Virginia Rural Health Summit  Washington Update Spring, 2011 Wintergreen, Virginia
Bill Finerfrock Senior Vice President Health Policy  Capitol Associates 202-544-1880 [email_address]
 
Budget Impasse – Business as Usual?
 
<ul><li>The current Continuing Resolution expires on April 8 th .  If Congress and the President are unable to reach a com...
Budget/Appropriations <ul><li>The new GOP House leadership has announced plans to scale back federal spending to the level...
<ul><li>The 111 th  Congress was the first Congress since enactment of the Budget and Impoundment Control Act of 1974, tha...
<ul><li>Historically , entitlement programs and programs and services deemed “essential” have NOT been subject to a suspen...
<ul><li>Discretionary Spending  </li></ul><ul><li>Vs.  </li></ul><ul><li>Entitlement Spending? </li></ul><ul><li>The Econo...
Who is the Rural Safety Net?
 
 
<ul><li>The Affordable Care Act </li></ul>
<ul><li>On March 23, 2010 President Obama signed the Patient Protection and Affordable Care Act into law .  </li></ul>
<ul><li>Reimbursement Incentive Study and Report </li></ul><ul><li>STUDY- The Secretary of Health and Human Services  </li...
Collaboration with FQHCs <ul><li>The ACA has language directing that the Health Resources and Services Administration enco...
RHC Technical Assistance Call <ul><li>Contracting and Collaboration Opportunities  Monday, December 13, 2010, 2 PM EST </l...
<ul><li>The Independent Payment Advisory Board is established to develop and submit “proposals” to Congress and the privat...
Medicare Payment Changes <ul><li>PProvide a 10% bonus payment to primary care physicians in Medicare from 2011 through 201...
Medicare Payment Changes <ul><li>Provide a 10% bonus payment to primary care physicians and to   general surgeons   practi...
Medicaid Expansion <ul><li>Beginning in 2014, Medicaid eligibility will be expanded to mandate coverage of individuals mak...
Questions for Consideration <ul><li>Will there be an on-going need for a  healthcare safety net post-2018? </li></ul><ul><...
Healthcare Reform – Timeline The Challenge of Change
Provisions already implemented Provide dependent coverage for adult children up to age 26 for all individual and group pol...
<ul><li>Small employers (those with no more than 25 employees and average annual wages of less than $50,000 that purchase ...
Small Employer Tax Credit <ul><li>Maximum Amount.  The credit is worth up to 35 percent of a small business' premium costs...
<ul><li>Eligibility Rules </li></ul><ul><li>Providing health care coverage.  A qualifying employer must cover at least 50 ...
IRS Information Available <ul><li>www.irs.gov/newsroom/article/0,,id=221511,00.html </li></ul>
Pre-Existing Condition Insurance Program (PCIP) <ul><li>The PCIP initiative is in place in all 50 states and the District ...
https:// www.pcip.gov/StatePlans.html <ul><li>The Pre-Existing Condition Insurance Plan may vary depending on what state y...
ACO and Workforce
<ul><li>HEALTH WORKFORCE EVALUATION & ASSESSMENT </li></ul><ul><li>National Health Care Workforce Commission </li></ul><ul...
What impact will workforce policy have if the payer does not recognize the provider? <ul><li>Look at the experience of NPs...
HCR and Rural Workforce? <ul><li>Will the increased demand for healthcare lead to shortages of health professionals?  </li...
The Politics  and Legality of Healthcare Reform
New Deliver Models Shared Savings?
Accountable Care Organizations (ACOs) <ul><li>Are ACOs just a dressed up version of HMOs? </li></ul><ul><li>Will ACOs lead...
Accountable Care Organizations
ACOs, Quality and Cost <ul><li>ACOs meeting the quality standards must ALSO demonstrate that they saved Medicare money whe...
Quality and Cost and ACOs <ul><li>ACOs will be required to sign a three year agreement with CMS to operate as an ACO. </li...
So what Comes First? <ul><li>Cost Savings  Quality </li></ul>
According to CMS – Cost Savings! <ul><li>“… ACOs will only share in savings if they  first generate shareable savings and ...
