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Medicaid Directors Comment on Proposed Medicaid Pass-Through Regulation

national association of medicaid directorsLast November the Centers for Medicare & Medicaid Services proposed a new regulation governing the use of pass-through payments in state Medicaid managed care programs.
The National Association of Medicaid Directors submitted formal comments to CMS about that proposed regulation. See its comments here.
 

2017-01-11T06:00:13+00:00January 11th, 2017|Pennsylvania Medicaid policy|Comments Off on Medicaid Directors Comment on Proposed Medicaid Pass-Through Regulation

Weighing the Impact of ACA Repeal

How might repeal of the Affordable Care Act affect the financial health of different kinds of hospitals?
iStock_000001497717XSmallThe New York Times recently took a look at how the 2010 reform law’s repeal would affect two Pennsylvania health systems: the Temple University Health System, led by a heavily Medicaid-dependent safety-net hospital located in one of the poorest communities in the country; and Main Line Health, a non-profit organization with several hospitals all located in affluent communities.
See what the Times found here.

2017-01-10T06:00:03+00:00January 10th, 2017|Affordable Care Act, Pennsylvania safety-net hospitals|Comments Off on Weighing the Impact of ACA Repeal

Medicaid Directors Set 2017 Legislative Priorities

The National Association of Medicaid Directors has published its legislative priorities for 2017. Those 13 priorities, and the manner in which the group hopes to achieve them, are:

  1. namdImplement requirements for advance review of federal regulations and guidance by state Medicaid staff. Require in federal statute a distinct role for state Medicaid leaders to review the conceptual soundness and operational feasibility of federal regulations and guidance prior to finalization, which directly or indirectly impact the Medicaid program.
  2. Advance value-based reimbursement methodologies for all types of Medicaid providers.   Update the tools states may use to allow for aligned value-based purchasing approaches for all Medicaid safety-net providers, including modest down-side risk where consistent with broader statewide reforms.
  3. Provide long-term certainty for effective state Medicaid program innovations. Establish a reasonable path for states to make permanent the foundational aspects of their Section 1115 demonstrations programs. 
  4. Make consistent the federal financing options for Medicaid eligibility expansions and ensure state flexibility on coverage strategies. Provide states more options under the Medicaid state plan to address coverage gaps for low-income populations. An example is to allow a phased approach to coverage for new populations up to 100 percent of the federal poverty level. The existing phase down in federal financing should be consistent for all states, regardless of their starting point.
  5. Provide flexible options for states to streamline waiver authorities and braid funding for Medicaid, overlapping health-related services programs and the social determinants of health. Establish federal demonstration pilots that allow states to integrate funding from other federal health care funding streams, particularly those for behavioral health services, with the explicit purpose of enhancing states’ ability address the total cost of care for Medicaid enrollees. 
  6. Resolve statutory conflicts presented by federal mental health and addiction disorder parity requirements, the federal payment exclusion for Medicaid Institutions for Mental Diseases (IMD) exclusion and federal privacy laws for individuals with a substance use disorder. Repeal or make meaningful modifications to the parameters of the Medicaid IMD payment exclusion or authorize defined waiver authority to do so. Revise existing privacy rules to enable access to protected health information (PHI) of individuals with a substance use disorders diagnosis. 
  7. Delink Medicaid from Medicare financing. Congress should develop a mechanism for keeping the impact of Medicare policies on states predictable, reasonable, and sustainable. 
  8. Address the service dichotomy that continues to impede coordinated, high value care for individuals dually eligible for Medicare and Medicaid. Enhance support for the MMCO’s work with states around the dual eligible population, including by authorizing permanent authority for demonstration models which align and coordinate services for the population dually eligible for Medicare and Medicaid. Permanently reauthorize the SNP program, requiring agreements between all types of SNP plans and states, and providing clear expectations for CMS and states to collaborate to maximize the administrative and care coordination opportunities. 
  9. Allow all states to cover complex populations in managed care. Repeal the prohibition on requiring enrollment in Medicaid managed care for the Medicare and Medicaid dual eligible population and children with special health care needs. States have significant experience designing, launching and administering managed care programs for special populations. 
  10. Harmonize federal payment rules across Medicaid delivery system models. Resolve the inconsistency in federal Medicaid policy so that payment rules apply equitably, regardless of the state’s delivery system model. 
  11. Expand the tools states can use to design and manage Medicaid’s optional prescription drug benefit, including flexibility to exclude some FDA-approved drugs from coverage. Expand the factors states may consider in setting their prescription drug benefit, including cost. Also, advance a multi-pronged strategy to address the affordability of prescription drugs, including providing: transparency for drug pricing for public programs; providing authority for new purchasing and reimbursement strategies for Medicaid’s prescription drug benefit, including flexibility to exclude some FDA-approved drugs from coverage; and limiting the states’ exposure to high-cost prescription drugs. 
  12. Equalize treatment of the territories of the United States. Apply the same formulary to the territories as for the broader group of states and remove the Medicaid cap. 
  13. Facilitate innovation in long-term care, particularly home and community-based services. Allow states to target services to specific populations who will most benefit and for whom the services would be cost-effective.

