MiraMed Global Services Podcast

Today's podcast takes a closer look at the just released 2022 Hospital Outpatient Prospective Payment System (OPPS) and ASC Payment System Final Rule (FR). Take a listen! 

​There's no doubt about it: Nicholas Cage is one of America's finest actors. In fact, he is so good at his craft that he has been among Hollywood's highest-paid personalities, amassing at one point $150 million in acting fees. That's quite a chunk of change. However, the Academy Award winner lost much of his fortune due to questionable spending habits. It wasn't like his National Treasure was Gone in Sixty Seconds, but over a period of time he eventually found himself broke and in trouble with the IRS. What could have possibly happened? Some suggest it was his purchase of the dinosaur bones or the 50 vehicles or the 15 estates and two castles, or any number of exotic acquisitions with which he has been associated over the years. Perhaps it would have helped to take an inventory of his balance sheet from time to time. It's a good idea, you know. We should all make time, on a periodic basis, to take stock of where we are from a financial standpoint. That goes for hospitals, as well; and, to that end, one organization is leading the way. Last month, the American Hospital Association (AHA) produced a report that sought to gauge the costs generally incurred by America's hospitals and health systems. The report, released late last month, addressed several drivers of hospital spending, which we will summarize in today's podcast. Take a listen! 

Breakdown of how the CARES Act funds were distributed to hospitals due to the COVID-19 pandemic. 

The No Surprise Act Final Rule initiated some "surprised" reactions from various healthcare organizations. Today's podcast takes a closer look.

This episode breaks down the No Surprises Act final rule (FR) which further defines provisions of the previously passed bill which aims to protect beneficiaries from unexpectedly high medical bills. This FR outlines a new independent dispute resolution process, good faith estimate requirements and patient/provider dispute resolution process for uninsured individuals.  Take a listen! 

Senators and U.S. representatives cannot come up with everything on their own. They have a staff and a team of legal experts who help craft and review legislation. But that's not all they have. They depend, in large measure, on advice and counsel coming from those who are experts in a particular field. In other words, they give ear to lobbyists, often allowing such individuals to help write provisions that become law. It is with this dynamic in mind, that we provide you with today's article.

Last week, we published an alert that outlined some of the key provisions of the Medicare Physician Fee Schedule (PFS) Proposed Rule (PR) for 2022 that may affect hospitals. As promised in that alert, this week's article will provide additional details arising from the 2022 PR.

It's that time of year again. Last week, the government released the 2022 Medicare Physician Fee Schedule (PFS) Proposed Rule (PR), and there are some interesting changes that may be in store for hospitals. The following treatment is based on what we've gleaned from summaries of the PR released by the Centers for Medicare and Medicaid Services (CMS) and the American Hospital Association (AHA).

On July 1, 2021, the Department of Health and Human Services (HHS), the Department of Labor, and the Department of the Treasury released an interim final rule (IFR) that acted to flesh out some of the provisions of the No Surprises Act (NSA), scheduled to go into effect next year.   

Right now, the American hospital industry seems to be recovering nicely from a devastating year of elective surgery cancelations, overworked staff, major shifts in care parameters, and a dip in case-related revenue. 

There's recently been a change of plans by the federal government that will positively affect many of America's hospitals.

Something strange happened in Cleveland late last month.  Joe Biden was giving a speech on the economy when he made the following statement: “You know, if we don't do something about Alzheimer's in America, every single solitary hospital bed that exists in America—as the nurses can tell you—every single one will be occupied in the next 15 years with an Alzheimer's patient—every one.” 

We've all witnessed occasions where someone who's had a tumble, but looks to be unharmed, is nevertheless encouraged to go to the emergency room to have a once-over—just to be sure. Now, however, you'd have to stop and give that some additional thought, because we are seeing increasing signs that payers are beginning to redefine what they deem to be reasonable and payable emergency department (ED) services.

It is sad when relations between fellow humans devolve into strife, leading to hard feelings and demoralization.  While violence rarely erupts in today's business world, there are still those occasions when owner and employee are at odds.  Sometimes, the employee resentment—whether reasonable or not—can transform into serious action.   In recent days, we have seen such action on the part of employees bubble over in American hospitals.  Let's look at two notable examples.