How Will ACOs affect RHCs and other safety net providers? Rural Health Clinics, FQHCs and CAHs can be part of an ACO.  Rur...
ACOs and Rural <ul><li>Although RHCs and FQHCs will be allowed to form RHC exclusive or FQHC exclusive ACOs, as a practica...
ACOs and Rural <ul><li>Minimum of 5,000 Medicare beneficiaries “assigned” to the ACO. </li></ul><ul><li>In order for a pat...
ACOs and Rural <ul><li>ACOs including RHCs and FQHCs are eligible for an additional “bonus” payment for including RHCs and...
Are ACOs the same as Value-Based Purchasing or Bundled Payments? <ul><li>NO </li></ul>
Bundled Payments <ul><li>A national  pilot  program geared towards inpatient care that would pay the provider a “bundled” ...
Bundled Payments <ul><li>To the extent that bundled payment arrangements encourage providers to become more efficient in t...
What is Value Based Purchasing? <ul><li>Under VBP Medicare (and eventually other payers) will base payment on “quality”.  ...
What is Value Based Purchasing (VBP) <ul><li>The premise behind value based purchasing is that Medicare pays a predetermin...
Value-Based Purchasing and the PQRI/S initiative <ul><li>Key Dates </li></ul><ul><li>January 1, 2012 , CMS publishes the q...
Providers who fall into Quartile 1 would receive a reduced Payment.  Providers who fall into Quartile 2 and 3 would receiv...
Is the Data Being collected under PQRI/S reflective of the physician specialty being analyzed? <ul><li>Serious concerns ha...
 
Legal Challenges <ul><li>28 states have filed suit challenging the constitutionality of the Affordable Care Act. </li></ul>
Legal Challenges to ACA <ul><li>Two Key issues raised by the States:  </li></ul><ul><li>Can the federal government require...
Repeal, Replace? <ul><li>On January 19 th , the House passed a bill repealing the Patient Protection and Affordable Care a...
 
Other Issues
3% Withholding and Physicians <ul><li>The 3% withholding law, which was enacted in 2005 and mandates that federal, state, ...
EHR Incentive Payments <ul><li>Medicare </li></ul><ul><li>Medicaid </li></ul>
Medicaid EHR Incentive Payments
Medicaid EHR Incentive Payments <ul><li>Physicians, NPs, CNMs and some PAs working in an RHC are eligible for EHR incentiv...
Rural Health Clinic and FQHC  EHR Incentive Payments <ul><li>Eligible Professionals (physician, NP, CNM or certain PAs) mu...
Who is a “Needy Individual” <ul><li>Someone who is receiving assistance under Medicaid </li></ul><ul><li>Someone who is re...
What is PA led? <ul><li>A “PA led” Clinic is,  </li></ul><ul><li>(1) When a PA is the primary provider in a clinic (for ex...
Medicaid EHR Incentive Payments <ul><li>Year 1 - $25,000 (adopt, implement  or upgrade) </li></ul><ul><li>Year 2 - $10,000...
Medicare <ul><li>Physicians </li></ul><ul><li>Hospitals </li></ul><ul><li>CAHs </li></ul>
Medicare EHR <ul><li>Physicians meeting the meaningful use criteria are eligible for EHR incentive payments based upon the...
<ul><li>Hospital (non-CAH) Incentive payments </li></ul><ul><li>$ 2 Million per hospital plus additional incentive payment...
<ul><li>Critical Access Hospitals </li></ul><ul><li>The Secretary shall compute reasonable costs by  </li></ul><ul><li>exp...
<ul><li>There shall be substituted for the Medicare share that would otherwise be applied under paragraph a percent (not t...
Double dipping? <ul><li>An eligible professional shall not qualify as a Medicaid provider under this subsection unless any...
New Medicare Enrollment Fee <ul><li>Effective Friday, March 25, 2011, all NEW providers enrolling in Medicare will be requ...
5010 Standards
<ul><li>December 31, 2010 -  Internal  testing of Version 5010 must be complete to achieve Level I Version 5010 compliance...
<ul><li>RHC Rules and Regulations </li></ul><ul><li>Proposed changes in RHC Rules and Regulations Issued on June 27 2008. ...
