IN THIS WEEK’S ISSUE:
- IRF Criteria Transmittal Addresses Status Verification
- CMS to Provide Medicare E-Prescribing Forum
- PRRB Seeks Input on Appeal Process Changes
- Deadline Near for Hospital 2006 Wage Index Corrections
- GASB Seeks Comments on Standards Implementation
- January Consumer Medical Costs Increase Slightly
- CMS: Medicare Advantage Contracting with Rural and Critical Access Hospitals
- Hospitals Recognize Inevitability of Electronic Health Records
- Quick Links
- Featured in the HFMA Resource Center
1. IRF CRITERIA TRANSMITTAL ADDRESSES STATUS VERIFICATION
CMS has clarified the existing policy on determining whether inpatient rehabilitation facilities (IRFs) meet PPS payment criteria. The transmittal outlines the timing of reviews, the compliance assessment period, the compliance percentage calculations, and any required change of status. Details of the change of status process are also provided. Appendix A to the transmittal lists the ICD-9-CM and impairment group codes from the IRF patient assessment instrument database that will be used to verify compliance with the classification requirements.
CMS regional offices make compliance determinations annually using the most recent, consecutive, and appropriate 12-month time period. However, the threshold for compliance with the criteria (the required percentage of patients that meet one or more of the specified medical conditions) varies by cost reporting period and IRF PPS payment year.
2. CMS TO PROVIDE MEDICARE E-PRESCRIBING FORUM
CMS will host a special Open Door Forum focusing on clarification and discussion of the e-prescribing proposed rule published in the February 4 Federal Register. The purpose of the event is to clarify understanding of the proposed rule, provide an overview of some of the key elements, discuss the timeline for adoption of the e-prescribing standards, and describe a pilot project to test additional standards mandated by the Medicare Modernization Act. The forum will be held on March 1, 2 to 4 p.m. (EST).
3. PRRB SEEKS INPUT ON APPEAL PROCESS CHANGES
The Provider Reimbursement Review Board (PRRB) has developed new instructions for appeals and is seeking provider input on these proposed regulations by April 15. The most significant change proposed is a requirement that providers brief each issue and submit all available supporting documentation to the intermediary at the time of the initial hearing request, according to Christopher Keough, partner at the law firm Vinson & Elkins. Keough says the proposed rules lack any significant sanction to ensure intermediary compliance and would require providers to do a great deal of work prior to the initial filing, due 180 days after receipt of a notice of program reimbursement.
4. DEADLINE NEAR FOR HOSPITAL 2006 WAGE INDEX CORRECTIONS
Supporting documentation for corrections to hospital FY06 Medicare wage index data is due to fiscal intermediaries by March 14, 2005. It is important that hospital financial managers review this data, since the wage index tables in the proposed FY06 inpatient PPS rule will be based on the revised wage index data from February.
CMS is expected to release the revised FY06 wage index public use files (PUFs) today on its web site. Hospitals are asked to review their data for corrections to errors in the February PUFs (due to CMS or FI mishandling of the wage index data) and for revisions of desk review adjustments.
5. GASB SEEKS COMMENTS ON STANDARDS IMPLEMENTATION
The Governmental Accounting Standards Board issued three standards statements in 2004 for which implementation guides are being developed. GASB staff members want to hear about issues that the users of the statements (preparers and auditors) feel should be addressed in the guides. The statements, GASB staff contacts, and response deadlines are:
- No. 43--Financial Reporting for Postemployment Benefit Plans Other Than Pension Plans, Michelle Czerkawski ( mlczerkawski@gasb.org ), March 15
- No. 44--Economic Condition Reporting: The Statistical Section, Dan Mead ( dmmead@gasb.org ), May 31
- No. 45--Accounting and Financial Reporting by Employers for Postemployment Benefits Other Than Pensions, Michelle Czerkawski ( mlczerkawski@gasb.org ), March 15
Feedback from the field is also being sought for the GASB annual update of its Comprehensive Implementation Guide intended to assist in the implementation and ongoing application of a number of GASB pronouncements. Send descriptions of issues to Michelle Czerkawski at mlczerkawski@gasb.org by May 31.
6. JANUARY CONSUMER MEDICAL COSTS INCREASE SLIGHTLY
Consumers' out-of-pocket costs for medical care in January increased 0.4 percent, after increasing 0.3 percent in December 2004, according to U.S. Bureau of Labor Statistics data released Wednesday. By comparison, the January Consumer Price Index for all urban consumers (CPI-U) increased by 0.1 percent, compared with no change in December 2004.