The United States Supreme Court may soon serve as the arena for a battle between a couple of organizational heavyweights, with one substantially outweighing the other.   In one corner is the American Hospital Association (AHA).  While strong and influential, it cannot compare to the unmatched might of the federal government, as represented in this legal contest by the U.S. Department of Health and Human Service (HHS) and its new secretary, Xavier Becerra 

Today's article will conclude our look at the massive 2022 IPPS Proposed Rule (PR). So far, we've summarized how the PR treats topics such as payment rates, quality measures, negotiated payment disclosure, residency programs and efforts to reduce hospital readmissions. Based on a summary of the PR released by the Centers for Medicare and Medicaid Services (CMS), we will now provide some of the remaining highlights of the government's proposed changes impacting hospitals in FY 2022.

Today's article is a continuation of last week's treatment of Medicare's 2022 Inpatient Prospective Payment System Proposed Rule (PR), released in late April.  As we pointed out previously, the PR contains over 1,900 pages of proposals.  Consequently, we have found it necessary to break down the proposed changes among multiple alerts so that we might provide as many relevant highlights as possible to our readers.  With that said, the following will act to summarize more details in the PR—beyond what we summarized last week—that hospital executives and clinicians will find most relevant.

Last week, the Centers for Medicare and Medicaid Services (CMS) released its Fiscal Year (FY) 2022 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital (LTCH) Rates Proposed Rule, along with a fact sheet that acts to summarize the critical parts of the proposals. The following will highlight some of the more critical components of the Proposed Rule (PR). As the PR is over 1,900 pages long, our summary will be provided in a multi-part series of alerts.

The HAH model today is seen as beneficial for older patients and those with chronic diseases, such as asthma, congestive heart failure and COPD.  It has the added benefit of alleviating space in hospitals that have otherwise reached capacity.  As the American population continues to age, this model of care will be seen as an increasingly appealing option for both facilities and patients.

In the midst of a declared public health emergency (PHE), it is more important than ever to receive direction from our leaders that is both consistent and supportable.  Vacillation and mixed messages are not a good look.  The question is: are recent announcements concerning the ongoing COVID event creating confusion among the general population and even healthcare workers?

Despite the short-term nature of pandemics, it is clear that we are not out of the woods just yet as it concerns COVID.  The virus that began in 2019 is still a factor in certain hot zones, including at least 5 U.S. states.  Michigan, for example, is currently experiencing the biggest surge in cases—despite its history of mask mandates and rigid lockdowns.  This raises the question of how American hospitals, as a group, are handling the 2021 version of COVID.  One government agency decided to get some answers to that question.

If perfection is the standard, then it is clear that we often come up short, depending on the task. However, it is the push toward that goal that puts us on the path of improvement, constant improvement. This is the real message of Carter's retrospective account: to simply get better. That is something we can all achieve.For those who work in our nation's hospitals, the goal should be perfection in patient care, which means working every day to get as close to that goal as possible. So, what does that look like? 

In this age of 24-hour news, it's hard to wade through all the chatter to see what really matters; so, we've done the wading for you. In today's article, we provide you with three recent news stories that are particularly applicable to hospitals and those that run them.

Earlier this month, the Centers for Medicare and Medicaid Services (CMS) published a Medicare Learning Network (MLN) article addressing changes to the IPPS rules that will take effect April 5 of this year.

The ECRI's list of patient safety concerns for 2021—listed in order of ranking— with our commentary following each.

PROVISIONS OF THE BILLThe following reflects a summary of some of the most pertinent components of the bill, from a hospital perspective.  The summary is based in-part on a document published by the American Hospital Association (AHA).

In the event you, as a hospital administrator, have been getting that nagging feeling of late that someone is watching from afar, you are not delusional or on the brink of a nervous breakdown.  In fact, your instincts have served you well; for, the federal government has just admitted that it has been quietly checking up on hospital billing practices, and it doesn't like what it sees.  

It's been a little over a year since the first COVID-19 case was treated in an American hospital.  Since that time, we have witnessed one of the most remarkable societal transformations to occur in peace time.  