<ul><li>It is not a certainty that CMS will move to release the RHC FINAL rule by June 28, 2011. </li></ul>
<ul><li>The Patient Protection and Affordable Care Act (Healthcare Reform) legislation, mandated that the Secretary of HHS...
<ul><li>In May, Ron Nelson, PA-C, Associate Executive Director of NARHC and Alan Morgan were appointed to the Negotiated R...
Negotiated Rulemaking Committee <ul><li>Issues under consideration: </li></ul><ul><li>How to define a rational service are...
Negotiated Rulemaking Committee Update <ul><li>Time Line </li></ul><ul><li>Process  </li></ul><ul><li>Consensus </li></ul>...
<ul><li>Policy Changes being pursued by NARHC during the 112 th  Congress </li></ul>
Linking Quality and Payment in RHCs <ul><li>The Patient Protection and Affordable Care Act directed the Secretary of HHS t...
RHC Technical Assistance <ul><li>NARHC in conjunction with the Federal Office of Rural Health Policy conducts RHC Technica...
To view transcripts or download audio recordings of previous calls <ul><li>http://www.hrsa.gov/ruralhealth/policy/confcall...
<ul><li>To sign up for both the RHC TA listserve as well as the NARHC NEWS listserve, go to: </li></ul><ul><li>Send an ema...
Be on the look out <ul><li>The Senate Rural Health Caucus and the House Rural Healthcare Coalition are drafting a new Rura...
Bill Finerfrock Senior Vice President Health Policy  Capitol Associates 202-544-1880 [email_address]
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Washington Update

  1. 1. Virginia Rural Health Summit Washington Update Spring, 2011 Wintergreen, Virginia
  2. 2. Bill Finerfrock Senior Vice President Health Policy Capitol Associates 202-544-1880 [email_address]
  3. 4. Budget Impasse – Business as Usual?
  4. 6. <ul><li>The current Continuing Resolution expires on April 8 th . If Congress and the President are unable to reach a compromise on a budget for the current fiscal year, we COULD face a shut-down of all “non-essential” government services beginning Midnight, April 8 th ? </li></ul><ul><li>What Happens to Medicare Payments if Congress and the President are Unable to reach a deal on the 2011 Budget? </li></ul>
  5. 7. Budget/Appropriations <ul><li>The new GOP House leadership has announced plans to scale back federal spending to the level in place in 2008? </li></ul><ul><li>What, if anything, does this mean for RHCs and rural providers? </li></ul>
  6. 8. <ul><li>The 111 th Congress was the first Congress since enactment of the Budget and Impoundment Control Act of 1974, that has failed to enact a single appropriations bill. </li></ul><ul><li>In addition, the 111 th Congress failed to pass a budget by either the House or the Senate. </li></ul>
  7. 9. <ul><li>Historically , entitlement programs and programs and services deemed “essential” have NOT been subject to a suspension of services or payments due to the failure of Congress to enact the necessary appropriations bills. </li></ul><ul><li>Military </li></ul><ul><li>Border Security </li></ul><ul><li>Airline Security (TSA) </li></ul><ul><li>Medicare </li></ul><ul><li>Medicaid </li></ul><ul><li>Social Security </li></ul><ul><li>Services affecting health and safety (i.e. FDA, CDC, etc.) </li></ul><ul><li>FBI </li></ul><ul><li>Congress </li></ul><ul><li>Each federal agency has developed a contingency plan identifying those programs/services deemed “essential”. </li></ul>
  8. 10. <ul><li>Discretionary Spending </li></ul><ul><li>Vs. </li></ul><ul><li>Entitlement Spending? </li></ul><ul><li>The Economic Stimulus Bill (ARRA) Vs. traditional appropriations? </li></ul>
  9. 11. Who is the Rural Safety Net?
