The National Council for Community Behavioral Healthcare submitted comments in response to CMS' proposed changes to hospital outpatient prospective payment systems and 2011 payment rates. Specifically:
1) They strongly opposed CMS' proposal to exclude hospital costs from calculating payment rates for partial hospitalization services provided by community mental health centers.
2) Including hospital costs is required by statute, and excluding them would reduce CMHC payments by 42% in one year.
3) They urged CMS to continue calculating partial hospitalization rates solely based on hospital costs as required by law and consider phasing in any rate reduction.
An in-depth review of legislative, regulatory and policy updates for elder law in 2017.
Call for a Harrisburg elder law attorney.
Hazen Law Group
2000 Linglestown Rd #202
Harrisburg, PA 17110
(717) 540-4332
https://www.hazenlawgroup.com
The consolidated billing requirement confers on the SNF the billing responsibility for the entire package of care that residents receive during a covered Part an SNF stay and physical, occupational, and speech therapy services received during a non-covered stay.
An in-depth review of legislative, regulatory and policy updates for elder law in 2017.
Call for a Harrisburg elder law attorney.
Hazen Law Group
2000 Linglestown Rd #202
Harrisburg, PA 17110
(717) 540-4332
https://www.hazenlawgroup.com
The consolidated billing requirement confers on the SNF the billing responsibility for the entire package of care that residents receive during a covered Part an SNF stay and physical, occupational, and speech therapy services received during a non-covered stay.
Radiology Part B Billing for Hospital and SNF PatientsJessica Parker
Acceptable HCPCS codes for radiology and other diagnostic services are taken primarily from the CPT-4 portion of HCPCS. Payment is the lower of the charge or the Medicare physician fee schedule amount.
Back to the Future... Will CMS' Proposed Provider-Based Rules Reshape the Fut...Polsinelli PC
Polsinelli's Reimbursement Institute presents a special 2-part webinar series, in which it will provide an in-depth analysis of the provider-based changes enacted in the Bipartisan Budget Act of 2015 (Act) and CMS' proposed rules implementing those changes. Virtually overnight, Section 603 of that Act imposed sweeping changes that effectively shut down the development and implementation of new off-campus provider-based hospital outpatient departments.
To implement Section 603, CMS is issuing changes to Medicare's provider-based regulations as part of the CY 2017 Hospital Outpatient Prospective Payment System proposed rule – the first such changes since 2003. This webinar will review the newly proposed regulatory changes, address the practical implications of the proposed rule, and present ideas on how to operationalize CMS's proposals, should they be finalized. This webinar will also highlight potential comment areas that stakeholders should consider.
The latest HRB has been released and details various ACA reminders, PCORI Fees HHS Rules and much more. Check out the slideshare document and be sure to contact us at www.cbiz.com should you have any questions.
PhilHealth Benefits: National Health Insurance Program. Philippine Labor Law requires employers to contribute for the health insurance coverage of their employees through PhilHealth.
Radiology Part B Billing for Hospital and SNF PatientsJessica Parker
Acceptable HCPCS codes for radiology and other diagnostic services are taken primarily from the CPT-4 portion of HCPCS. Payment is the lower of the charge or the Medicare physician fee schedule amount.
Back to the Future... Will CMS' Proposed Provider-Based Rules Reshape the Fut...Polsinelli PC
Polsinelli's Reimbursement Institute presents a special 2-part webinar series, in which it will provide an in-depth analysis of the provider-based changes enacted in the Bipartisan Budget Act of 2015 (Act) and CMS' proposed rules implementing those changes. Virtually overnight, Section 603 of that Act imposed sweeping changes that effectively shut down the development and implementation of new off-campus provider-based hospital outpatient departments.
To implement Section 603, CMS is issuing changes to Medicare's provider-based regulations as part of the CY 2017 Hospital Outpatient Prospective Payment System proposed rule – the first such changes since 2003. This webinar will review the newly proposed regulatory changes, address the practical implications of the proposed rule, and present ideas on how to operationalize CMS's proposals, should they be finalized. This webinar will also highlight potential comment areas that stakeholders should consider.
The latest HRB has been released and details various ACA reminders, PCORI Fees HHS Rules and much more. Check out the slideshare document and be sure to contact us at www.cbiz.com should you have any questions.
PhilHealth Benefits: National Health Insurance Program. Philippine Labor Law requires employers to contribute for the health insurance coverage of their employees through PhilHealth.
