Use Your Voice – Advocate on Behalf of RHC Burden Reduction Act

April 28, 2023

Use Your Voice – Advocate on Behalf of RHC Burden Reduction Act

The National Association of Rural Health Clinics (NARHC) is requesting your help in generating support for the Rural Health Clinic Burden Reduction Act (S.198). This important piece of legislation modernizes 5 pieces of the RHC statute written in 1977 to better reflect the changing world of health care delivery.

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New Policy Brief: Financial Characteristics of CAHs Participating in Accountable Care Organizations (ACO)

November 2, 2022

Financial Characteristics of CAHs Participating in ACOs

The Flex Monitoring Team has released a new policy brief, Financial Characteristics of Critical Access Hospitals (CAHs) Participating in Accountable Care Organizations (ACO). This brief describes CAH participation in ACOs and the financial performance and organizational characteristics of participating and non-participating CAHs. An understanding of the financial and operational factors that may be important to ACO participation may benefit hospital leaders and State Flex Programs as they identify areas for improvement and benchmark performance.

View Policy Brief

2022 National Training Program Virtual Workshops

Date: July 8, 2022

Registration is OPEN
2022 National Training Program Virtual Workshops

Registration for the 2022 Centers for Medicare & Medicaid Services (CMS) National Training Program (NTP) virtual workshops is open. Session dates are listed below.

Select the hyperlinked event title(s) to register for each event you’re interested in attending. You’ll be prompted to login to the NTP virtual workshop webpage. To login, use the same email address and password you use to register for all NTP webinars. If you don’t have an account, you’ll need to create one before registering. After you register for an event, you’ll get an email confirmation which will include a calendar appointment. Please email NTPHelp@cms.hhs.gov if you need help with your account or registration. Sessions will start at 1:00 PM and conclude no later than 3:30 PM (ET). Sessions will be recorded for later viewing.

August 2022

2ndSocial Security
Description: This workshop will explain retirement, disability, supplemental security income, and survivors benefits and how they can affect Medicare.

3rdMedicare Enrollment, Eligibility, Part A and Part B
Description: This workshop will explain Medicare coverage—who’s eligible, how and when to enroll, Medicare Part A and Part B, the services they cover, and associated costs.

4thMedicare Supplement Insurance (Medigap)
Description: This workshop will discuss how Medicare Supplement Insurance policies (also known as Medigap) work with Medicare, what Medigap policies cover, how they’re structured, and when to buy a Medigap policy.

9thMedicare Drug Coverage
Description: This workshop will explain drug coverage under the different parts of Medicare and describe how Medicare drug coverage (Part D) works, coverage rules, eligibility, enrollment, and Extra Help.

10thMedicare Advantage
Description: This workshop will explain Medicare health plan options other than Original Medicare with a primary focus on Medicare Advantage (sometimes called Medicare Part C).

11thPreventing Medicare & Medicaid Fraud, Waste, & Abuse
Description: This workshop will define health care fraud, waste, and abuse, identify causes of improper payments, and discuss the processes and organizations in place to prevent and detect Medicare and Medicaid fraud.

16thCoordination of Benefits
Description: This workshop will explain different payers’ responsibilities when people have both Medicare and certain other types of health and/or prescription drug coverage.

17thWhere Do I Find? (Online Resources)
Description: This workshop will identify key websites, like Medicare.gov, associated resources, and tools to help our partners, stakeholders, not-for-profit professionals, and volunteers (who work with consumers and their families) help others make informed health care coverage decisions.

18thMedicaid & the Children’s Health Insurance Program (CHIP)
Description: This workshop will explain Medicaid, the Children’s Health Insurance Program (CHIP), and review considerations for those with both Medicare and Medicaid (sometimes called dual eligibles or duals).

23rdMedicare Scenarios (Casework Session)
Description: This workshop will walk through examples of Medicare coverage scenarios in a casework format to evaluate the case, review possible resources and options, and discuss appropriate solutions.