  10. 14. <ul><li>The Affordable Care Act </li></ul>
  11. 15. <ul><li>On March 23, 2010 President Obama signed the Patient Protection and Affordable Care Act into law . </li></ul>
  12. 16. <ul><li>Reimbursement Incentive Study and Report </li></ul><ul><li>STUDY- The Secretary of Health and Human Services </li></ul><ul><li>shall carry out, or contract with a private entity to carry out, </li></ul><ul><li>a study that examines methods to create efficient </li></ul><ul><li>reimbursement incentives for improving health care quality </li></ul><ul><li>in Federally qualified health centers, rural health clinics , </li></ul><ul><li>and free clinics. </li></ul><ul><li>(2) REPORT- Not later than 2 years after the date of the </li></ul><ul><li>enactment of this Act, the Secretary of Health and Human </li></ul><ul><li>Services shall submit to the appropriate committees of </li></ul><ul><li>jurisdiction of the House of Representatives and the Senate </li></ul><ul><li>a report on the study carried out under paragraph (1). </li></ul>
  13. 17. Collaboration with FQHCs <ul><li>The ACA has language directing that the Health Resources and Services Administration encourage greater collaboration/cooperation between FQHCs and other safety net providers: </li></ul><ul><li>RHCs </li></ul><ul><li>CAHs, </li></ul><ul><li>Small Community Hospitals </li></ul>
  14. 18. RHC Technical Assistance Call <ul><li>Contracting and Collaboration Opportunities Monday, December 13, 2010, 2 PM EST </li></ul><ul><li>Go to: </li></ul><ul><li>http://www.hrsa.gov/ruralhealth/policy/confcall/index.html </li></ul>
  15. 19. <ul><li>The Independent Payment Advisory Board is established to develop and submit “proposals” to Congress and the private sector aimed at extending the solvency of Medicare, lowering health care costs, improving health outcomes for patients, promoting quality and efficiency, cure cancer, solve global warming and bring about the end to nuclear proliferation… </li></ul>
  16. 20. Medicare Payment Changes <ul><li>PProvide a 10% bonus payment to primary care physicians in Medicare from 2011 through 2015. </li></ul><ul><li>CContinues the 5% payment increase for certain mental health services that was instituted by the Medicare Improvements for Patients and Providers Act (MIPPA) until December 31, 2010 . </li></ul>
  17. 21. Medicare Payment Changes <ul><li>Provide a 10% bonus payment to primary care physicians and to general surgeons practicing in health professional shortage areas, from 2011 through 2015. </li></ul>
  18. 22. Medicaid Expansion <ul><li>Beginning in 2014, Medicaid eligibility will be expanded to mandate coverage of individuals making up to 400% of federal poverty level. </li></ul><ul><li>Rural providers should benefit from this as more individuals without health insurance will present to rural providers. </li></ul><ul><li>Potential downside is that individuals with employer sponsored health insurance could see their employer drop health insurance and these individuals could move to Medicaid. In general, Medicaid payments are lower than commercial insurance payments </li></ul>
  19. 23. Questions for Consideration <ul><li>Will there be an on-going need for a healthcare safety net post-2018? </li></ul><ul><li>What will the safety net look like in 2018? </li></ul><ul><li>How will healthcare be delivered in the future? </li></ul><ul><li>Will we need Community Health Centers, Rural Health Clinics, etc. in the future? </li></ul>
  20. 24. Healthcare Reform – Timeline The Challenge of Change
  21. 25. Provisions already implemented Provide dependent coverage for adult children up to age 26 for all individual and group policies. This provision takes effect on September 23 rd . However, companies do not have to make this available until the scheduled renewal of the company’s policy.
