient admissions.
  • CMS finalized its proposal to use cost-to-charge ratios (CCRs) for Implantable Devices, MRIs, CT scans, and cardiac catheterization for rate-setting purposes, which increases the total number of CCRs used to calculate FY 2014 relative weights from 15 to 19. The additional CCRs generally increase relative weight values for surgical Medicare severity diagnosis related group (MS–DRGs) and decrease values for medical MS–DRGs.
  • The rule implements an ACA provision that provides that distribution of Medicare disproportionate share hospital (DSH) payments will be based in part on an estimate of how much uncompensated care hospitals provide relative to other hospitals.
  • The rule addresses a number of other policy issues, including: MS-DRG classifications for certain procedures; applications for new technology add-on payments; the timeframe for hospital billing of Medicare Part B services inappropriately billed under Part A; the calculation of graduate medical education payments; a revised/rebased market basket; critical access hospital (CAH) conditions of participation; the expiration of the Medicare-Dependent Hospital program, the expiration of changes to low volume hospital policy; and revised measures under the Inpatient Psychiatric Facility (IPF) Quality Reporting, LTCH QRP, and PPS-Exempt Cancer Hospital Quality Reporting programs.
  • The rule also updates LTCH PPS rates and policies for FY 2014. Under the final rule, the standard federal rate will equal $40,607.31, compared to a standard rate of $40,397.96 applicable from December 29, 2012 through September 30, 2013. The FY 2014 standard federal rate reflects a 1.7% update for LTCHs that submit the requisite quality data under the LTCH Quality Reporting Program (LTCH QRP), based on a market basket update of 2.5% reduced by a multi-factor productivity adjustment of 0.5 percentage point and an additional 0.3 percentage point reduction as mandated by the ACA. The LTCH PPS standard federal rate will be of -0.3% for LTCHs that fail to submit data under the LTCH QRP. The rule also provides a budget neutrality adjustment (under the second year of a 3-year phase-in of a onetime prospective adjustment) and an area wage level budget neutrality factor. In addition, the final rule sets the fixed-loss amount for high cost outlier cases at $13,314, down from the FY 2013 fixed-loss amount of $15,408. Moreover, the final rule allows the current moratorium on the full implementation of the so-called “25% rule” to expire at the end of FY 2013 (at which time, if an LTCH admits more than a specified percentage of its patients from a single acute care hospital during a fiscal year, it will be paid at a rate comparable to the IPPS rate for patients above the specified percentage threshold).

CMS Issues Final FY 2014 Medicare Inpatient Rehabilitation Facility (IRF) Rule

CMS published a final rule on August 6, 2013 that updates Medicare IRF PPS rates for FY 2014. CMS is applying a 1.8% payment update to IRF PPS rates for FY 2014, derived from a 2.6% market basket update that is reduced by a 0.5 percentage point multi-factor productivity adjustment and an additional 0.3 percentage point reduction as required by the ACA. This results in a standard payment conversion factor of $14,846 for discharges in FY 2014, up from the FY 2013 conversion factor of $14,343. CMS also decreased the outlier threshold from $10,466 to $9,272, which has the effect of increasing IRF PPS payments by an estimated 0.5%. In addition, CMS is revising the list of diagnosis codes that are used to determine presumptive compliance under the “60 percent rule” and qualify a facility to be excluded from the IPPS and be paid under the IRF PPS. Under the final rule, CMS is removing from the “presumptive compliance” list certain non-specific diagnosis codes, arthritis diagnosis codes, unilateral upper extremity diagnosis, some congenital anomalies diagnosis codes, and other miscellaneous diagnosis codes, effective for compliance review periods beginning on or after October 1, 2014. CMS also adopted revisions to the conditions of payment for IRF units of acute care hospitals to specify a minimum number of hospital beds that the IPPS hospital must have to meet the regulatory standard for having an IRF unit. Under the rule, the institution of which the IRF unit is a part must have at least 10 staffed and maintained hospital beds that are not excluded from the IPPS, or at least 1 staffed and maintained hospital bed for every 10 certified IRF beds, whichever number is greater (CAHs that have IRF units are excluded from these requirements because they already have specific bed size restrictions). CMS is delaying implementation of this change until October 1, 2014 to give impacted IRFs adequate time to comply with state certificate of need or other state licensure laws. The final rule also updates the IRF facility-level adjustment factors, revises the Inpatient Rehabilitation Facility-Patient Assessment Instrument, and revises and updates quality measures and reporting requirements under the IRF quality reporting program.