24thCMS and SAMHSA: Federal Partners addressing Behavioral Health
Description: This workshop will outline the Centers for Medicare & Medicaid Services’ (CMS) new Behavioral Health Strategy from the Centers for Medicare & Medicaid Services (CMS) which covers multiple elements including access to prevention and treatment services for substance use disorders, mental health services, crisis intervention, and pain care. The workshop will also include program updates from the Substance Abuse and Mental Health Services Administration (SAMHSA).

25thMedicare Plan Finder
Description: This workshop will demonstrate how to shop and compare Medicare plan options using the Plan Finder tool on Medicare.gov.

30thMedicare Current Topics
Description: This workshop will explain some of the Centers for Medicare & Medicaid Services’ (CMS’) current priorities, initiatives, and recent programmatic updates.

31stThe Public Health Emergency (PHE) and CMS Programs (this topic is subject to change)
Description: This workshop will explain temporary flexibilities to CMS Programs in response to the Public Health Emergency (PHE) declaration for COVID-19, coverage for COVID-19-related treatments, vaccination efforts, and transition activities to prepare for the end of the PHE.

September 2022

1stMarketplace to Medicare: What You Can Expect
Description: This workshop will focus on considerations if you’re enrolled in a Health Insurance Marketplace® plan and qualify for Medicare. It will explain the programs that can help you pay for Medicare, Periodic Data Matching (PDM), and Medicare and the Marketplace resources.

Session materials will be available for download at the time of the event.

NOTE: Registration requests will be considered on a first-come, first-serve basis until each session reaches capacity. The number of attendees from the same organization may be limited. If any session reaches capacity, we’ll work to schedule an additional offering for a later date.

Please send all correspondence to cms@seiservices.com

CY 2023 Proposed Payment Updates and Policy Changes Updates for Home Health Agencies and Home Infusion Therapy Suppliers

Date: June 22, 2022

Proposals and Updates to the HH PPS for CY 2023

This rule proposes routine, statutorily required updates to the home health payment rates for CY 2023. The Centers for Medicare and Medicaid Services (CMS) estimates that Medicare payments to Home Health Agencies (HHAs) in CY 2023 would decrease in the aggregate by -4.2%, or -$810 million compared to CY 2022, based on the proposed policies. This decrease reflects the effects of the proposed 2.9% home health payment update percentage ($560 million increase), an estimated 6.9% decrease that reflects the effects of the proposed prospective, permanent behavioral assumption adjustment of -7.69% ($1.33 billion decrease), and an estimated 0.2% decrease that reflects the effects of a proposed update to the fixed-dollar loss ratio (FDL) used in determining outlier payments ($40 million decrease).

Proposed Permanent Cap on Wage Index Decreases

To achieve the policy goal of increased predictability in home health payments, while aligning with proposals in the FY 2023 Inpatient Prospective Payment System proposed rule and other proposed rules, this rule proposes a permanent, budget neutral approach to smooth year-to-year changes in the pre-floor/pre-reclassified hospital wage index. Specifically, this rule proposes a permanent 5% cap on negative wage index changes (regardless of the underlying reason for the decrease) for home health agencies.

Recalibration of Patient-Driven Groupings Model (PDGM) Case-Mix Weights

Each of the 432 payment groups under the PDGM has an associated case-mix weight and Low Utilization Payment Adjustment (LUPA) threshold. CMS’ policy is to annually recalibrate the case-mix weights and LUPA thresholds using the most complete utilization data available at the time of rulemaking. In this proposed rule, CMS is proposing to recalibrate the case-mix weights (including the functional levels and comorbidity adjustment subgroups) and LUPA thresholds using CY 2021 data to more accurately pay for the types of patients HHAs are serving.