Learn more about NAMD’s goals for 2017 in its publication NAMD’s Legislative Priorities for 2017.

2017-01-06T06:00:57+00:00January 6th, 2017|Uncategorized|Comments Off on Medicaid Directors Set 2017 Legislative Priorities

New Medicare Payments to Help With High-Need Patients

New Medicare payment practices that took effect on January 1 will improve payments to physicians who care for high-need patients in the hope that those enhanced payments will improve the care such seniors receive.
A medical doctor standing with a confident smileAmong those improved payments are:

  • payments to physicians for the time they spend working with specialists, families, pharmacists, caregivers, and others to coordinate services for seriously ill patients
  • improved payments for time spent coordinating seniors’ transitions between different care settings and home and connecting those patients with additional resources
  • separate payments to perform cognitive impairment assessments
  • payments for time physicians spend reviewing patient records and talking on the phone to patients and their caregivers
  • ayments for work physicians perform with their high-need patients’ behavioral health caregivers

Learn more about how Medicare is trying to improve care for its some of its highest-need, highest-cost patients in this Kaiser Health News report.

2017-01-05T06:00:05+00:00January 5th, 2017|Medicare|Comments Off on New Medicare Payments to Help With High-Need Patients

Medicaid Directors Set Goals for First 100 Days

The National Association of Medicaid Directors has published a paper detailing its objectives for its interaction with the Trump administration during that administration’s first 100 days in office.

namdWe call upon the new Administration to convene with NAMD’s Board of Medicaid Directors to solidify specific areas for ongoing collaboration to be carried out and reflected throughout our respective agencies. 

The Administration should make two updates to the process for developing federal Medicaid regulations and guidance. First, build in a step for engaging states during the pre-conceptual phase of work. Second, establish a distinct process whereby state Medicaid leaders can review federal regulations and guidance prior to finalization to ensure policies are operationally sound. 

NAMD also calls for the administration to foster state-federal collaboration in the following areas:

  1. Alternative Payment Methodologies
  2. Medicare and Medicaid Dual Eligible Population
  3. Prescription Drugs
  4. Managed Care/Risk-Based Delivery Models
  5. Behavioral Health Issues
  6. Access to Services
  7. Home and Community Based Services
  8. Department of Labor & the Fair Labor Standards Act
  9. Medicaid Management Information Systems
  10. Transformed Medicaid Statistical Information Services
  11. Other Existing Regulations

Learn more about NAMD’s goals for the first 100 days of the Trump administration in the association paper “The First 100 Days: Laying the Groundwork for a Successful Federal-State Medicaid Partnership.”

2017-01-04T06:00:47+00:00January 4th, 2017|Uncategorized|Comments Off on Medicaid Directors Set Goals for First 100 Days

Expanded Access to Hep C Drugs Isn’t the Answer for Medicaid, Study Says

A new study suggests that greatly expanding access to new drugs that essentially “cure” Hepatitis C would cost Pennsylvania’s Medicaid program a great deal of money but save relatively few lives.
The study found that in many cases, Hepatitis C progresses so slowly that by the time many of the people who suffer from it truly need the new generation of expenses drugs they will be old enough for Medicare, which would leave the federal government, rather than the state, with the cost of paying for the treatment.
Prescription Medication Spilling From an Open Medicine BottlePatient advocates maintain that all Medicaid beneficiaries with Hepatitis C should have access to the drugs and Pennsylvania’s Medicaid program appears to be on a path toward making that possible.
Learn more about the study and its findings in this Philadelphia Inquirer story.

2017-01-03T06:00:29+00:00January 3rd, 2017|Pennsylvania Medicaid policy|Comments Off on Expanded Access to Hep C Drugs Isn’t the Answer for Medicaid, Study Says

Patient Safety Authority Issues Newsletter

patient-safety-authorityThe Pennsylvania Patient Safety Authority has published its December 2016 newsletter.
Included in it are articles about drug interactions, infection control practices, wrong-site surgeries, the use of simulations in improving patient safety, and more.
Find the newsletter here.