  22. 26. <ul><li>Small employers (those with no more than 25 employees and average annual wages of less than $50,000 that purchase health insurance for employees) are eligible for a federal tax credit to help cover the cost of providing health insurance for their employees. </li></ul>Provisions already implemented Small Employer Tax Credit
  23. 27. Small Employer Tax Credit <ul><li>Maximum Amount.  The credit is worth up to 35 percent of a small business' premium costs in 2010. On Jan. 1, 2014, this rate increases to 50 percent. </li></ul><ul><li>Phase-out. The credit phases out gradually for firms with average wages between $25,000 and $50,000 and for firms with the equivalent of between 10 and 25 full-time workers.  </li></ul>
  24. 28. <ul><li>Eligibility Rules </li></ul><ul><li>Providing health care coverage. A qualifying employer must cover at least 50 percent of the cost of health care coverage for some of its workers based on the single rate. </li></ul><ul><li>Firm size. A qualifying employer must have less than the equivalent of 25 full-time workers (for example, an employer with fewer than 50 half-time workers may be eligible). </li></ul><ul><li>Average annual wage. A qualifying employer must pay average annual wages below $50,000. </li></ul>Provisions already implemented
  25. 29. IRS Information Available <ul><li>www.irs.gov/newsroom/article/0,,id=221511,00.html </li></ul>
  26. 30. Pre-Existing Condition Insurance Program (PCIP) <ul><li>The PCIP initiative is in place in all 50 states and the District of Columbia. </li></ul><ul><li>This is either a state-run initiative or in the absence of a state program, a federally enrolled product. GEHA – Government Employees Health Association. </li></ul><ul><li>https:// www.pcip.gov / </li></ul>
  27. 31. https:// www.pcip.gov/StatePlans.html <ul><li>The Pre-Existing Condition Insurance Plan may vary depending on what state you live in. The U.S. Department of Health and Human Services will run the Pre-Existing Condition Insurance Plan in some states, and is contracting with a national insurance plan (GEHA) to administer benefits in those states. Other states have requested that they run the program themselves, and each of those states has the flexibility to design the program that best meets their state’s needs. </li></ul>
  28. 32. ACO and Workforce
  29. 33. <ul><li>HEALTH WORKFORCE EVALUATION & ASSESSMENT </li></ul><ul><li>National Health Care Workforce Commission </li></ul><ul><li>Establishes the National Health Care Workforce Commission to serve as a national resource for the purpose of assessing if the demand for health care workers is being met, identify barriers to coordination between federal, state and local levels, and encourage innovations. </li></ul><ul><li>National Care Workforce Assessment National Center for Health Workforce Analysis </li></ul><ul><li>Establishes the National Center for Health Workforce Analysis for the purpose of working in cooperation with the National Health Care Workforce Commission to: </li></ul><ul><li>Develop information describing and analyzing the health care workforce and workforce related issues </li></ul><ul><li>Implement those activities </li></ul><ul><li>Evaluate programs, and </li></ul><ul><li>Establish and publicize a national internet registry of grant awards and a database to collect data from evaluations on performance measures. </li></ul>
  30. 34. What impact will workforce policy have if the payer does not recognize the provider? <ul><li>Look at the experience of NPs, PAs, CNMs, PT, OTs, etc. </li></ul><ul><li>What is the correlation between innovative delivery models and improved access to care? </li></ul><ul><li>What is the correlation between improved access to care and the aggregate cost of healthcare? </li></ul>
  31. 35. HCR and Rural Workforce? <ul><li>Will the increased demand for healthcare lead to shortages of health professionals? </li></ul><ul><li>Given the lag time between new workforce expansion and production, will rural providers be recruited to urban/suburban areas to meet demand? </li></ul>
  32. 36. The Politics and Legality of Healthcare Reform
  33. 37. New Deliver Models Shared Savings?
  34. 38. Accountable Care Organizations (ACOs) <ul><li>Are ACOs just a dressed up version of HMOs? </li></ul><ul><li>Will ACOs lead to the “Walmartization” of American Health Care or truly reform the healthcare delivery system in a way that is beneficial to patients? </li></ul>
  35. 39. Accountable Care Organizations
  36. 40. ACOs, Quality and Cost <ul><li>ACOs meeting the quality standards must ALSO demonstrate that they saved Medicare money when compared to the actuarially expected costs for the population “assigned” to the ACO. </li></ul>
  37. 41. Quality and Cost and ACOs <ul><li>ACOs will be required to sign a three year agreement with CMS to operate as an ACO. </li></ul><ul><li>ACOs will be required to meet dozens of quality markers on an annual basis. Many of the quality markers track with the EHR reporting requirements for “meaningful use.” </li></ul>
  38. 42. So what Comes First? <ul><li>Cost Savings Quality </li></ul>
  39. 43. According to CMS – Cost Savings! <ul><li>“… ACOs will only share in savings if they first generate shareable savings and then meet the quality standards .” </li></ul><ul><li>NPRM, page 24 </li></ul>
  40. 44. How Will ACOs affect RHCs and other safety net providers? Rural Health Clinics, FQHCs and CAHs can be part of an ACO. Rural Health Clinics, FQHCs and CAHs that are part of an ACO can continue to receive cost-based reimbursement from Medicare. However, How patients will be “assigned” or “attributed” to an ACO could affect RHC and FQHC participation.