CMS Finalizes Hospice Policies, Rates for FY 2014

CMS published a final rule on August 7, 2013 that updates Medicare hospice reimbursement and related policies for FY 2014, which begins on October 1, 2013. The final rule increases Medicare hospice payments by 1.0% compared to FY 2013 rates, but down slightly from the 1.1% increase anticipated in the proposed rule. Specifically, CMS is increasing hospice per diem rates by 1.7% (reflecting a 2.5% market basket increase that is reduced by 0.8 percentage points due to ACA adjustments), but this update is partially offset by a 0.7 percentage point cut resulting from the use of updated wage data and continued phase-out of the wage index budget neutrality adjustment factor (as set forth in prior rulemaking). CMS is also finalizing its clarification of ICD–9–CM coding guidelines and CMS’s expectations for diagnosis reporting on hospice claims, especially regarding the use of nonspecific symptom diagnoses. CMS instructs hospice providers to use the most definitive, contributory terminal illness as the principal diagnosis, with additional diagnoses included on the claim. CMS provides that “debility” and “adult failure to thrive” may not be used as principal hospice diagnoses on the claim; such claims will be returned to the provider for more definitive coding. However, in response to comments regarding the need for additional time to implement these coding clarification changes within provider software systems, CMS will delay returning claims to providers until October 1, 2014 (which coincides with the transition to ICD-10-CM).

CMS also adopted revisions to its hospice quality reporting requirements. By way of background, under the ACA, hospices that fail to meet quality reporting requirements will receive a 2 percentage point reduction to their market basket update beginning in FY 2014. In 2013, hospices began reporting data on two quality measures (a pain management measure and a structural measure on participation in a Quality Assessment and Performance Improvement Program) for the FY 2014 payment determination. Beginning with the 2016 payment determination, CMS is eliminating these two measures and replacing them with a standardized patient-level data collection instrument called the Hospice Item Set (HIS). Hospices must complete the HIS at admission and discharge on all patients admitted to hospice effective July 1, 2014. The final rule also discusses, among other things, CMS’s plans to require the use of a Hospice Experience of Care Survey beginning in 2015 for the FY 2017 payment determination, and CMS’s efforts to reform the hospice payment framework. Further, the rule provides that CMS will update future hospice per diem rates through an annual rule or notice, rather than solely through a subregulatory Change Request, as CMS has previously done.

Medicare Home Health PPS Rates to Drop under Proposed CY 2014 Rule

CMS’s proposed Medicare home health PPS (HH PPS) rule for CY 2014 would cut payment by 1.5% ($290 million) compared to 2013 levels. This proposed reduction reflects a 2.4% home health payment update, which is more than offset by an ICD–9 grouper refinement and an ACA-mandated rebasing adjustment to the national, standardized 60-day episode payment rate and other applicable payment amounts. The ACA rebasing adjustment is intended to reflect factors such as changes in the number of visits in an episode, the mix of services in an episode, the level of intensity of services in an episode, and the average cost of providing care per episode. CMS estimates that the difference between the 2013 average payment per episode and the average cost per episode is 13.63%; since the ACA caps the adjustment at 3.5% per year for four years, CMS proposes to reduce payments in each year from CY 2014 to CY 2017 by 3.5% (for a total of 14% over four years). In addition to other home health policy updates, the proposed rule would revise the Home Health Quality Reporting Program, including adding quality measures relating to hospital readmissions and Emergency Department visits with the first 30 days of a home health stay. The proposed rule would also clarify cost allocation of home health agency survey expenses; for that portion of costs attributable to Medicare and Medicaid, CMS would assign 50% to Medicare and 50% to Medicaid. CMS will accept comments on the proposed rule until August 26, 2013.

CMS Invites Comments on Proposed PPS-Exempt Cancer Hospital Quality Measures

CMS has opened an “informal” comment period on potential quality of care measures for cancer hospitals exempt from the Medicare prospective payment system (PPS). A CMS contractor has developed the following candidate measures intended to address gap areas not covered by the current PPS-Exempt Cancer Hospital Quality Reporting (PCHQR) Program: (1) Initiation of Osteoclast Inhibitors for Patients with Multiple Myeloma or Bone Metastases Associated with Breast Cancer, Prostate Cancer, or Lung Cancer; (2) Overuse of Imaging for Staging Breast Cancer at Low Risk of Metastasis; and (3) Potentially Avoidable Admissions and Emergency Department Visits Among Patients Receiving Outpatient Chemotherapy. Comments are due July 3, 2013.

