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CMS

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The Centers for Medicare and Medicaid Services (CMS) released the fiscal year (FY) 2025 hospital inpatient prospective payment system (IPPS) proposed rule. While the proposed rule is focused primarily on provisions specific to acute care hospitals and long-term care hospitals (LTCH), the rule includes a proposed mandatory model — the Transforming Episode Accountability Model (TEAM) — that would implement episode-based payments for five procedures: lower extremity joint replacement, surgical hip femur fracture treatment, spinal fusion, coronary artery bypass graft, and major bowel procedure.

Under the proposed program, selected acute care hospitals would coordinate care for fee-for-service (FFS) beneficiaries who undergo one of the listed procedures and assume responsibility for the cost and quality of care through the first 30 days after the Medicare beneficiary leaves the hospital. Hospitals required to participate would continue to bill Medicare FFS but would receive a target price based on all non-excluded Medicare Parts A & B items and services included in an episode; inpatient rehabilitation facility (IRF) care is listed among these covered services. Hospitals may earn a payment from CMS, subject to a quality performance adjustment, if their spending is below the target price (additionally, hospitals could owe CMS a repayment amount, subject to a quality performance adjustment, if their spending was above the target price). Hospitals will face a “graduated risk” scale through different participation tracks to allow participants to ease into full-risk participation.

Per CMS, the program aims to incentivize coordination between care providers during surgery, as well as the services provided during the 30 days that follow, and require referral to primary care services to support continuity of care. CMS notes that TEAM hospitals may “want to engage in financial arrangements with providers and suppliers or participants in Medicare Accountable Care Organization (ACO) initiatives who are making contributions to the TEAM participant’s performance in the model,” and TEAM hospitals could share reconciliation payment amounts or repayment amounts with these individuals and entities. IRFs are listed among the potential “TEAM Collaborators” by CMS. Comments are encouraged on both the proposed definition of a TEAM collaborator and their role in the model.

There are several other provisions notable for IRFs, including the fact that CMS is proposing to require that TEAM hospitals “must, as part of discharge planning, account for potential financial bias by providing TEAM beneficiaries with a complete list of all available post-acute care options in the Medicare program, including home health agencies (HHA), skilled nursing facilities (SNF), IRFs, or LTCHs, in the service area consistent with medical need, including beneficiary cost-sharing and quality information (where available and when applicable).” The list must also indicate whether the TEAM participant has a sharing arrangement with the post-acute care provider.

The model would begin in 2026 and run for five years and is intended to build on other episode-based models, such as the Bundled Payments for Care Improvement Advanced and Comprehensive Care for Joint Replacement Models. Like with other Center for Medicare and Medicaid Innovation (CMMI) programs, CMS will assess whether the model would reduce Medicare spending while maintaining or improving the quality of care.

The proposed rule will be published in the May 2, 2024, Federal Register and will be open for public comments.

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The Centers for Medicare and Medicaid Services (CMS) has announced two days of interactive training webinars that will cover Medicare basics. The webinars will be offered on April 16 and 17, 2024, from 1:00 pm – 3:30 pm. Attendees can attend one or both days, and space is limited. CEUs will not be offered. The topics for the webinars include:

Day 1 — Medicare enrollment and eligibility; SSA and CMS roles and responsibilities; cost and coverage under Medicare Part A (Hospital Insurance) and Medicare Part B (Medical Insurance); why enrolling on time is important; and an overview of Medicare Supplement Insurance (Medigap) policies.

Day 2 — Medicare drug coverage (Part D); Medicare Advantage Plans; coordination of benefits; how to detect and report suspected Medicare fraud, waste, and abuse; and different resources to help you find answers to Medicare policy and coverage questions.

To register for these events, visit the CMS National Training Program website. The webinars will be recorded and posted to the NTP website. To view the recordings, visit here.

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The Centers for Medicare and Medicaid Services (CMS) has released the fiscal year (FY) 2025 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule. The proposed rule will be published in the March 29, 2024, Federal Register. A high-level overview of the proposed rule is provided below:

Payment Updates:

CMS estimates an overall increase in aggregate payments to IRFs by 2.5% or $255 million (compared to the 4% payment update in FY 2024).

Market basket update for IRF services is 3.2%. This will be reduced by a productivity adjustment of 0.4%, which would result in an overall 2.8% increase. These figures are likely to change due to updated forecasts.

CMS is proposing to update the outlier threshold amount from $10,423 (FY 2024) to $12,158 (FY 2025), which would account for an estimated 0.2 percent decrease to aggregate payments across the IRF PPS in FY 2025.

