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2021: Policies Affecting Hospital Revenue Integrity Programs

With a new administration in Washington DC and CMS moving deadlines for MIPS applications, winter looks like a prime time for strategizing on hospital revenue integrity programs.

Provider Relief Fund: Writing for JDSupra, the law firm of Holland and Knight take a look at some of the changes in the Biden administration that will impact hospitals. In addition to pandemic response funds, major healthcare items in Biden’s package will include more funding (and perhaps more distribution rules) for the provider relief fund; addressing vaccine administration costs; and increasing to 12 percent the Federal Medicaid Assistance Percentages (FMAP) for the duration of the pandemic public health emergency to incentivize states that have not yet expanded under the Affordable Care Act (ACA).

In the same article, the editors make the following predictions for policies coming later this year: “Other major items that could see action include further mitigation of the Medicare Physician Fee Schedule (MPFS) cuts to procedural services; a variety of other changes to Medicaid and Medicare (including supplemental payment programs); changes to the 340B program in response to some manufacturers not recognizing contract pharmacies as covered entities; significant drug pricing reforms, including Medicare negotiation and Part D inflation-based rebates; and legislation to expand the use of telehealth post-pandemic as well as increase broadband access.”

Meanwhile, at the Department of Health and Human Services (HHS) CARES Act Provider Relief Fund overview page, we learn that the Provider Relief Fund supports American families, workers, and the heroic healthcare providers in the battle against the COVID-19 outbreak. HHS is distributing $178 billion to hospitals and healthcare providers on the front lines of the coronavirus response. See this checklist for Phase 3 General Distribution.

Appeals Court Clears Hospital Transparency Rule to Go Into Effect Jan. 1 [also from JDSupra]:  On December 29th, the U.S. Court of Appeals for the District of Columbia Circuit ruled that the Department of Health and Human Services (HHS) could move forward with its hospital price transparency rule on Jan. 1, 2021. The final rule requires hospitals to make public their standard charges for all items and services, including their gross charges and payer-specific negotiated charges. Hospitals will need to provide price transparency through a comprehensive machine-readable file with all items and services and a display of 300 shoppable services in a consumer-friendly format. The American Hospital Association is urging the incoming Biden administration not to enforce the rule for the duration of the COVID-19 public health emergency and to revise the rule.

CMS – Applications for MIPS Exceptions Due to COVID-19 Now Due Feb. 1: On December 17th, the Centers for Medicare and Medicaid Services (CMS) pushed back the deadline to February 1st for doctors to apply for extreme and uncontrollable circumstances exceptions from the Merit-based Incentive Payment System (MIPS). CMS is reminding providers that that process can include a request to leave out one or more performance categories from their score due to the COVID-19 pandemic. However, the hardship application for the interoperability category had a December 31st deadline. You can review the CMS MIPS Exceptions page here

What other MIPS considerations do you have for 2021? Your hospitalists might like to take a look at the Society for Hospital Medicine, MIPS Guide for Hospitalists

The American Hospital Association (AHA) page about MIPS explains that, “The quality payment program (QPP) creates new quality measurement and reporting requirements for eligible clinicians and the hospitals with whom they partner. However, the QPP’s payment implications will vary depending on a number of scenarios – such as whether a clinician is attributed to the Merit-Based Incentive Payment System (MIPS); to a MIPS alternative payment model (APM); or to an advanced APM.” The AHA has also prepared a PDF overview guide here.  

Still more related hospital guidance resources from CMS include: Toolkits, recommendations, and other resources for hospitals and hospital administrators to improve quality, reduce errors, and increase patient safety.

We will keep you posted on policies affecting hospital revenue integrity programs throughout the year.

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