CMS Proposes Medicare IPPS and LTCH PPS Rates/Policies for FY 2014

On Mayl 10, 2013, the Centers for Medicare & Medicaid Services (CMS) published its proposed rule updating Medicare inpatient prospective payment system (IPPS) and long-term acute care hospital prospective payment system (LTCH PPS) rates and policies for fiscal year (FY) 2014, which begins October 1, 2013. Comments on the proposed rule will be accepted until June 25, 2013. Highlights of the sweeping rule include the following: 

  • The proposed rule would increase IPPS operating rates by 0.8% after accounting for all adjustments (if a hospital does not successfully participate in the Hospital Inpatient Quality Reporting (IQR) Program, this update is reduced by 2.0 percentage points). The 0.8% update reflects the hospital market basket of 2.5% reduced by a -0.4 percentage point multi-factor productivity adjustment and an additional -0.3 percentage point reduction in accordance with the Affordable Care Act (ACA). The rate is further decreased by 0.8% for a proposed documentation and coding recoupment adjustment required by the American Tax Relief Act of 2012 and by a 0.2% proposed adjustment to offset the cost of a proposal addressing its inpatient medical review criteria. Specifically, CMS proposes to clarify its medical review criteria to presume that Part A hospital inpatient status is appropriate if the beneficiary is admitted to the hospital pursuant to a physician order and receives care for at least two midnights. On the other hand, hospital inpatient admissions spanning less than two midnights will presumptively be inappropriate under Part A. Appropriate documentation could rebut the presumption.
  • The proposed rule includes a number of hospital quality initiatives. For instance, CMS is proposing to implement the ACA’s Hospital-Acquired Condition (HAC) Reduction Program. Under this provision, effective beginning in FY 2015, hospitals that rank among the lowest-performing 25% with regard to HACs will be paid 99% of the IPPS payment that otherwise would be made. The proposed rule addresses, among other things, the payment adjustment, measure selection, risk-adjustment and scoring methodology; performance scoring; public availability of hospital-specific performance information; and limitation of administrative and judicial review. CMS also proposes to update the Hospital Value-Based Purchasing (VBP) Program, which adjusts IPPS payments based on how well a hospital performs or improves performance on a set of quality measures. For FY 2014, CMS proposes increasing the applicable percent reduction to base operating DRG payment amounts to 1.25%, increasing the total estimated amount available for value-based incentive payments (approximately $1.1 billion), and adding new measures to the program. In addition, the proposed rule would expand the Hospital Readmissions Reduction Program, under which CMS currently assesses hospitals’ penalties using three readmissions measures (heart attack, heart failure, and pneumonia). The maximum payment reduction will increase from 1% to 2% in FY 2014, as mandated by the ACA. For FY 2014, CMS also proposes to add two new measures to calculate readmission penalties effective for FY 2015: readmissions for hip/knee arthroplasty and chronic obstructive pulmonary disease. CMS also proposes a revised methodology to take into account planned readmissions for the existing readmissions measures. The proposed rule also would revise IQR program measures.
  • CMS proposes to implement new cost centers for Implantable Devices, MRIs, CT scans, and cardiac catheterization for FY 2014, which would increase the total number of cost-to-charge ratios (CCRs) used to calculate the FY 2014 proposed relative weights from 15 to 19. The additional CCRs generally increase the relative weight values for surgical Medicare severity diagnosis related group (MS-DRGs) and decrease the relative weight values for medical MS-DRGs.
  • CMS proposes to implement an ACA provision revising how Medicare disproportionate share hospital (DSH) payments are paid. Under the proposed rule, hospitals will receive 25% of the payment they otherwise would receive, and the remaining 75% percent will be adjusted for decreases in the national rate of uninsured individuals and distributed to hospitals payments based on the hospital’s share of uncompensated care relative to all Medicare DSH hospitals.
  • The proposed rule also addresses, among many other things: MS-DRG classifications for certain procedures; applications for new technology add-on payments; direct graduate medical education and indirect medical education payments; and the rate-of-increase limits for certain hospitals excluded from the IPPS that are paid on a reasonable cost basis subject to these limits. In addition, CMS proposes to revise the conditions of participation (CoPs) for hospitals relating to the administration of vaccines by nursing staff, and the CoPs for critical access hospitals relating to the provision of acute care inpatient services.
  • With regard to the LTCH PPS, CMS proposes a 1.8% annual update for LTCHs, which would increase the standard federal rate to $40,622.06. The rule also includes a number of other LTCH PPS payment and policy provisions, including a proposal to allow the regulatory moratorium on the full application of the “25% Rule” to lapse, new quality measures, and solicitation of comments on patient criteria-based payment adjustments. Reed Smith has prepared a Client Alert with additional details on the LTCH PPS provisions.