PDGM and Behavioral Assumptions

On January 1, 2020, CMS implemented the home health PDGM and a 30-day unit of payment, as required by the Bipartisan Budget Act of 2018. The PDGM, which Congress required, better aligns payments with patient care needs, especially for clinically complex beneficiaries that require more skilled nursing care rather than therapy. The law required CMS to make assumptions about behavior changes that could occur because of the implementation of the 30-day unit of payment and the PDGM. In the CY 2019 HH PPS final rule with comment period, CMS finalized three behavioral assumptions (clinical group coding, comorbidity coding, and LUPA threshold). The law also requires CMS to annually determine the impact of differences between assumed behavior changes and actual behavior changes on estimated aggregate expenditures, beginning with 2020 and ending with 2026, and to make temporary and permanent increases or decreases, as needed, to the 30-day payment amount to offset such increases or decreases. Additionally, in the CY 2019 HH PPS final rule (83 FR 56455), it was stated that CMS interpret actual behavior change to encompass both behavior changes that were previously outlined, as assumed by CMS when determining the budget-neutral 30-day payment amount for CY 2020, and other behavior changes not identified at the time the 30-day payment amount for CY 2020 is determined. In the CY 2022 home health proposed rule, CMS solicited comments on a repricing methodology to determine the impact of behavior changes on estimated aggregate expenditures. This CY 2023 proposed rule proposes the repricing method, which calculates what the Medicare program would have spent had the PDGM not been implemented in CYs 2020 and 2021, assuming that HHAs would have provided home health services in the same way they do under the PDGM, compared to what actual home health expenditures were under the PDGM in CY 2020 and CY 2021.

Using this method, CMS is proposing a -7.69% permanent adjustment to the 30-day payment rate in CY 2023 to ensure that aggregate expenditures under the new payment system (PDGM) would be equal to what they would have been under the old payment system. While the law also requires CMS to implement one or more temporary adjustments to retrospectively offset for such increases or decreases in estimated aggregate expenditures, CMS also has the discretion to implement these adjustments in a time and manner deemed appropriate, therefore, CMS is not proposing a temporary payment adjustment in CY 2023. However, CMS is soliciting comments on how best to implement a temporary payment adjustment, estimated to be $2.0 billion for excess estimates in CYs 2020 and 2021.

Comment Solicitation on the Collection of Data on the Use of Telecommunications Technology under the Medicare Home Health Benefit

CMS finalized policy changes regarding the use of services furnished via telecommunications systems in the CY 2021 HH PPS final rule. However, the collection of data on the use of telecommunications technology under the home health benefit is limited to a broad category of telecommunications technology costs under administrative costs on the HHA cost reports (reported at the agency level). This proposed rule solicits comments on the collection of data on the use of such services furnished using telecommunications technology on the home health claims (at the individual beneficiary level). Collecting data on the use of telecommunications technology on home health claims would allow CMS to analyze the characteristics of the beneficiaries utilizing services furnished remotely, and could give us a broader understanding of the social determinants that affect who benefits most from these services, including what barriers may potentially exist for certain subsets of beneficiaries.

For additional information about the Home Health Prospective Payment System.

 

For additional information about the Home Health Patient-Driven Groupings Model.

 

For additional information about the Home Infusion Therapy Services benefit. 

 

The proposed rule can be downloaded from the Federal Register.

CY 2023 Home Health Prospective Payment System Rate Update and Home Infusion Therapy Services Requirements Proposed Rule (CMS-1766-P)

Date: June 22, 2022

CY 2023 Home Health Prospective Payment System Rate Update and Home Infusion Therapy Services Requirements Proposed Rule (CMS-1766-P)

 

On June 17, 2022, the Centers for Medicare & Medicaid Services (CMS) issued the calendar year (CY) 2023 Home Health Prospective Payment System (HH PPS) Rate Update proposed rule, which would update Medicare payment policies and rates for home health agencies (HHAs). This rule includes proposals and routine updates to the Medicare Home Health PPS and the home infusion therapy services’ payment rates for CY 2023, in accordance with existing statutory and regulatory requirements. In addition, CMS is proposing to apply a permanent prospective payment adjustment to the home health 30-day period payment rate to account for any increases or decreases in aggregate expenditures, as a result of the difference between assumed behavior changes and actual behavior changes, due to the implementation of the Patient-Driven Groupings Model (PDGM) and 30-day unit of payment. CMS is soliciting comments on how best to implement a temporary payment adjustment for CYs 2020 and 2021. CMS is also soliciting comments on the collection of telehealth data on home health claims to allow CMS to analyze the characteristics of the beneficiaries utilizing services furnished remotely. The actions CMS is taking in this proposed rule would help improve patient care and also protect the Medicare program’s sustainability for future generations by serving as a responsible steward of public funds.

