Payment Matters

January 11, 2012

Independence at Home Demonstration: Testing In-Home Primary Care Services

By: Sarah E. Swank

On December 20, 2011, CMS announced that it is seeking applications for the Independence at Home Demonstration (IAH Demonstration). The IAH Demonstration will measure the cost effectiveness and quality of primary services by physicians and nurse practitioners provided in the homes of chronically ill Medicare beneficiaries. Among the goals of the Demonstration is to test whether in-home primary care services reduce hospitalizations, hospital readmissions and emergency room visits. CMS also hopes that the Demonstration will increase access to care, improve patient satisfaction and promote care that matches beneficiary preferences. Those eligible practices interested in participating must complete and submit an application or letter of intent (LOI), as discussed below, by Monday, February 6, 2012.

FY 2012 Wage Index Appeals Due Soon

By: Leslie Demaree Goldsmith

Each year CMS includes its final wage index numbers as part of its final inpatient prospective payment system rule for acute care hospitals. CMS included the FY 2012 wage index numbers in the display copy of the rule posted on its website on August 1, 2010, and formally published in the August 18, 2011 Federal Register. Providers have 180 days to appeal their wage index numbers. The 180-day appeal period has historically been calculated to run from publication in the Federal Register, which would allow appeals for the FY 2012 wage indices to be filed by February 14, 2012. Providers that wish to operate under an abundance of caution may want to file their appeals by January 28, 2012, which uses the earlier date, when CMS posted the display copy on the internet, as the start date for the running of the 180 days.

Bundled Payment Application Deadline Extended until April

By: Sarah E. Swank

CMS announced on January 5, 2012 that it extended the application deadline for Models 2-4 under the Bundled Payment for Care Improvement Initiative to April 30, 2012. Under the Bundled Payment Initiative, providers propose a set price for a single episode of care and then receive a predetermined discount if the target is met. Providers may still apply for Models 2, 3 and 4:

• Model 2: retrospective acute care stays along with post acute care
• Model 3: retrospective post acute care
• Model 4: prospective acute care hospital stays

Sunshine Proposed Rule Sheds Light on Reporting Requirements

By: Sarah E. Swank and William T. Mathias

On December 14, 2011, CMS released the much-anticipated proposed rule implementing the “sunshine” provisions of Section 6002 of the Affordable Care Act (ACA). The proposed sunshine regulation requires certain manufactures of drugs, devices, and biologics to report to CMS information regarding payments and other transfers of value to covered physicians and teaching hospital. Transfers of value include gifts, consulting fees, research activities, speaking fees, meals and travel. In addition, the proposed regulation also would require certain manufactures and group purchasing organizations (GPOs) to report ownership interests in such organizations held by physicians. CMS would make the reported information available on a searchable, public website.