Human Resources: Request for Information
rfi
CMS Releases RFI on Establishing National Directory of Health Care Providers/Services
The Centers for Medicare and Medicaid Services (CMS) released a Request for Information (RFI) that seeks public input on the concept of establishing a National Directory of Healthcare Providers and Services (NDH) that could serve as a centralized data hub for health care provider, facility, and entity directory information nationwide. The goal of this directory is to improve access to care, reduce clinician burden, and support interoperability throughout the health care sector.
CMS is seeking comment on how a CMS-led directory could reduce directory maintenance burden on providers and payers by creating a single, centralized system, promoting real-time accuracy for patients.
Feedback obtained in response to the RFI will aid CMS’ understanding of the current landscape of health care directories, as well as information useful to CMS when considering an NDH. CMS is specifically requesting public feedback on the NDH concept and potential benefits, provider types, entities and data elements that could be included to create value for the health care industry, the technical framework for an NDH, priorities for a possible phased implementation, and prerequisites and actions CMS should consider taking to address potential challenges and risks.
The RFI will be published in the Federal Register on October 7, 2022. Comments on the RFI will be accepted through December 6, 2022.
CMS Releases RFI Seeking Public Input on Accessing Healthcare & Related Challenges
The Centers for Medicare and Medicaid Services (CMS) has released a Request for Information (RFI) that seeks public input on accessing healthcare and related challenges, understanding provider experiences, advancing health equity, and assessing the impact of waivers and flexibilities provided in response to the COVID-19 Public Health Emergency (PHE).
The Make Your Voice Heard: Promoting Efficiency and Equity Within CMS Programs RFI furthers CMS’ commitment to engaging and learning from partners, communities, and individuals across the health system to inform how we can better support the populations we serve. In alignment with Executive Order 13985, Advancing Racial Equity and Support for Underserved Communities Through the Federal Government, the CMS Strategic Plan Pillar: Health Equity, and the CMS Framework for Health Equity (2022–2032), this RFI aims to gather feedback and perspectives related to challenges and opportunities for CMS to embed health equity into their efforts encouraging innovation, reducing burden, and creating efficiencies across the healthcare system.
CMS is seeking to better understand individual and community-level burdens, health-related social needs, and opportunities for improvement that can reduce disparities and promote efficiency and innovation across programs. CMS is requesting information related to strategies that successfully address drivers of health inequities, including opportunities to address social determinants of health and challenges underserved communities face in accessing comprehensive, quality care. For example, challenges accessing care may include understanding coverage options, receiving culturally and linguistically appropriate care, accessing oral health services, and accessing comprehensive and timely healthcare services and medication.
Through this RFI, CMS also seeks to better understand the factors impacting provider wellness and learn more about the distribution of the healthcare workforce. CMS is particularly interested in understanding the greatest challenges for healthcare workers in meeting the needs of individuals, and the impact of CMS policies, documentation, and reporting requirements, operations, and communications on provider experiences.
Comments received in response to the Make Your Voice Heard RFI will be used to identify opportunities for improvement and to increase efficiencies across CMS programs. In addition, CMS hopes to learn how specific programs have benefited providers, practices, and the people served.
CMS encourages comments from all interested stakeholders, in particular, patients and their families, providers, clinicians, consumer advocates, and healthcare professional associations. CMS also encourages comments from individuals serving and located in underserved communities and from all CMS stakeholders serving populations facing disparities in health and healthcare. The RFI is open for a 60-day public comment period.
Comments must be received by November 4, 2022, to be considered.
CMS Releases RFI Seeking Public Comments on Medicare Advantage Program
The Centers for Medicare and Medicaid Services (CMS) recently released a Request for Information (RFI) requesting public comments on the Medicare Advantage program. CMS is asking for input on ways to achieve the agency’s vision so that all parts of Medicare are working towards a future where people with Medicare receive more equitable, high quality, and person-centered care that is affordable and sustainable, essentially asking for ways to strengthen this program.
CMS’s intent is to better align the Medical Assistance (MA) program with the agency’s vision for Medicare and the CMS Strategic Pillars. CMS is strongly emphasizing the importance of stakeholder comments for this process. This openness to feedback presents MA plans, providers, and other stakeholders an opportunity to inform the agency’s early thinking as it considers potential regulatory actions impacting supplemental benefits, value-based contracting arrangements, risk adjustment, prior authorization, and marketing among other issues.
CMS will accept comments on the RFI until August 31, 2022.
Office of Vocational Rehabilitation Issues RFI in Preparation for Grant Application
The Department of Labor and Industry’s Office of Vocational Rehabilitation (OVR) is issuing a Request for Information (RFI) to seek input from its stakeholders as it prepares to apply to the Rehabilitation Services Administration for a competitive discretionary grant through the Consolidated Appropriations Act, 2021 (Pub. L. 116-260).
The grants are intended to support innovative activities aimed at increasing Competitive Integrated Employment (CIE). The priority of the grant is the “Subminimum Wage to Competitive Integrated Employment (SWTCIE) Innovative Model Demonstration Project.”