 

For additional information about the Home Health Prospective Payment System.

 

For additional information about the Home Health Patient-Driven Groupings Model.

 

For additional information about the Home Infusion Therapy Services benefit. 

 

The proposed rule can be downloaded from the Federal Register.

NARHC Hosts Webinar on Modernization Policy

As part of H.R. 133, the Consolidated Appropriations Act of 2021 (aka COVID Relief Package), Congress approved and the President signed into law the most comprehensive reforms of the Medicare Rural Health Clinic (RHC) payment methodology since the mid-90s. In this webinar, Bill Finerfrock, the Executive Director of National Association of Rural Health Clinics (NARHC), and Nathan Baugh, the Director of Government Affairs for NARHC, discuss these major changes in detail.

You can find slides & recording here. Read More

2020 MIPS Extreme and Uncontrollable Circumstances Exception Application Deadline for COVID-19 has been Extended to February 1, 2021

To further support clinicians during the COVID-19 public health emergency, the Centers for Medicare & Medicaid Services (CMS) has extended the deadline for COVID-19 related 2020 Merit-based Incentive Payment System (MIPS) Extreme and Uncontrollable Circumstances Exception applications to February 1, 2021.

For the 2020 performance year, CMS will be using the Extreme and Uncontrollable Circumstances policy to allow MIPS eligible clinicians, groups, and virtual groups to submit an application requesting reweighting of one or more MIPS performance categories to 0% due to the current COVID-19 public health emergency.

If you have any concerns about the effect of the COVID-19 public health emergency on your performance data, including cost measures, for the 2020 performance period, submit an application now and be sure to cite COVID-19 as the reason for your application.

If you have an approved application, you can still receive scores for the Quality, Improvement Activities and Promoting Interoperability performance categories if you submit data. If the Cost performance category is included in your approved application, you will not be scored on cost measures even if other data are submitted. IMPORTANT: Individuals, groups and virtual groups can’t submit an application to override PY2020 data that has already been submitted. Any data submitted as an individual, group or virtual group before or after an application has been approved will be scored. Learn more in the 2020 Exceptions Applications Fact Sheet.

CMS has finalized that APM Entities may submit an application to reweight MIPS performance categories as a result of extreme and uncontrollable circumstances, such as the public health emergency resulting from the COVID-19 pandemic. Data submitted for an APM won’t override performance category reweighting from an approved application. Learn more in the 2021 Quality Payment Program Final Rule Overview Fact Sheet.

Note: The deadline to submit a MIPS Promoting Interoperability Performance Category Hardship Exception application or an Extreme and Uncontrollable Circumstances application not related to COVID-19 will remain December 31, 2020. Remember, if you’re already exempt from reporting Promoting Interoperability data, you don’t need to apply.

How do I Apply?

You must have a Health Care Quality Information Systems (HCQIS) Access Roles and Profile (HARP) account to complete and submit an exception application on behalf of yourself, or another MIPS eligible clinician, group, virtual group or APM Entity. For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide.

Once you register for a HARP account, sign in to qpp.cms.gov, select “Exceptions Applications” on the left-hand navigation, select “Add New Exception,” and select “Extreme and Uncontrollable Circumstances Exception” or “Promoting Interoperability Hardship Exception.”

How do I Know if I’m Approved?

If you submit an application for either of the exceptions, you will be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool, but may not appear in the tool until the submission window is open in 2021.

For More Information

Questions?

Contact the QPP at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. To receive assistance more quickly, please consider calling during non-peak hours-before 10:00 a.m. and after 2:00 p.m. ET.

  • Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.