CMS Proposes Hospice Payment Policies for FY 2014

CMS published a proposed rule on May 10, 2013 that would increase Medicare hospice reimbursement by 1.1% -- or $180 million -- in FY 2014. Specifically, CMS would update the hospice per diem rates by 1.8% (reflecting a 2.5% market basket increase that is reduced by 0.7 percentage points for adjustments mandated by the ACA), but this update is partially offset by a 0.7 percentage point cut resulting from the use of updated wage data and CMS’s continued phase-out of its wage index budget neutrality adjustment factor (as set forth in prior rulemaking).

The proposed rule also would clarify ICD–9–CM coding guidelines and CMS’s expectations for diagnosis reporting on hospice claims, especially regarding the use of nonspecific symptom diagnoses. CMS restates its expectation that hospice providers will “code the most definitive, contributory terminal illness in the principal diagnosis field with all other related conditions in the additional diagnoses fields for hospice claims reporting.” For instance, CMS clarifies that “debility” and “adult failure to thrive” would not be used as principal hospice diagnoses on the hospice claim form. CMS specifically solicits comments on its coding guideline clarifications.

CMS also proposes revisions to its hospice quality reporting requirements. By way of background, under the ACA, hospices that fail to meet quality reporting requirements will receive a 2 percentage point reduction to their market basket update beginning in FY 2014. In 2013, hospices began reporting data on two quality measures (a pain management measure and a structural measure on participation in a Quality Assessment and Performance Improvement Program) for the FY 2014 payment determination. Beginning with the 2016 payment determination, CMS is proposing to replace these two measures with a standardized patient-level data collection instrument called the Hospice Item Set (HIS). The proposed rule also discusses, among other things, CMS’s plans to require the use of a Hospice Experience of Care Survey beginning in 2015 for the FY 2017 payment determination, and its efforts to reform the hospice payment framework. Comments will be accepted until June 28, 2013.

CMS Proposes Updated FY 2014 Medicare Payments and Other Policies for IRFs

CMS published a proposed rule on May 8, 2013 that would update Medicare inpatient rehabilitation facility (IRF) prospective payment system (PPS) rates for FY 2014. CMS proposes a 1.8% payment update for FY 2014, reflecting a 2.5% market basket increase factor, reduced by a 0.4% multi-factor productivity adjustment and an additional 0.3 percentage point reduction required by the ACA. The update would establish a standard payment conversion factor of $14,865 for discharges occurring in FY 2014, which is an increase from the FY 2013 standard payment conversion factor of $14,343. CMS also is proposing to update the outlier threshold, which would increase IRF PPS payments by an estimated 0.2%, for a total estimated increase of 2%. In addition, the proposed rule would revise and update quality measures and reporting requirements under the IRF quality reporting program. Beginning in FY 2014, CMS will apply a 2 percentage point reduction to the applicable market basket increase factor for IRFs that fail to comply with the quality data submission requirements. In the rule, CMS also proposes to revise the list of diagnosis codes that are used to determine presumptive compliance under the “60 percent rule” for a facility to be excluded from the IPPS and be paid under the IRF PPS. Under the proposed rule, CMS would remove from the “presumptive compliance” list certain non-specific diagnosis codes, arthritis diagnosis codes, unilateral upper extremity diagnosis, some congenital anomalies diagnosis codes, and other miscellaneous diagnosis codes. In addition, CMS proposes revisions to the conditions of payment for IRF units of acute care hospitals to specify a minimum number of hospital beds that the IPPS hospital must have to meet the regulatory standard for having an IRF unit. Under the rule, the institution of which the IRF unit is a part would be required to have at least 10 staffed and maintained hospital beds that are not excluded from the IPPS, or at least 1 staffed and maintained hospital bed for every 10 certified IRF beds, whichever number is greater. If the institution does not meet this threshold, CMS proposes that the IRF unit should instead be classified as an IRF hospital. CAHs that have IRF units would be excluded from these requirements because they already have specific bed size restrictions. The proposed rule also would, among other things: update the IRF facility-level adjustment factors; revise the Inpatient Rehabilitation Facility-Patient Assessment Instrument; and clarify various regulatory provisions.  CMS will accept comments on the rule until July 1, 2013.

