In this issue
Hospital spotlight: MN hospitals
reducing CAUTI
MHA Hospital
Engagement Network hospitals that are participating in On the Cusp: Stop CAUTI
are making strong improvements in reducing Minnesota’s catheter-associated
urinary tract infections. Nine of the 15 participating hospitals have had zero
CAUTIs to date. Hospitals are also reducing the number of days patients use
catheters. For the period July through September, Minnesota hospitals’ rate was
2.19CAUTIs per 1,000 patient days, below the national comparative rate of 2.47 CAUTIs per 1,000 patient days. Furthermore,
Minnesota hospitals report confidence regarding adherence to proper techniques
for catheter insertion and catheter maintenance. return to top
HHS’s
anti-kickback U-turn for subsidized plans sold on MNsure
Less than a week after issuing a surprising ruling that federal
anti-kickback laws do not prohibit hospitals and health systems from paying
patients’ premiums for health plans sold through a health insurance exchange,
the U.S. Department of Health and Human Services (HHS) reversed course and
strongly warned providers that the agency will not condone this kind of
financial support for patients.
The first guidance from HHS stated that federally
subsidized health plans sold on health insurance exchanges, like Minnesota’s
MNsure, are not considered federal health care programs and, therefore, not
governed by anti-kickback laws. Many provider organizations interpreted this
decision as a window of opportunity to help financially struggling patients
retain health coverage and decrease uncompensated care, although Internal Revenue
Service rules and state laws could pose other barriers.
Before definitive analysis could be completed, however, HHS responded to
providers’ interest in helping patients with their premium and cost sharing
obligations with a statement on Nov. 4. The agency expressed
“significant concerns with this practice,” stated that it “discourages this
practice” and warned that it “intends to monitor this practice and to take
appropriate action, if necessary.”
For more information, contact Ben Peltier, MHA vice president of legal
services, 651-603-3513. return to top
Partial
enforcement of CMS two-midnight policy extended
The Centers for Medicare and Medicaid Services (CMS) will move
forward with the prepayment “Probe and Educate” audits for inpatient admissions
claims submitted by acute care inpatient hospital facilities for admissions
claims dated Oct. 1, 2013 through March 31, 2014. This represents a three-month
extension from its original guidance. It also now includes prepayment
review of critical access hospitals, inpatient psychiatric and long term care hospitals. Initial
reviews will be a sampling of 10 claims for most hospitals and 25 for larger
hospitals. If the probe discovers lack of medical documentation of necessity,
phone calls will be made to the facility.
In its Nov. 5 update, CMS reiterated the two-midnight benchmark set forth in
the inpatient Prospective Payment System (PPS) final rule. Under this final
rule, surgical procedures, diagnostic tests and other treatments (in addition
to services designated as inpatient-only) are generally appropriate for
inpatient hospital admission and payment under Medicare Part A when:
1. The physician expects the beneficiary to require a stay that
crosses at least two midnights; and
2.
admits the beneficiary to the hospital based upon that
expectation.
Documentation in the medical record must support a reasonable
expectation of the need for the beneficiary to require a medically necessary
stay lasting at least two midnights. If the inpatient admission lasts fewer
than two midnights due to an unforeseen circumstance, this must also be clearly
documented in the medical record. Specific examples of unforeseen
exceptions were noted as death, transfer, departures against medical advice and
clinical improvement. Other exceptions should be rare or unusual, however
hospitals are encouraged to send any additional suggestions for the exceptions
list to IPPSAdmissions@cms.hhs.gov
with “Suggested Exceptions to the 2-Midnight Benchmark” in the subject line.
In general, post-payment reviews for this issue by recovery audit contractors
(RAC) for this six-month time span will also be limited.
CMS also indicates that it will update its website with additional
medical review information and that an updated Q&A document will be coming
soon. For questions, contact Joe Schindler, MHA vice president of finance,
651-659-1415. return to top
Cuts
to hospital payments still at risk as Congress faces new fiscal deadlines
Congress continues to face several key fiscal deadlines that
will be both opportunities for health care policy improvements and risks for
hospital funding cuts, including:
-
Dec. 13 - a deadline for budget
conferees to have resolved differences in the House and Senate budget
resolutions passed earlier this year;
- Between Jan. 1 and Jan. 15 - a
“fix” for physician payments is needed to prevent large cuts from taking
place;
- Jan. 15 - the continuing
resolution that is funding the government is set to expire and more
defense sequestration cuts take effect; and
- Feb. 7 - Congress must lift the
debt ceiling again sometime after this date.
Relief from sequestration cuts could be on the table as the
effects of the defense cuts becomes a reality and this could mean welcome
relief for hospitals, but hospital payments could be looked at as a source of
replacement savings.
MHA continues to ask our congressional delegation to support thoughtful policy
reforms instead of across-the-board payment reductions.
MHA Members are encouraged to reinforce the following key messages when
reaching out to members of our delegation prior to these deadlines:
-
MHA members are involved in
many reforms aimed at improving patient health while lowering costs.
- Minnesota hospitals are already
facing over $2 billion in payment reductions over 10 years as a result of
the Affordable Care Act
and more than $614 million cuts from sequestration.
- Federal programs pay Minnesota
hospitals less than the actual costs of caring for patients.
- MHA opposes cuts to the
following programs that are under consideration:
- Cuts to graduate medical
education.
- Cuts to critical access
hospital (CAH) funding and arbitrary policy changes that would limit CAH
designations.
- Cuts to outpatient and
evaluation management services (E/M)—some of the most common outpatient
services provided in hospitals.
- Cuts to Medicare bad debt
payments.
Another deadline looming is the end of the moratorium on
enforcement of direct supervision requirements for outpatient therapeutic
services delivered in a hospital. This policy change was first announced in
2009 and the federal government agreed to refrain from enforcing it for rural
hospitals with fewer than 100 beds through 2013. MHA is pleased that Rep. Colin
Peterson (D-MN) co-authored a House bill to change this policy, and that Sens.
Al Franken (D-MN) and Amy Klobuchar (D-MN), as well as Rep. Tim Walz (D-MN)
have signed on as co-sponsors of the bill in their respective chambers.
In addition, MHA continues to work on securing support for our priority bills. Additional support for these
bills will increase the chances they are included in a larger legislative
package. For questions, contact Ann Gibson, MHA vice president of federal
relations and workforce, 651-603-3527. return to top
Sample
tobacco-free campus policy available for hospitals
Tobacco is a proven health and safety hazard,
both to the smoker and non-smoker, carrying very serious health risks. It has
been proven to be the leading cause of preventable death in the U.S. and is
inconsistent with the health care mission of hospitals. Start Noticing, a coalition working to eliminate
the harmful effects of tobacco use and exposure, has developed a sample
tobacco-free campus policy for hospitals interested in ending tobacco use on
their campuses. Hospitals can download the sample policy here and tailor it to
your own facility.
For questions about the sample policy, contact Susan Vileta with the Start Noticing coalition, 507-847-6930. return to top