After a year of languishing in the extreme conditions caused by COVID, hospitals are showing new life and a renewed hope for a positive future. The once suppressed revenues and restrained budgets are now loosening up, and some hospitals are poised to hit the ground running—and not just for the long term. The short term is in play as well.

High towers, thick stones and surrounding water traps were the cutting-edge means of protecting a building back in the Middle Ages.  Today, however, the methods of attack are ingeniously sophisticated, and we must erect new defenses to match the threat.  That is especially true when it comes to large institutions with lots to lose, like hospitals.

On January 20, CMS directed its surveyor agents to significantly relax their scope of operations within the hospital setting for 30 days from the issuance of the directive.  Moreover, this temporary guidance is subject to possible renewal involving additional 30-day periods.  The move was sparked, in part, by a request from the American Hospital Association (AHA) to eliminate or severely restrict surveying activities during the pandemic.  In response, CMS has announced that, during this initial 30-day period, it will be suspending certain hospital surveying activities .

Numerous studies have demonstrated that about one quarter of healthcare spending amounts to waste.  This is an astounding figure.  Imagine how a hospital's financial health could be bettered by simply trimming this fat. 

By way of background, the Department of Health and Human Services (HHS) had previously published a set of reporting instructions that would apply to those receiving PRF funds in excess of $10,000 in the aggregate.  The Department had originally planned on opening a reporting portal by January 15, 2021, and had set February 15, 2021 as the first deadline for submissions.  However, with the passage of the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act in December, an additional $3 billion was added to the PRF program fund.  This, along with the inclusion of new language within CRRSA implicating PRF reporting requirements, created new roadblocks to the original timeline.

On Friday, January 8, the Department of Health and Human Services (HHS) issued a final rule, to be known as the Securing Updated and Necessary Statutory Evaluations Timely (SUNSET) rule. Essentially, the rule builds on the efforts of previous administrations—going all the way back to the Carter presidency—to review and improve the federal regulation process. The broad-stroke take on this latest government effort is that there will be a mandated decadal review of certain health-related regulations; and—here's the kicker—if the government fails to review a particular regulation, it goes off the books.

With the recent promotion and extension of virtual medicine, including telehealth services, many hospital workers are wondering: when is it appropriate to utilize telehealth in this determination process? Is there a checklist that makes the decision to go virtual more supportable?

While millions of Americans have been stuffing wrapping paper and ribbons in the trash or heading to the store to return or exchange unwanted gifts, the federal government has delivered one more present to the American healthcare industry. This package comes in the form of the Consolidated Appropriations Act (CAA)—otherwise known as the COVID-19 relief bill—passed by Congress on December 21 and signed into law by President Trump on December 27. It is a nearly 5,600-page document that covers a wide range of topics and will take some time to fully digest; but, based on multiple societal publications and other sources we have reviewed, we have taken note of a few key highlights found in the CAA that we believe will be of interest to our readers. They are summarized in this message.

As we head toward the end of another year, there are the obligatory “year in review” offerings provided via television, print media and websites.  Some might argue that there are years we'd just as soon forget—2020 perhaps being one of them.  However, end-of-the-year stories aren't always about the year that was, but about the year ahead.  That is especially true when it comes to the rash of releases by the federal government concerning changes for the healthcare industry slated for the new year.  In that spirit, we want to bring you a summary of a set of regulations that will impact hospitals in 2021.

Hospital patients should be able to rely on the expertise of their nurses and clinical staff as they undergo treatment and recuperation, rather than having to worry if they are putting themselves in harm's way. A 2016 report appearing in Johns Hopkins Medicine found that over 250,000 deaths occur in the U.S. due to medical error in the hospital setting. When comparing that figure with total U.S. deaths, hospital-based medical errors account for 9.5 percent of all deaths in this country, ranking third behind heart disease and cancer.

Since we are in the midst of a second wave of COVID-19, it may be a good time to revisit some of these government allowances as they pertain to the issue of site of service.  In November, CMS provided an updated document outlining place of service options that are available to hospitals during the public health emergency (PHE).  The agency, which falls under the jurisdiction of HHS, explained that these temporary provisions are meant to fulfill its “Hospitals Without Walls” initiative—an effort to allow off-site locations for care events that would nonetheless act as extensions of the hospital setting.