The 2020 Hospital Outpatient Prospective Payment System (OPPS) Final Rule has been issued and changes are on the way that can affect your organization’s Medicare reimbursement.
As part of our commitment to help protect and enhance your Medicare revenue, we’ve developed this expert analysis of the FY 2020 OPPS Final Rule to quickly give you insight into the most important changes.
BESLER remains your trusted advisor and we look forward to helping you identify areas of revenue opportunity for your facility.
Read the scenario that you will use for the Individual Projects in ea.pdfashokarians
Read the scenario that you will use for the Individual Projects in each week of the course. The
Centers for Medicare and Medicaid Services (CMS) has taken on a more visible role in health
care delivery. Many changes have transpired to improve patient safety along with the
implementation of additional quality metrics, and these changes impact reimbursement rates
Likewise, the Patient Protection and Affordable Care Act has changed the reimbursement fee
structure of Medicare and Medicaid reimbursement for health care services. Other legislation
including the HITECH Act and the Medicare Authorization and CHIP Reactivation Act of 2015
(MACRA) all impact how healthcare organizations receive reimbursement and demonstrate use
of data to improve quality and delivery of patient care Mr. Magone, CEO of Healing Hands
Hospital, has asked you to join the \"Future of Healing Hands Task Force, and your first
assignment is to work with the Hospital Chief Financial Officer, Mr. Johnson, and provide a
summary of the current regulations regarding Medicare reimbursement including how MACR
impact reimbursement if/when Healing Hands coordinates delivery of services by affiliating with
physician practices For this assignment, write a 2-3 page report that you will deliver to Mr.
Magone on how the new CMS initiatives and regulations impact the organization\'s revenue
structure. In your presentation, address the following questions: Why did CMS become more
involved in the reimbursement component of health care? How does CMS\'s involvement impact
the reimbursement model for Healing Hands Hospital and other health care organizations If
CMS reimbursement regulations for Medicare and Medicaid change, does it follow that other
insurance providers change heir policies on reimbursement? What tools can be implemented to
ensure organizations such as Healing Hands Hospital and physician practices are meeting the
policies and procedures set forth by CMS? Identify 3 tools from the CMS Web site that are
helpful in meeting the requirements for Medicare reimbursement set forth by CMS
Solution
Part-a & part-b:
The physician’s work, practice expense, and malpractice, RVU values, CMS (centers for
Medicare and Medicaid services) is required to control overall expenditures in health care
organization. Therefore, CMS become highly involved in the reimbursement component of
health care to patients as per their \"insurance packages\". The CMS\' involvement in “budget
Neutrality” & the reimbursement model at Healing Hand hospital & other health care
organizations is mainly for physician RVU based payments from Medicare & Medicare that can
control its physician costs by adjusting physician payment rates based on “previous periods in a
calendar year” as per federal acts and regulations. The Medicare is going to control physicians
costs according to “medical procedures and medical visits of their record” in a Jan- 1 ending Dec
31. Conversion Factor is main basis to control the physician costs ac.
The Center for Medicare & Medicaid Innovation (CMS Innovation Center) hosted a webinar to discuss various aspects of the Advancing Care Coordination through Episode Payment Models (EPMs); Cardiac Incentive Payment Model; and changes to the Comprehensive Care for Joint Replacement Model final rule on Wednesday, February 22, 2017, from 12:00 p.m. – 1:00 p.m. EST. The final rule was displayed at the Federal Register on December 20, 2016 and is effective on February 18, 2017.
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CMS Innovation Center
http://innovation.cms.gov
We accept comments in the spirit of our comment policy:
http://newmedia.hhs.gov/standards/comment_policy.html
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http://cms.gov/About-CMS/Agency-Information/Aboutwebsite/Privacy-Policy.html
On July 31, 2014, the Centers for Medicare and Medicaid Services (CMS) issued the Final Rule under the Medicare Program: Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities to be implemented on October 1, 2014. This seminar will discuss the impact of Fiscal Year 2015 Medicare payment rate increases for Skilled Nursing Facilities (SNFs) and will review the most recent Office of Management and Budget (OMB) statistical area delineations affecting the SNF PPS Wage Index. Learn about the revision to the existing COT OMRA policy. Additionally attendees will be apprised of updates to Chapter 8, Section 30 of the Medicare Benefit Policy Manual (Pub. 100-02) which directs providers on coverage decisions for reasonable and necessary treatment of patient’s illness or injury.