CMS Proposed Changes to Medicare LTCH Payment Rates and Policies for FY 2014

This post was written by Paul W. Pitts.

On April 26, 2013, the Centers for Medicare & Medicaid Services (“CMS”) released the proposed update to the Medicare long-term acute care hospital prospective payment system (“LTCH PPS”) policies and payment rates for fiscal year (“FY”) 2014. The proposed changes would apply to discharges occurring on or after October 1, 2013 through September 30, 2014. CMS will accept comments on the proposed rule until June 25, 2013, and will respond to comments in a final rule to be issued by August 1, 2013. Reed Smith has prepared a Client Alert that provides a summary of the most significant proposed changes to the LTCH PPS in the proposed rule.

Updated House SGR Reform Proposal

The chairmen of the House Energy and Commerce Committee and Ways and Means Committee have provided additional details regarding their proposal to repeal the current Medicare physician fee schedule sustainable growth rate (SGR) methodology and replace it with an alternative physician payment system. The update builds on comments received from the public on the panels’ February 7, 2013 outline. Among other things, the expanded proposal discusses processes to determine quality and efficiency measures that focus on evidence while being flexible and specialty-specific; recognizes the role that specialty-specific registries play in quality improvement; and addresses timely performance feedback for providers. Comments will be accepted until April 15 at sgrcomments@mail.house.gov

CMS Call: ESRD Quality Incentive Program (March 13)

On March 13, 2013, CMS is hosting a provider call on the Medicare End-Stage Renal Disease (ESRD) Quality Incentive Program (QIP) for Payment Year (PY) 2015. Among other things, the call will review the measures, standards, scoring methodology, and payment reduction scale that will be applied to the PY 2015 program.

National Provider Call: Hospital Value-Based Purchasing FY 2015 Overview (March 14)

On March 14, 2013, CMS is hosting a National Provider Call to provide an overview of the FY 2015 Medicare Hospital Value-Based Purchasing (VBP) Program design and a preview of the FY 2015 Baseline Measures Report. The event is intended to help demonstrate how hospitals will be evaluated for each of the FY 2015 domains (measures/dimensions).

Older Entries

January 30, 2013 — GAO Offers Recommendations for Medicare Physician Value Modifier Program

January 14, 2013 — Hospital Readiness for Electronic Quality Reporting

December 17, 2012 — Interim Rule Revises EHR Certification Criteria, Incentive Program Specifications

November 29, 2012 — CMS Requests Comments on ACA Exchange Health Plan Quality Management

November 29, 2012 — ACA Medicare Data Sharing Provision Implementation Proceeds

November 16, 2012 — CMS Finalizes OPPS, ASC Rates and Policies for 2013

November 16, 2012 — CMS Adopts 2013 ESRD PPS Update, Bad Debt Reimbursement Cuts

November 16, 2012 — CMS Adopts 2013 Medicare Home Health PPS Rates, Update to Hospice Quality Program

October 31, 2012 — CMS Posts Specifications for Electronic Clinical Quality Measures (eCQMs)

October 15, 2012 — CMS Calls on IRF, LTCH Quality Reporting (Oct. 18)

September 24, 2012 — CMS to Host ASC Quality Reporting Webinar (Sept. 26)

August 20, 2012 — CMS Issues Final Medicare Inpatient Hospital Rates/Policies for FY 2013

August 20, 2012 — CMS Adopts LTCH PPS Payment, Policy Changes for FY 2013

August 16, 2012 — CMS Forum on LTCH Quality Reporting (Aug. 30)

July 27, 2012 — CMS Publishes FY 2013 Medicare Hospice Wage Index/Rate Update Notice, Comorbidity Diagnosis Reminder, Quality Update