Details on submitting responses for the RFI can be viewed here.
CMS Hospital/Quality Initiative Open Door Scheduled for April 26
The Centers for Medicare and Medicaid Services (CMS) recently announced the next Hospital/Quality Initiative open door forum has been scheduled for April 26, 2022, from 2:00 pm – 3:00 pm. Agenda topics that will be covered during this open door forum include:
- Fiscal Year (FY) 2023 Inpatient/Long-Term Care Prospective Payment System (IPPS/LTC PPS) Proposed Rule
- Hospital Quality Updates:
- Background/Context on Health Equity and Maternal Health
- Inpatient Quality Reporting (IQR) Program
- Equity and Maternal Health Measures
- Other IQR Measures and eCQM Reporting Requirements
- Hospital Designation on Maternal Care
- Requests for Information (RFIs) Re: Health Equity and Maternal Health
- Measure Suppressions Due to the Impact of the COVID-19 Pandemic
- Promoting Interoperability Program and Advancing Trusted Exchange Framework and Common Agreement (TEFCA) RFI
- Hospitals and Critical Access Hospital (CAH) Conditions of Participation (CoPs) – Required COVID-19 Reporting Until December 2024, and Reporting in Future Public Health Emergencies (PHEs)
- IPPS and Long-Term Care Hospital (LTCH) Update
- RFI on Resource Costs for N95 Masks
- Hospital Quality Updates:
- IPPS Wage Index Timeline Update
There will also be an open question and answer (Q&A) session included during the hour. This call will be a conference call only.
To participate by phone:
Dial: 888-455-1397 & Reference Conference Passcode: 5109694
Instant Replay: 866-416-1185, Conference ID: No Passcode Needed
Instant Replay is an audio recording of this call that can be accessed by dialing 866-416-1185 beginning 1 hour after the call has ended. The recording expires after April 28, 2022.
CMS Releases IRF PPS Proposed Rule for FY 2023
On March 31, 2022, the Centers for Medicare and Medicaid Services (CMS) released the fiscal year (FY) 2023 inpatient rehabilitation facility prospective payment system (IRF PPS) proposed rule.
Some of the key provisions contained in this proposed rule include:
Proposed Updates to the FY 2023 IRF PPS Payment Policies
CMS is proposing to update the IRF PPS payment rates by 2.8 percent based on the IRF market basket update of 3.2 percent less than a 0.4 percentage point productivity adjustment. CMS is proposing that if more recent data becomes available (for example, a more recent estimate of the market basket update or productivity adjustment), they would use this data, if appropriate, to determine the FY 2023 market basket update and the productivity adjustment in the final rule. In addition, the proposed rule contains an adjustment to the outlier threshold to maintain outlier payments at 3.0 percent of total payments. This adjustment will result in a 0.8 percentage point decrease in outlier payments. The estimated overall IRF payments for FY 2023 would increase by 2.0 percent (or $170 million), relative to payments in FY 2022.
Proposed Permanent Cap on Wage Index Decreases
CMS is proposing a permanent 5 percent cap on annual wage index decreases to smooth year-to-year changes in providers’ wage index payments.
Soliciting Comments on the Office of Inspector General (OIG) Recommendation to Include Home Health in the IRF Transfer Policy
A recent Office of Inspector General (OIG) report that evaluated early discharges from IRFs to home health recommended that CMS expand the IRF transfer payment policy to apply to early discharges to home health. CMS is requesting feedback from stakeholders about potentially including home health in the IRF transfer payment policy, as recommended by OIG. CMS plans to analyze home health claims to determine the appropriateness of including home health in the IRF transfer policy, and is seeking comments to inform this future analysis and any potential future rulemaking.
Soliciting Comments on the Methodology for Updating the Facility-Level Adjustment Factors
CMS is seeking public comments regarding the methodology used to determine the facility-level adjustment factors and suggestions for what may be driving the variability in the IRF teaching status adjustment factor.
IRF Teaching Status Adjustment Policy
CMS is proposing to codify the longstanding IRF teaching status adjustment policy in regulation and clarify certain teaching status adjustment policies.
Proposed Updates to the IRF Quality Reporting Program (QRP)
The IRF QRP is a pay-for-reporting program. IRFs that do not meet reporting requirements are subject to a 2.0 percentage point reduction in their Annual Increase Factor (AIF). CMS is proposing one policy change and is initiating three Requests for Information (RFIs) related to the IRF QRP.
Quality Data Reporting on All IRF Patients Regardless of Payer
CMS is proposing to expand the IRF qualify data reporting requirements, which currently apply to all admitted IRF patients with Medicare Part A fee-for-service (FFS) and Medicare Part C, such that IRFs would begin collecting data on all IRF patients, regardless of payer. This policy proposal would help to ensure all IRF patients are receiving the same quality of care and that provider metrics reflect performance across the spectrum of IRF patients. CMS is proposing that this expanded quality reporting requirement would take effect starting with the FY 2025 IRF QRP, meaning providers would need to start collecting the IRF-Patient Assessment Instrument (PAI) assessment on all patients receiving care in an IRF, regardless of payer, beginning on October 1, 2023.