1. August 27, 2010
Donald M. Berwick, MD, MPP, FRCP
Administrator
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Room 445-G, Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, DC 20201
RE: CMS-1504-P: Medicare Program: Proposed Changes to the Hospital Outpatient
PPS and CY 2011 Payment Rates
NOTE: “PARTIAL HOSPITALIZATION” and “PHYSICIAN
SUPERVISION” COMMENTS
Dear Dr. Berwick,
As an association representing community behavioral healthcare provider organizations, the
National Council for Community Behavioral Healthcare (National Council) appreciates the
opportunity to provide comments on the proposed rule titled “Medicare: Proposed Changes to
the Hospital Outpatient Prospective Payment System and CY 2011 Payment Rates….” as
published in the August 3, 2010, Federal Register.
We are specifically providing comments on the proposed partial hospitalization payment rates.
ABOUT THE NATIONAL COUNCIL
The National Council is the unifying voice of America’s behavioral health organizations.
Together with our 1,700 member organizations, we serve our nation’s most vulnerable citizens
— more than 6 million adults and children with mental illnesses and addiction disorders. We are
committed to providing comprehensive, quality care that affords every opportunity for recovery
and inclusion in all aspects of community life.
The National Council advocates for policies that ensure that people who are ill can access
comprehensive healthcare services, and we offer state-of-the-science education and practice
improvement resources so that services are efficient and effective.
“OPPS: PARTIAL HOSPITALIZATION” COMMENTS
The National Council strongly opposes the proposed exclusion of hospital costs from the
calculation of APC rates for partial hospitalization services furnished by community
mental health centers (CMHCs).
2. We urge CMS to reconsider its proposed exclusion of hospital costs from the calculation of APC
rates for partial hospitalization services furnished by CMHCs. Excluding hospital costs in this
calculation is contrary to the express terms of the Social Security Act of section 1833(t)(2)(B)
and CMS's regulation interpreting that statute, 42 C.F.R. § 419.31(b)(1).
Section 1833(t)(2)(B) requires that:
the Secretary shall, using data on claims from 1996 and using data
from the most recent available cost reports, establish relative
payment weights for covered OPD services (and any groups of
services . . .) based on medical . . . hospital costs . . . .
CMS has interpreted this statute to require the use of hospital outpatient claims data and data
from the most recent available hospital cost reports in determining the median costs for the
services and procedures within each APC group. 1 No other sources of data are referenced in the
statute. Thus, the calculation of national APC rates under HOPPS requires the use of hospital
costs.
As is evident in prior preambles establishing APC payments for partial hospitalization under
HOPPS, there is no question that these authorities apply to the calculation of APC rates for
partial hospitalization services furnished by hospital-based partial hospitalization programs and
by CMHCs. The authorities, therefore, require the use of hospital costs in determining APC
rates for partial hospitalization services furnished by both of these types of providers. CMS does
not have discretion under the statute to exclude hospital data from the calculation of APC rates
for CMHC providers. On this basis alone, finalizing the proposed payment methodology for
partial hospitalization services would be contrary to the Social Security Act.
Therefore, the National Council urges CMS to continue to calculate partial hospitalization APCs
based solely on hospital costs, as required by the statute.
Because the proposed reimbursement structure reduces payment for CMHCs by 42 percent in a
single year, we recommend that CMS consider a phase-in of the rate reduction as it has done in
the face of significant changes to other payment rates.
“PHYSICIAN SUPERVISION” COMMENTS
We appreciate the opportunity to discuss physician supervision issues in the 2010 proposed rule.
Physicians are an integral and regular physical presence in partial hospitalization programs. They
are readily available for consultation, face-to-face evaluations, and program oversight. Programs
have well-defined procedures for handling medical and psychiatric emergencies.
The further clarification of physician supervision and the addition of other types of professionals
capable of providing supervision will significantly assist program services across the country and
particularly in rural areas.
1
42 C.F.R. § 419.31(b)(1).
3. Comment on Section 1301 of the Affordable Care Act (ACA)
The ACA specifies that a CMHC provide at least 40 percent of its services to individuals who are
not eligible for Medicare benefits under Title XVIII of the Act. The National Council urges CMS
to issue guidance regarding this provision and further, requests that this guidance stipulate that the
40% threshold applies to all clients treated by the CMHC, regardless of the specific treatment
modality.
Thank you for your consideration of our comments. We look forward to working with CMS and
the Department of Health and Human Services to ensure that Medicare beneficiaries continue to
have access hospital outpatient mental health and partial hospitalization services.
Sincerely,
Linda Rosenberg, MSW
President and CEO