July 25, 2012 — CMS Forum: Improving Care for Medicare Beneficiaries with ESRD (July 31)

July 20, 2012 — CMS Schedules Calls on IRF Quality Reporting Program

July 19, 2012 — CMS Issues Proposed OPPS, ASC Policies for 2013

May 14, 2012 — CMS Proposes Medicare Inpatient Hospital Rates/Policies for FY 2013

April 2, 2012 — GAO Examines CMS Nursing Home Quality Rating System

February 22, 2012 — Physician Value-Based Payment Modifier Program: Experience from Private Sector Physician Pay-for-Performance Programs (Feb. 29)

February 10, 2012 — CMS Call on Hospital Value-Based Purchasing Program Performance Reports (Feb. 28)

January 5, 2012 — Final Medicaid Core Quality Measures

December 13, 2011 — CMS Seeks Early Input on Future Quality & Efficiency Measures

December 12, 2011 — CMS Call: Payment Standardization and Risk Adjustment for the Medicare Physician Feedback & Value Modifier Programs (Dec. 21)

November 22, 2011 — Hospital Value Based Purchasing National Provider Call

November 21, 2011 — CMS Call on IRF Quality Reporting (Nov. 29)

November 14, 2011 — CMS Issues Final Medicare Physician Fee Schedule Rule for 2012

November 14, 2011 — CMS Finalizes CY 2012 OPPS/ASC Rates, Policy Changes

November 14, 2011 — CMS Adopts Home Health PPS Rate Cut for 2012

November 14, 2011 — CMS Updates End-Stage Renal Disease (ESRD) PPS for 2012

October 28, 2011 — GAO Report Examines CMS Oversight of Long-Term Care Hospitals

September 29, 2011 — CMS Accepting Comments on LTCH Quality Measures

September 29, 2011 — CMS Seeks Comments on Hospice Quality Reporting Forms

September 20, 2011 — CMS Accepting Suggestions for Future PQRS Measures (Due Oct. 7)

September 19, 2011 — CMS Call on Long-Term Care Hospital (LTCH) Quality Reporting Program (Sept. 21)

September 8, 2011 — CMS Call on Changes to Medicare Electronic Prescribing (eRx) Incentive Program (Sept. 13)

August 16, 2011 — CMS Issues Final Medicare Inpatient Hospital PPS Rule for FY 2012

August 16, 2011 — CMS Issues Final FY 2012 Medicare Long Term Acute Care Hospital PPS Rule

August 16, 2011 — GAO Assesses Challenges with CMS Physician Feedback Program

August 16, 2011 — GAO Examines Information for Policymakers on Health Care Quality/Value

August 1, 2011 — CMS Releases Final FY 2012 Hospice Wage Index Rule

August 1, 2011 — CMS Finalizes FY 2012 Inpatient Rehabilitation Facility (IRF) PPS Policies

July 27, 2011 — ESRD Quality Incentive Program Special Open Door Forum (Aug. 4)

July 19, 2011 — CMS Issues Proposed CY 2012 Physician Fee Schedule Rule

July 18, 2011 — CMS Proposes CY 2012 OPPS/ASC Rates, Policy Changes

July 18, 2011 — CMS Proposes CY 2012 Changes to End-Stage Renal Disease (ESRD) PPS

July 15, 2011 — CMS Special Open Door Forum on FY 2013 Hospital Value-Based Purchasing Program (July 27)

July 13, 2011 — CMS call on Physician Quality Reporting System/E-Prescribing Incentive Program (July 26)

June 14, 2011 — CMS Proposes ACA Medicare Claims Data Sharing Rule

June 8, 2011 — CMS Physician Quality Reporting System & E-Prescribing Incentive Program Provider Teleconference (June 21)

May 31, 2011 — Federal Agencies Outline Regulatory Review Plans

May 11, 2011 — CMS Call on Medicare/Medicaid EHR Incentive Programs: Understanding Meaningful Use (May 19)

May 11, 2011 — CMS Forum on 2011 Physician Quality Reporting System and Electronic Prescribing Incentive Programs: ICD-10 Conversion (May 26)

May 11, 2011 — 2011 Physician Quality Reporting System & Electronic Prescribing Incentive Program National Provider Call (May 17)

