ParaRev Weekly eJournal, April 19, 2023

CMSPROPOSES POLICIESON PATIENTSAFETY AND HEALTH EQUITY

Proposed Rule Would Reward Hospitals that Deliver High-Quality Care to Underserved Populations

The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule for inpatient and long-term care hospitals that builds on the Biden-Harris Administration?s key priorities to advance health equity and support underserved communities.

As required by statute, the fiscal year (FY) 2024 inpatient prospective payment system (IPPS) and long-term care hospital prospective payment system (LTCH PPS) rule updates Medicare payments and policies for hospitals The rule would also adopt hospital quality measures to foster safety, equity, and reduce preventable harm in the hospital setting

CMSis proposing to recognize homelessness as an indicator of increased resource utilization in the acute inpatient hospital setting, which may result in higher payment for certain hospital stays. This action aligns with the Administration?s goal of providing support to historically underserved and under-resourced communities

?CMSis helping to build a resilient health care system that promotes good outcomes, patient safety, equity, and accessibility for everyone,?said CMSAdministrator Chiquita Brooks-LaSure

?This proposed rule reflects our person-centric approach to better measure health care quality and safety in hospitals to reduce preventable harm and our commitment to ensure that people with Medicare in rural and underserved areas have improved access to high-quality health care.?

For acute care hospitals paid under the IPPSthat successfully participate in the Hospital Inpatient Quality Reporting program and are meaningful electronic health record users, the proposed increase in operating payment rates for FY2024 is projected to be 2 8% This reflects an FY2024 projected hospital market basket update of 3.0%, reduced by a projected 0 2 percentage point productivity adjustment For FY2024, CMSexpects the proposed increase in operating and capital IPPSpayment rates would generally increase hospital payments by $3.3 billion. For LTCHs, CMSproposes to increase the LTCH PPSstandard Federal payment rate by 2 9%

Overall, CMSexpects LTCH payments under the dual-rate payment system to decrease by 0 9%, or $24 million, primarily due to a projected decrease in high-cost outlier payments in FY2024 compared to FY2023.

CMSPROPOSES POLICIESON PATIENTSAFETY AND HEALTH EQUITY

?With this proposed rule, CMSis more accurately paying hospitals and recognizing for the first time that homelessness, as a social determinant of health, also impacts resource utilization,? said CMSDeputy Administrator Dr Meena Seshamani

?Creating incentives for hospitals to provide excellent care for underserved populations lays the foundation for a health system that delivers higher-quality, more equitable, and safer care for everyone.?

Advancing Health Equity

CMSis proposing to make health equity adjustments in the Hospital Value-Based Purchasing Program by providing incentives to hospitals to perform well on existing measures and to those who care for high proportions of underserved individuals, as defined by dual eligibility status

This builds on previous efforts to advance health equity through the finalized health equity adjustment in the Medicare Shared Savings Program and finalized policies in Medicare Advantage and Part D Star Ratings Program. CMSalso proposes to recognize the higher costs that hospitals incur when treating people experiencing homelessness, when hospitals report social determinants of health codes on claims. In addition, CMSis requesting comment on how to further support safety-net hospitals

CMSis also proposing that rural emergency hospitals could be designated as graduate medical education training sites As a result, more medical residents would be able to train in rural settings, which can help address workforce shortages in these communities. This proposal builds on other policies to support access to care in rural and other underserved communities.

Promoting Patient Safety

Consistent with the CMSNational Quality Strategy and theHHSNational Healthcare System Action Alliance to Advance Patient Safety goals to promote the highest quality outcomes and safest care for all individuals, the proposed set of quality measures aims to foster safety and equity and to reduce preventable harm in hospital settings. Among this set is a proposal to measure the rate of patients and residents in long-term care hospitals who are up to date on their COVID-19 vaccinations and new, additional measures for screenings for cancer and social drivers of health

The FY2024 IPPS/LTCH PPSproposed rule has a 60-day comment period. The proposed rule can be downloaded from the Federal Register at: https://www.federalregister.gov/public-inspection/2023-07389/medicare-program-proposedhospital-inpatient-prospective-payment-systems-for-acute-care-hospitals

On Monday, April 10, 2023, President Biden signed a bill passed through Congress that ended the COVID-19 National Emergency, but it did not end the Public Health Emergency

The PHEwill end as planned on May 11, 2023

Biden?s signature enacted Public LawNo 118-3 on April 10, 2023:

https://www.congress.gov/bill/118th-congress/house-joint-resolution/7/text

Resolved bytheSenateand Houseof Representativesof theUnited Statesof America in Congress assembled, That, pursuant to section 202 of the National Emergencies Act (50 U SC 1622), the national emergency declared by the finding of the President on March 13, 2020, in Proclamation 9994 (85 Fed. Reg. 15337) is hereby terminated.

CMSissued a statement on its ?Current Emergencies?website which reiterates that the PHEwill end as planned on May 11, 2023:

https://www cms gov/about-cms/agency-information/emergency/epro/current-emergencies /current-emergencies-page

CorroHealt h rem inds our readers t hat Medicare Adm inist rat ive Cont ract or Nat ional Governm ent Services (NGS) has m any upcom ing t raining sessions, free of cost , for Part A and Part B providers.

https://www.ngsmedicare.com/web/ngs/events?lob=96664&state=97244&rgion=93624

Topics Available bet w een April 10 t o April 21, 2023:

Part A

- Submitting Revalidation via CMS-855A Paper Application for Pt A Providers

- Counseling to Prevent Tobacco Use

- Over-the-Counter COVID-19 Tests

- Let?s Chat About Provider Enrollment Revalidation

- PECOS: Manage Signatures and Additional Information Requests

- Let?s Chat about Medicare Secondary Payer for Part A Providers

Part B

-

Part B Appeals, Clerical Error Reopenings, ADRs and Prior Auth Requests

- Submitting Revalidation via CMS-855I Paper Application for Pt B Providers

- Introduction to Medicare Part I and II

- End of the PHEand Billing Telehealth Services

- NCCI Edits

- How to Avoid Duplicate Claims

NGSalso offers computer-based training through its Medicare University portal. To access these sessions, you must register and create a login. Once logged in, registrars have access to hundreds of courses

According to an MLN Fact Sheet published in December, 2022, Medicare will require all 340(B) entities, including Critical Access Hospitals, which submit claims for separately payable Part B drugs and biologicals to report modifier ?JG?or ?TB?on claim lines for drugs acquired through the 340(B) discount program.

The MLN is available at the following website:

www cms gov/files/document/mln4800856-medicare-part-b-inflation-rebate-guidance-use340b-modifier pdf

ALL FACILITIESREQUIRED TO REPORT340B MODIFIERSIN 2024

This is a substantial change from the original 340B billing requirement Previously, Critical Access Hospitals and Maryland All-Payer or Total Cost of Care Model hospitals were not required to report a modifier on 340(B) drugs. CMSissued a companion ?FAQ?document which reiterates this point:

https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/HospitalOutpatientPPS/ Downloads/Billing-340B-Modifiers-under-Hospital-OPPS.pdf

ALL FACILITIESREQUIRED TO REPORT340B MODIFIERSIN 2024

The FAQ document provides a table summarizing the requirement for affected provider types:

The modifier requirement does not apply to all drugs purchased under 340(B), although hospitals may opt to report the modifier for all 340B drugs. The obligation to append a modifier applies to only Part B drugs and biologicals assigned OPPSStatus Indicator G or K(?separately payable?under OPPS.)

PARA Dat a Edit or users may identify the line items within the hospital charge master which are separately payable drugs by navigating to the ?Filters?tab, clicking the checkbox next to ?Status Indicator?, and clicking on both status G and status K, as illustrated below:

PARA invit es you t o check out t he m lnconnect s page available from t he Cent ers For Medicare and Medicaid (CMS). It 's chock full of new s and inform at ion, t raining opport unit ies, event s and m ore! Each w eek PARA w ill bring you t he lat est new s and links t o available resources. Click each link for t he PDF!

Thursday, April 13, 2023

New s

- COVID-19: End of Public Health Emergency

- CMSRoundup (Apr. 07, 2023)

- Medicare Shared Savings Program: Application Toolkit Materials

- Inpatient Rehabilitation Facility Interdisciplinary Team Meetings After the COVID-19 Public Health Emergency

- Hospital Outpatient Departments: Prior Authorization for Facet Joint Interventions Starts July 1

-

Opioid Treatment Program Webpage Updates

Claim s, Pricers, & Codes

- Home Health Original Claims: Don? t Include Cross-Reference Document Control Numbers

-

Outpatient Rehabilitation Claims with Reason Code W7072: You Might

Need to Resubmit Claims

Event s

-

IRIS: XML Format & Duplicate Interns and Residents Full-Time Equivalents

t r ans mit t al s

Therew ereFOUR new or revised Transmittalsreleased thisw eek.

To go to thefull Transmittal document simply click on thescreen shot or thelink.

TRANSMITTAL R11912OTN

TRANSMITTAL R11941CP

TRANSMITTAL R11951OTN

TRANSMITTAL R11949PI

TRANSMITTAL R11948MPI

TRANSMITTAL R2P248I

TRANSMITTAL R11954OTN

1 m edl ear ns

Therew asONEnew or revised MedLearnsreleased thisw eek.

To go to thefull Transmittal document simply click on thescreen shot or thelink.

Theprecedingmaterialsare for instructional purposesonly. Theinformation ispresented "as-is"and to the best of ParaRev?s knowledgeisaccurate at thetime of distribution. However, dueto theever changing legal/regulatorylandscapethisinformation issubject to modification, asstatutes/laws/regulationsor other updatesbecomeavailable.

Nothingherein constitutes, isintended to constitute, or should berelied on as, legal advice ParaRev expressly disclaimsanyresponsibilityfor anydirect or consequential damagesrelated in anywayto anythingcontained in thematerials, which areprovided on an ?as-is?basisand should beindependentlyverified beforebeing applied.

You expresslyaccept and agree to thisabsoluteand unqualified disclaimer of liability.Theinformation in this document isconfidential and proprietaryto ParaRev and isintended onlyfor thenamed recipient. No part of thisdocument maybereproduced or distributed without expresspermission. Permission to reproduce or transmit in anyform or byanymeanselectronicor mechanical, includingpresenting, photocopying, recording and broadcasting, or byanyinformation storageand retrieval system must be obtained in writingfrom ParaRev. Request for permission should be directed to sales@pararevenue.com.

ParaRev is excited to announce we have joined industry leader CorroHealt h to enhance the reach of our offerings! ParaRev services lines are additive in nature strengthening CorroHealt h?s impact to clients?revenue cycle. In addition, you now have access to a robust set of mid-cycle tools and solutions from CorroHealt h that complement ParaRev offerings

In terms of the impact you?ll see, there will be no change to the management or services we provide The shared passion, philosophy and cultures of our organizations makes this exciting news for our team and you, our clients

While you can review the CorroHealt h site HERE, we can coordinate a deeper dive into any of these solutions Simply let us know and we?ll set up a meeting to connect.

As always, we are available to answer any questions you may have regarding this news We thank you for your continued partnership