Inclusion of the National Healthcare Safety Network (NHSN) Healthcare-Associated Clostridioides difficile (C. difficile) Infection Outcome Measure in the IRF QRP — Request for Information (RFI)
CMS is seeking stakeholder feedback on the future inclusion of the National Healthcare Safety Network (NHSN) Healthcare-associated Clostridioides difficile Infection (HA-CDI) Outcome Measure as a digital quality measure in the IRF QRP. This measure tracks the development of new C. difficile infection among patients already admitted to IRFs, using algorithmic determinations from data sources widely available in electronic health records. This measure improves on the existing NHSN Facility-wide Inpatient Hospital-onset Clostridium difficile Infection (CDI) Outcome Measure (NQF #1717) by requiring both microbiologic evidence of C. difficile in stool and evidence of antimicrobial treatment. Through this RFI, CMS would like to assess the feasibility of this digital measure in IRFs. If this type of measure is proposed and finalized in a future rule, this would be the first digital measure in the IRF QRP.
Overarching Principles for Measuring Equity and Healthcare Quality Disparities Across CMS Quality Programs — Request for Information (RFI)
CMS is committed to achieving equity in health care outcomes for beneficiaries. In this RFI, CMS provides an update on the equity work that is occurring across CMS. Included are: plans to expand the quality reporting programs to allow CMS to provide more actionable, comprehensive information on health care disparities; measuring health care disparities through quality measurement and reporting these results to providers; and providing an update on our methods and research around measure development and disparity reporting.
The proposed rule will be published in the April 6 Federal Register. Comments on the proposed rule are due by May 31, 2022.
OLTL’s Agency With Choice RFI Released
The Office of Long-Term Living (OLTL) recently released the Request for Information (RFI) to gather feedback regarding the implementation of Agency With Choice (AWC) services for the participants of Medical Assistance (MA) managed care programs, the 1915(c) MA home and community-based services (HCBS) waiver program, and a state-funded program.
Through these programs, eligible participants receive long-term services and supports (LTSS) and other benefits, depending on the particular program. Specifically, this RFI seeks information to assist OLTL in determining how it may improve options for LTSS participants to self-direct their services in the Community HealthChoices Program (CHC), OBRA Waiver, and the state-funded Act 150 Attendant Care Program through the procurement and implementation of AWC.
Through this RFI, OLTL is seeking to become more aware of and knowledgeable about current efforts to increase opportunities for self-direction and feedback on the implementation of AWC through a potential, future procurement. OLTL encourages interested parties, including vendors and stakeholders, to provide feedback in response to this RFI or any part of it. An interested party may respond to all or any of the specific questions or topics included in this RFI.
RFI responses are due by12:00 pm on March 25, 2022. Responses must be submitted electronically with “OLTL Agency With Choice RFI” in the email subject line. While OLTL does not intend to respond to questions or clarifications during the RFI response period, interested parties and individuals may submit administrative questions related to this RFI electronically using “OLTL Agency With Choice” in the email subject line. OLTL may or may not respond based on the nature of the question.
CMS Issues RFI on Prior Authorization for Hospital Transfers to PAC Settings During PHE
In today’s Federal Register, the Centers for Medicare and Medicaid Services (CMS) published a proposed rule that included updates to the Medicare Advantage program. Contained within this proposed rule is a Request for Information (RFI): Prior Authorization for Hospital Transfers to Post-Acute Care (PAC) Settings During a Public Health Emergency (PHE). The RFI highlights several concerns, including the fact that providers often wait up to three days for authorization determinations, and that a high rate of MA requests are initially denied, all of which hinder the ability of hospitals to maximize capacity during a public health emergency (PHE). The RFI requests several areas for feedback, including the overall impact of prior authorization on hospitals and patient care, the denial rates and associated burden on providers, and the consequences of delayed patient transfers.
Members are encouraged to share any direct examples of these prior authorization issues with Melissa Dehoff, Director, Rehabilitation Services Division. In addition, this issue will be discussed during the upcoming Outpatient Rehabilitation Committee and Medical Rehabilitation Committee meetings.
CMS Extends RFI on New Provisions in MACRA
In the October 1, 2015 Federal Register, the Centers for Medicare and Medicaid Services (CMS) released a Request for Information (RFI) to seek public comment related to new provisions in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). This is for the design of the new Medicare physician payment system that will replace the Sustainable Growth Rate (SGR) formula, which includes the merit-based incentive payment system, alternative payment models, and a physician-focused payment model. Originally, comments were due by November 2, 2015; however, an extension of the comment period for an additional 15 days was published in the October 20, 2015 Federal Register, indicating the new due date as Tuesday, November 17, 2015.
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