  41. 45. ACOs and Rural <ul><li>Although RHCs and FQHCs will be allowed to form RHC exclusive or FQHC exclusive ACOs, as a practical matter this will not be possible under the current formulas </li></ul>
  42. 46. ACOs and Rural <ul><li>Minimum of 5,000 Medicare beneficiaries “assigned” to the ACO. </li></ul><ul><li>In order for a patient to be “assigned” he or she MUST have been seen by a primary care physician at least once during the previous 12 months </li></ul>
  43. 47. ACOs and Rural <ul><li>ACOs including RHCs and FQHCs are eligible for an additional “bonus” payment for including RHCs and FQHCs in their ACO </li></ul>
  44. 48. Are ACOs the same as Value-Based Purchasing or Bundled Payments? <ul><li>NO </li></ul>
  45. 49. Bundled Payments <ul><li>A national pilot program geared towards inpatient care that would pay the provider a “bundled” payment (super DRG) for the full continuum of care provided as a result of a hospitalization (surgical or medical). </li></ul><ul><li>Payment will cover care provided immediately prior to admission, admission, post-hospital care (SNF or home health). </li></ul>
  46. 50. Bundled Payments <ul><li>To the extent that bundled payment arrangements encourage providers to become more efficient in the delivery of care, these arrangements can also benefit providers financially. Any reductions in unnecessary care that result from bundling can improve the quality of care. - GAO </li></ul>
  47. 51. What is Value Based Purchasing? <ul><li>Under VBP Medicare (and eventually other payers) will base payment on “quality”. CMS will use the data collected via the PQRI/S process to define what constitutes a “quality” service. </li></ul>
  48. 52. What is Value Based Purchasing (VBP) <ul><li>The premise behind value based purchasing is that Medicare pays a predetermined amount of money for a service based simply on the fact that it was delivered and does not determine the “quality” of the service provided. </li></ul><ul><li>Under VBP, Medicare will no longer just pay for a rendered service at the preset price but instead, will adjust that price to reflect the quality of the service. </li></ul>
  49. 53. Value-Based Purchasing and the PQRI/S initiative <ul><li>Key Dates </li></ul><ul><li>January 1, 2012 , CMS publishes the quality and costs measures </li></ul><ul><li>January 1, 2013 , CMS begins using the payment modifier </li></ul><ul><li>January 1, 2015 , CMS fully implements value based purchasing </li></ul>
  50. 54. Providers who fall into Quartile 1 would receive a reduced Payment. Providers who fall into Quartile 2 and 3 would receive “regular” payment. Providers who fall into Quartile 4 would receive a “bonus”
  51. 55. Is the Data Being collected under PQRI/S reflective of the physician specialty being analyzed? <ul><li>Serious concerns have been raised by a number of physician organizations that the low level of participation by some physicians would result in conclusions that are not reflective of care provided by that specialty. </li></ul><ul><li>The quality markers adopted by CMS for those specialties could be inaccurate. </li></ul>
  52. 57. Legal Challenges <ul><li>28 states have filed suit challenging the constitutionality of the Affordable Care Act. </li></ul>
  53. 58. Legal Challenges to ACA <ul><li>Two Key issues raised by the States: </li></ul><ul><li>Can the federal government require people to purchase health insurance </li></ul><ul><li>Can the federal government mandate expansion of the Medicaid program as directed under the ACA? </li></ul>
  54. 59. Repeal, Replace? <ul><li>On January 19 th , the House passed a bill repealing the Patient Protection and Affordable Care act by a vote of 245-189. </li></ul><ul><li>Subsequent to the House vote, the U.S. Senate rejected a proposal to repeal the Patient Protection and Affordable Care Act. </li></ul>
  55. 61. Other Issues