2016-12-30T06:00:24+00:00December 30th, 2016|Uncategorized|Comments Off on Patient Safety Authority Issues Newsletter

New Study: Social Risk Factors Affect Provider Performance and Patient Outcomes

Medicare patients with social risk factors fare worse than others in programs that measure quality and the providers that serve them also perform worse than others on quality measures.
This news comes from a new report presented to Congress by the U.S. Department of Health and Human Services’ Office of the Assistant Secretary for Planning Evaluation.
ASPEsealThe report, mandated by the Improving Medicare Post-Acute Care Transformation (IMPACT) Act of 2014, focused on nine Medicare payment programs:

  1. the hospital readmissions reduction program
  2. the hospital value-based purchasing program
  3. the hospital acquired condition reduction program
  4. the Medicare Advantage (Part C) quality star rating program
  5. the Medicare shared savings program
  6. the physician value-based payment modifier program
  7. the end-stage renal disease quality incentive program
  8. the skilled nursing facility value-based purchasing program
  9. the home health value-based purchasing program

APSE concluded that:

  • Beneficiaries with social risk factors had worse outcomes on many quality measures, regardless of the providers they saw, and dual enrollment status was the most powerful predictor of poor outcomes.
  • Providers that disproportionately served beneficiaries with social risk factors tended to have worse performance on quality measures, even after accounting for their beneficiary mix. Under all five value-based purchasing programs in which penalties are currently assessed, these providers experienced somewhat higher penalties than did providers serving fewer beneficiaries with social risk factors.

Among the solutions suggested in the report for addressing these problems are:

  • adjusting quality and resource use measures
  • adjusting payments
  • addressing the underlying issues

The report also suggests that HHS’s strategy for accounting for social risk in Medicare’s value-based purchasing programs should consist of the following three steps:

  • measure and report quality for beneficiaries with social risk factors
  • set high, fair quality standards for all beneficiaries
  • reward and support better outcomes for beneficiaries with social risk factors

And in carrying out these steps, the report recommends that HHS

  • provide specific payment adjustments to reward achievement and/or improvement for beneficiaries with social risk factors, and
  • where feasible, provide targeted support for providers who disproportionately serve them.

Medicare beneficiaries who present with socio-economic risk factors are served by Pennsylvania safety-net hospitals in especially large numbers.
Learn more about the problems APSE found and its proposals for dealing with those problems by reading Report to Congress: Social Risk Factors and Performance Under Medicare’s Value-Based Purchasing Programs.

2016-12-30T06:00:20+00:00December 30th, 2016|Medicare, Pennsylvania safety-net hospitals|Comments Off on New Study: Social Risk Factors Affect Provider Performance and Patient Outcomes

Medicare Program Biased Against Selected Hospitals

Medicare’s hospital-acquired conditions program unfairly penalizes large, large urban, and teaching hospitals, according to a new study.
According to “Complication Rates, Hospital Size, and Bias in the CMS Hospital-Acquired Condition Reduction Program,” published recently in the American Journal of Medical Quality, the hospital-acquired conditions program, which last year penalized nearly 800 hospitals, disproportionately penalizes large, large urban, and teaching hospitals because its threshold for identifying poor-performing hospitals is too broad, it relies on results that in many cases are not statistically different, and it fails to recognize when hospital performance improves.
quality-journalTo correct these biases, the study’s authors recommend adding risk-adjustment components, such as hospital size, to identify poor performers.
Many of Pennsylvania’s safety-net hospitals are large and have teaching programs.
Learn more about the study, its findings, and its recommendation in this Fierce Healthcare article or go here to read the study on the web site of the American Journal of Medical Quality.

2016-12-29T06:00:36+00:00December 29th, 2016|Medicare, Pennsylvania safety-net hospitals|Comments Off on Medicare Program Biased Against Selected Hospitals

PA Health Law Project Newsletter

phlpThe Pennsylvania Health Law Project has published its November-December 2016 newsletter.
Included in this edition are stories about a new effort to enroll children in the state’s Medicaid and Children’s Health Insurance Program, the new fees for Medicare Part A and Part B for 2017, a delay in the implementation of the state’s proposed Community HealthChoices program of managed long-term services and supports, and more.
Go here for the latest edition of PA Health Law News.

2016-12-28T06:00:04+00:00December 28th, 2016|Medicare, Pennsylvania Medicaid, Pennsylvania Medicaid policy|Comments Off on PA Health Law Project Newsletter
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