Hospitals are in trouble. There is no getting around it. At least as it pertains to those facilities in and around the COVID hotspots, staffing is becoming an increasingly problematic component of the overall care mission. 

Today, the newspaper biz is on life support as more and more citizens are reaching for their tablets or other electronic devices to get the latest infusion of facts.  But despite the change in delivery mechanisms, people are still anxious to get the lowdown on what's happening in their local and wider world.  News still counts, and there are few things that satiate the news consumer like the results of a survey.  Today's article focuses on a survey that hospital leaders around the country should find instructive.

The federal government issued a warning concerning a credible and imminent threat to our national healthcare security.  The Federal Bureau of Investigation (FBI), the Department of Health and Human Services (HHS) and the Department of Homeland Security (DHS) conducted an urgent conference call with leaders of the healthcare industry on Oct 28, informing them that the government has received reliable information that international hackers—perhaps with ties to Russia—are planning to breach the IT systems of some 400 hospitals and clinics throughout the United States. 

Yes, round one of the pandemic was devastating in many ways to the nation's health, economy and way of life.  The surge in the late spring was debilitating to be sure, but hospitals managed to find ways to battle through the hardships.  Now that the dreaded second round looks to be a reality in large sectors of the country, hospital officials and clinicians are being called on once more to fight the good fight in spite of all difficulties.  But how?

New ways of getting the job done are always just around the corner. The trick is translating these technologies into a mechanism for business improvement. In today's article, we will explore ways in which hospitals are using cutting edge strategies to improve their clinical effectiveness, profitability and presence in the community. So, buckle in, as we zoom "back to the future."

Mergers and acquisitions (MAs) appear to be part of the normal evolution of hospitals and health systems in America; but, like the hope of marriage, does it truly lead to greater happiness?

On October 1, the Department of Health and Human Services (HHS) released a third phase of relief funds into the healthcare sector. As you'll recall, the Coronavirus Aid, Relief and Economic Security (CARES) Act authorized billions of dollars to support struggling health providers and facilities in the wake of the coronavirus pandemic that swept the nation. Of the $175 billion authorized by the CARES Act, about $107 billion had been released in the first two phases. This third phase will pump another $20 billion into America's healthcare system.

National Public Radio (NPR) is reporting that it has come into possession of “internal documents” drafted by individuals at the Centers for Medicare and Medicaid Services (CMS), which indicate that the agency “is preparing to crack down aggressively on hospitals.”  The impending action will specifically be against those facilities who failed to report “complete COVID-19 data daily into a federal data system,” as mandated earlier this summer by the Trump administration.

Now that fall has officially arrived, many in the healthcare industry are bracing for what could be a new wave of the coronavirus within our borders. Many of our students are back at school, and some fear this may trigger a new spike in COVID cases throughout the country. 

As reported this past Monday by Becker's Health IT, the CEO of EPIC, Judy Faulkner, provided five predictions concerning healthcare in America in a recent interview with Business Insider. As many of our readers are aware, Epic is one of the giants of the electronic medical record (EMR) industry. Here is a snapshot of Ms. Faulkner's prognostications:

On September 2, the Centers for Medicare & Medicaid Services (CMS) issued the fiscal year (FY) 2021 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long Term Acute Care Hospital (LTACH) final rule, which includes "important provisions designed to ensure access to potentially life-saving diagnostics and therapies for hospitalized Medicare beneficiaries." According to a CMS press release, the changes will affect approximately 3,200 acute care hospitals and approximately 360 LTACHs. The agency estimates that total Medicare spending on acute care inpatient hospital services will increase by about $3.5 billion in FY 2021, representing an uptick of 2.7 percent over FY 2020.

Those who elected to access the APP funds may remember that, unlike other PHE-related relief efforts, these funds were meant to be a temporary stop-gap measure to support health facilities in their time of need. They were not gifts, grants or forgiven debts. They were straight-up loans; and the loans have come due.