Quality Reporting Program (QRP) Updates:

CMS is proposing to make additions, modifications, and removals of some QRP measures. A proposal was included to collect four new Standardized Patient Assessment Data Elements (SPADE) in the IRF QRP to bolster the collection of information on social determinants of health (SDOH):

  • Living Situation: Requests regarding the current living situation;
  • 2 Food Items: Questions about food running out;
  • Utilities: Questions about threats to shutting off utilities; and
  • A modification to an existing SPADE on Transportation.

CMS is also proposing to remove the “Admission Class” from the IRF Patient Assessment Instrument (PAI).

Feedback is requested on future revisions to the IRF QRP, as well as feedback on the development of a five-star methodology for IRFs.

Additional information will be forthcoming. Comments on the proposed rule are due to CMS by the end of May.

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The next phase of the Centers for Medicare and Medicaid Services (CMS) inpatient rehabilitation facility (IRF) review choice demonstration (RCD) is scheduled to be implemented in Pennsylvania on June 17, 2024, and will last for five years. This demonstration applies to only IRF providers physically located in Pennsylvania.

Between May 3, 2024, and June 2, 2024, IRFs must select either 100% pre-claim review or 100% post-payment claim review.

CMS has stated that creating a review choice process will ensure Medicare coverage and documentation requirements are likely met. This program reduces the number of Medicare appeals, improves provider compliance with Medicare program rules, does not alter the Medicare IRF benefit, and should not delay medically necessary care to Medicare beneficiaries.

Novitas Solutions is the Medicare Administrative Contractor (MAC) for Pennsylvania and will process the IRF claims. In preparation for the implementation of IRF RCD, Novitas Solutions will be conducting their first webinar on April 24, 2024, from 1:00 pm – 2:30 pm. Registration to participate in this webinar is now open. Members are strongly encouraged to participate in this webinar to prepare for this demonstration. If the registration link does not work, please copy and paste the below link into your browser to register:
https://fcso.webex.com/webappng/sites/fcso/meeting/register/0fd87e2111f7446fa477d0a25f78674c?ticket=4832534b000000073a942d9e6f94601b6b106adc8f502bcee359653432e8c326edb0f50ebc253329&timestamp=1711559626291&RGID=re6663754d2fe70defe3195e29c69465a

In addition to information on the CMS website, Novitas Solutions has a dedicated website that provides a great deal of information and resources on IRF RCD.

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The Office of Developmental Programs (ODP) has shared ODPANN 24-031, which informs all interested stakeholders of the submission of the Consolidated, Community Living, Person/Family Directed Support (P/FDS), and Adult Autism Waiver (AAW) amendments that contain Workforce Recovery Supplemental Payments to CMS and provides guidance for requesting these payments. The submitted waiver amendments are available on the Department of Human Services website.

Please view the announcement for information and details, and note that providers are required to complete ODP’s survey to request these payments.

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Message from The Centers for Medicare & Medicaid Services (CMS):

The Centers for Medicare & Medicaid Services (CMS) is continuing to monitor and assess the impact that the cyberattack on UnitedHealth Group’s subsidiary Change Healthcare has had on all provider and supplier types. Today, CMS is announcing that, in addition to considering applications for accelerated payments for Medicare Part A providers, we will also be considering applications for advance payments for Part B suppliers.

Over the last few days, we have continued to meet with health plans, providers and suppliers to hear about their most pressing concerns. As announced previously, we have directed our Medicare Administrative Contractors (MAC) to expedite actions needed for providers and suppliers to change the clearinghouse they use and to accept paper claims if providers need to use that method. We will continue to respond to provider and supplier inquiries regarding MAC processes.

CMS also recognizes that many Medicaid providers are deeply affected by the impact of the cyberattack. We are continuing to work closely with States and are urging Medicaid managed care plans to make prospective payments to impacted providers, as well.

All MACs will provide public information on how to submit a request for a Medicare accelerated or advance payment on their websites as early as today, Saturday, March 9.

CMS looks forward to continuing to support the provider community during this difficult situation. All affected providers should reach out to health plans and other payers for assistance with the disruption. CMS has encouraged Medicare Advantage (MA) organizations to offer advance funding to providers affected by this cyberattack. The rules governing CMS’s payments to MA organizations and Part D sponsors remain unchanged. Please note that nothing in this statement speaks to the arrangements between MA organizations or Part D sponsors and their contracted providers or facilities.

If you have any questions, please contact Fady Sahhar.

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As noted in a previous alert from the Department of Human Services (DHS), the Department of Health and Human Services (HHS) has also been providing updates regarding the recent cybersecurity incident that impacted Change Healthcare (a unit of UnitedHealth Group). HHS has noted that their first priority is to help coordinate efforts to avoid disruptions to care throughout the health care system.

On March 5, 2024, HHS announced immediate steps that the Centers for Medicare and Medicaid Services (CMS) is taking to assist providers to continue to serve patients. CMS will continue to communicate with the health care community and assist, as appropriate. Providers should continue to work with all their payers for the latest updates on how to receive timely payments.

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