  56. 62. 3% Withholding and Physicians <ul><li>The 3% withholding law, which was enacted in 2005 and mandates that federal, state, and local governments withhold 3% of nearly all of their contract payments, including Medicare payments, as part of a “tax compliance” initiative. </li></ul><ul><li>This provision is slated to take effect on January 1, 2012. </li></ul><ul><li>The IRS has proposed to exempt federal payments that are less than $10,000 during a normal payment cycle. </li></ul>
  57. 63. EHR Incentive Payments <ul><li>Medicare </li></ul><ul><li>Medicaid </li></ul>
  58. 64. Medicaid EHR Incentive Payments
  59. 65. Medicaid EHR Incentive Payments <ul><li>Physicians, NPs, CNMs and some PAs working in an RHC are eligible for EHR incentive payments under Medicaid. </li></ul><ul><li>Physicians must choose whether to receive a Medicare incentive payment OR a Medicaid incentive payment – cannot get both! </li></ul>
  60. 66. Rural Health Clinic and FQHC EHR Incentive Payments <ul><li>Eligible Professionals (physician, NP, CNM or certain PAs) must deliver a majority of the care they provide to patients in an RHC or FQHC in order to be eligible for the incentive payment. </li></ul><ul><li>In the case of PAs, the RHC or FQHC must be “PA led”. </li></ul>
  61. 67. Who is a “Needy Individual” <ul><li>Someone who is receiving assistance under Medicaid </li></ul><ul><li>Someone who is receiving assistance S-CHIP </li></ul><ul><li>Someone who is furnished un-compensated care by the provider; </li></ul><ul><li>Someone for whom charges are reduced by the provider on a sliding scale basis based on an individual's ability to pay. </li></ul>
  62. 68. What is PA led? <ul><li>A “PA led” Clinic is, </li></ul><ul><li>(1) When a PA is the primary provider in a clinic (for example, an RHC with a part-time physician and full-time PA, would be considered “PA led”); or </li></ul><ul><li>(2) When a PA is a clinical or medical director at a clinical site of practice; or </li></ul><ul><li>(3) When a PA is an owner of an RHC </li></ul>
  63. 69. Medicaid EHR Incentive Payments <ul><li>Year 1 - $25,000 (adopt, implement or upgrade) </li></ul><ul><li>Year 2 - $10,000 MU </li></ul><ul><li>Year 3 – $10,000 MU </li></ul><ul><li>Year 4 - $10,000 MU </li></ul><ul><li>Year 5 - $8,750 MU </li></ul><ul><li>Payments are available until 2021 </li></ul>
  64. 70. Medicare <ul><li>Physicians </li></ul><ul><li>Hospitals </li></ul><ul><li>CAHs </li></ul>
  65. 71. Medicare EHR <ul><li>Physicians meeting the meaningful use criteria are eligible for EHR incentive payments based upon their fee schedule billing. </li></ul><ul><li>1 st year - $18,000 </li></ul><ul><li>2 nd year - $12,000 </li></ul><ul><li>3 rd year - $8,000 </li></ul><ul><li>4 th year – $4,000 </li></ul><ul><li>5 th year - $2,000 </li></ul>
  66. 72. <ul><li>Hospital (non-CAH) Incentive payments </li></ul><ul><li>$ 2 Million per hospital plus additional incentive payments based upon hospital admissions if above 1,149. </li></ul><ul><li>For Each discharge above 1,149 and below 23,000, the hospital gets an incentive payment of $200 per discharge. </li></ul>
  67. 73. <ul><li>Critical Access Hospitals </li></ul><ul><li>The Secretary shall compute reasonable costs by </li></ul><ul><li>expensing such costs in a single payment year and not depreciating such costs over a period of years (and shall include as costs with respect to cost reporting periods beginning during a payment year costs from previous cost reporting periods to the extent they have not been fully depreciated as of the period involved). </li></ul>
  68. 74. <ul><li>There shall be substituted for the Medicare share that would otherwise be applied under paragraph a percent (not to exceed 100 percent) equal to the sum of-- </li></ul><ul><li>The Medicare share (as would be specified under paragraph (2)(D) of section 1886(n)) for such critical access hospital if such critical access hospital was treated as an eligible hospital under such section; and 20 percentage points </li></ul>
  69. 75. Double dipping? <ul><li>An eligible professional shall not qualify as a Medicaid provider under this subsection unless any right to payment under Medicare with respect to the eligible professional has been waived. </li></ul>