January's medical cost increase reflects a 0.5 percent increase for hospital services, a slight deceleration from the 0.7 percent increase in December 2004. Costs rose by 0.3 percent for drugs and supplies after declining by 0.1 percent in December. Nursing home costs increased by 0.3 percent for the second month in a row, and growth in costs for physician services held steady at 0.1 percent for the second month in a row.
- Regional CPI information is available through the BLS on-line interactive database.
- Get additional current inflation statistics in HFMA's Internet Guide to Healthcare Business Statistics.
- Consumers' out-of-pocket expenses will rise as more people opt for consumer-driven health plans. Learn about the CDHPs' implications for your organization with HFMA's new Spring Seminar, Consumer-Directed Health Plans: The Financial Impact on Hospitals.
7. CMS: MEDICARE ADVANTAGE CONTRACTING WITH RURAL AND CRITICAL ACCESS HOSPITALS
CMS staff answered several questions relating to Medicare Advantage (MA) payments to non-contracting rural health centers (RHCs) and critical access hospitals (CAHs) for covered services at a Rural Health Open Dorr Forum this week. The first question addressed the issue of payment amount. The statute and regulations require MA organizations to pay up to the amount that Medicare fee-for-service (FFS) would have paid, for example, 101 percent of cost for CAHs. The payment equation would be: beneficiary’s MA cost sharing + MA payment = FFS payment + beneficiary cost sharing under FFS. However, providers were cautioned that MA enrollees will have obligations with regard to use of the MA network that could affect the cost sharing amounts.
In addition, CMS staff said that statute prohibits a CAH from also being an essential hospital. A CMS official noted that there is no advantage in such an arrangement, since to the extent a noncontracting CAH treats a beneficiary payable through a regional MA plan, it would receive the same payment amount from the regional MA plan as from Medicare FFS.
Regarding whether there is a financial incentive for an RHC or CAH to contract with a MA PPO, CMS staff said there is the potential for increased utilization, because when there is no contract, the PPO could end up directing the beneficiary to contracting providers.
8. HOSPITALS RECOGNIZE INEVITABILITY OF ELECTRONIC HEALTH RECORDS
More than 60 percent of respondents to the 16th Annual HIMSS Leadership Survey consider the electronic health record as the most important information technology application to be dealt with in the next year, and more than 40 percent already have taken steps toward implementation. Respondents also say their top immediate IT issue, and one EHRs help address, is the reduction of medical errors; however the obvious barrier to the EHR-and all IT initiatives--is the lack of financial support. The survey findings were released February 14, 2005.
9. QUICK LINKS
ADVISORY OPINIONS ON GAINSHARING ARRANGEMENTS. On February 17, the OIG released three additional advisory opinions (05-2, 05-3, and 05-4) addressing gainsharing arrangements in which a hospital and a group of cardiac surgeons would share in savings from a number of cost reduction measures for certain surgical procedures.
2005 AMBULANCE FEE SCHEDULE AND REASONABLE CHARGE PUF UPDATES. CMS published the 2005 updates to the Medicare ambulance fee schedule and ambulance reasonable charge public use. The reasonable charge PUF displays 100 percent of the reasonable charge amount by HCPCS procedure code for each locality and instructs on determining the amount payable during 2005.
TELEHEALTH FACILITY FEE PAYMENT UPDATE. The 2005 telehealth originating site facility fee is $21.86, according to the CMS. The payment update reflects a CY05 Medicare Economic Index increase of 3.1 percent.
10. FEATURED IN THE HFMA RESOURCE CENTER
UPDATED! HFMA’S INTERNET GUIDE TO MEDICARE CODING AND BILLING INSTRUCTIONS. Use this handy billing compliance reference to be sure you are up to date on important Medicare coding and billing instructions.
NEW IN THE FEDERAL REGISTER. HFMA staff comb through the Federal Register daily to post links to relevant notices affecting Medicare, Medicaid, TRICARE, other federal healthcare programs, as well as federal grants announcements. View the most recently published notices, or search for specific effective dates, agencies, or type of notice.
Copyright 2005 Healthcare Financial Management Association, all rights reserved. HFMA Express News ISSN: 1540-0689. Volume XII, Number 8.
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