April 29, 2011 — CMS Proposes Medicare Inpatient Hospital/LTCH Payment Policies for FY 2012

April 29, 2011 — CMS Finalizes ACA Hospital Value-Based Purchasing Program

April 29, 2011 — CMS Issues Proposed FY 2012 Inpatient Rehabilitation Facility (IRF) PPS Rule

April 29, 2011 — CMS Releases FY 2012 Hospice Wage Index Proposed Rule, Notice of Ruling on Hospice Cap Challenges

April 29, 2011 — CMS Releases 2009 Quality Reporting Data

March 19, 2011 — CMS call on Physician Quality Reporting/E-Prescribing for Beginners (March 22)

March 19, 2011 — CMS Forum on Hospital Quality Reporting/HAC Measures (March 21)

March 2, 2011 — 2011 Physician Quality Reporting System/E- Prescribing Incentive Call (March 8)

February 24, 2011 — CMS to Hold Call on Medicaid Quality Measures (Feb. 28, 2011)

January 13, 2011 — CMS Proposes Hospital Value Based Purchasing Program

January 13, 2011 — ESRD Quality Incentive Program Final Rule

January 13, 2011 — HHS Seeks Comments on Draft Medicaid Quality Measures

December 13, 2010 — HIT Quality Measures Workgroup Comment Opportunity

December 6, 2010 — CMS Meeting on Developing New Imaging Efficiency Measures (Jan. 31, 2011)

December 6, 2010 — CMS Open Door Forum on LTCH, IRF, and Hospice Quality Measures (Dec. 16)

December 6, 2010 — Physician Quality Reporting/E-Prescribing Incentive Call (Dec. 15)

October 20, 2010 — CMS Hospital Value-Based Purchasing Program Special Forum (Oct. 26)

October 13, 2010 — CMS to Host PQRI/E-RX Call (Oct. 19)

October 6, 2010 — CMS Call on ASC Value-Based Purchasing (Oct. 14, 2010)

September 24, 2010 — CMS Town Hall Meeting on ACA Physician Compare Web Site Mandate (Oct. 27)

August 31, 2010 — Listening Session on ACA Provision on Use of Medicare Data for Performance Measurement (Sept. 20, 2010)

August 16, 2010 — CMS Forum on ESRD Quality Incentive Program (Aug. 24, 2010)

August 13, 2010 — Final FY 2011 Medicare Inpatient Hospital, LTCH Rates

August 11, 2010 — 2010 PQRI/E-Rx National Provider Call (Aug. 17, 2010)

June 7, 2010 — CMS PQRI/E-Prescribing Provider Call (June 22)

April 16, 2010 — 2009 National Healthcare Quality & Disparities Reports

February 4, 2010 — CMS Convenes Technical Expert Panel on ESRD Quality Measures

January 13, 2010 — Medicaid/CHIP Children's Healthcare Quality Measures

January 13, 2010 — OIG Report on Disclosure of Hospital Adverse Events

January 7, 2010 — CMS Listening Session on 2011 PQRI Quality Measures (Feb. 2, 2010)

January 7, 2010 — 2010 PQRI National Provider Call (Jan. 12, 2010)

December 18, 2009 — 2010 PQRI/Electronic Prescribing Call (Jan. 14, 2010)

December 4, 2009 — CMS Solicits Potential 2011 PQRI Measures/Measures Groups

December 1, 2009 — CMS Call on 2009 Physician Quality Reporting Initiative (Dec. 10).

November 11, 2009 — Final CY 2010 Medicare Physician Fee Schedule Rule Released

November 11, 2009 — Final CY 2010 Medicare HOPPS/ASC Rule Released

July 7, 2009 — CMS Proposes CY 2010 Medicare Physician Fee Schedule Rule

July 7, 2009 — HOPPS/ASC Proposed Rule

June 12, 2009 — 2009 PQRI Call (June 17, 2009)

May 8, 2009 — HOPPS Imaging Efficiency Measures

May 7, 2009 — Finance Committee Releases Health Care Delivery System Reform Options; Comment Opportunity (Due May 15)

April 24, 2009 — PQRI Electronic Health Record Test Specifications

April 7, 2009 — 2010 PQRI Measure Solicitation

April 6, 2009 — Driving for Quality in Acute Care

April 3, 2009 — 2009 PQRI Update (April 22, 2009)