  70. 76. New Medicare Enrollment Fee <ul><li>Effective Friday, March 25, 2011, all NEW providers enrolling in Medicare will be required to pay an application fee as a condition for enrolling in Medicare. </li></ul><ul><li>The application fee is $505.00. RHC can seek a waiver of the fee base on “hardship”. CMS has not issued guidelines for  qualifying for a hardship exception. </li></ul>
  71. 77. 5010 Standards
  72. 78. <ul><li>December 31, 2010 - Internal testing of Version 5010 must be complete to achieve Level I Version 5010 compliance </li></ul><ul><li>January 1, 2011 - Payers and providers should begin external testing of Version 5010 for electronic claims </li></ul><ul><li>CMS begins accepting Version 5010 claims but Version 4010 claims continue to be accepted. </li></ul><ul><li>January 1, 2012 – All covered entities must be fully compliant and must be able to conduct electronic transactions using the 5010 standards. </li></ul>
  73. 79. <ul><li>RHC Rules and Regulations </li></ul><ul><li>Proposed changes in RHC Rules and Regulations Issued on June 27 2008. </li></ul><ul><li>Final Rule MUST be issued by June 27, 2011 or the package must be rescinded. </li></ul>
  74. 80. <ul><li>It is not a certainty that CMS will move to release the RHC FINAL rule by June 28, 2011. </li></ul>
  75. 81. <ul><li>The Patient Protection and Affordable Care Act (Healthcare Reform) legislation, mandated that the Secretary of HHS appoint a “Negotiated Rulemaking” Committee to consider possible changes in the methodology used to designate areas as medically underserved or health professional shortage areas. </li></ul>
  76. 82. <ul><li>In May, Ron Nelson, PA-C, Associate Executive Director of NARHC and Alan Morgan were appointed to the Negotiated Rulemaking Committee. </li></ul>
  77. 83. Negotiated Rulemaking Committee <ul><li>Issues under consideration: </li></ul><ul><li>How to define a rational service area? </li></ul><ul><li>What is the proper ratio/threshold? </li></ul><ul><li>What Providers get Counted? </li></ul>
  78. 84. Negotiated Rulemaking Committee Update <ul><li>Time Line </li></ul><ul><li>Process </li></ul><ul><li>Consensus </li></ul><ul><li>Public Comment </li></ul>
  79. 85. <ul><li>Policy Changes being pursued by NARHC during the 112 th Congress </li></ul>
  80. 86. Linking Quality and Payment in RHCs <ul><li>The Patient Protection and Affordable Care Act directed the Secretary of HHS to analyze and make recommendations to Congress on how to link payments to RHCs, FQHCs and Free clinics to quality incentives/quality outcomes. </li></ul><ul><li>George Washington University has been awarded the contract to do this research and NARHC Executive Director Bill Finerfrock has been appointed to the GW Advisory Committee as a Subject Matter Expert. </li></ul>
  81. 87. RHC Technical Assistance <ul><li>NARHC in conjunction with the Federal Office of Rural Health Policy conducts RHC Technical Assistance teleconference calls on topics of specific interest to the RHC community. </li></ul><ul><li>In addition, ORHP support the maintenance of the RHC Listerve (NARHC News) </li></ul>
  82. 88. To view transcripts or download audio recordings of previous calls <ul><li>http://www.hrsa.gov/ruralhealth/policy/confcall/index.html </li></ul>
  83. 89. <ul><li>To sign up for both the RHC TA listserve as well as the NARHC NEWS listserve, go to: </li></ul><ul><li>Send an email to [email_address] from the email address you would like to get the messages and we will get you signed up. </li></ul>
  84. 90. Be on the look out <ul><li>The Senate Rural Health Caucus and the House Rural Healthcare Coalition are drafting a new Rural Health Bill that should be ready for introduction in the not-too-distant future. </li></ul>
  85. 91. Bill Finerfrock Senior Vice President Health Policy Capitol Associates 202-544-1880 [email_address]

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