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Payment Matters
September 2, 2009
Expensive Consequences: Failure to Report RHQDAPU Data Will Have Significant Impact Under FY 2010 Acute Care IPPS Rule
Hospitals that do not accurately and completely report quality data under the Reporting Hospital Quality Data for Annual Payment Update (RHQDAPU) program stand to lose virtually all of their market basket update for fiscal year (FY) 2010. On July 30, 2009, the Centers for Medicare and Medicaid Services (CMS) released a display copy of the FY 2010 Inpatient Prospective Payment System (IPPS) Final Rule, which includes changes to rebase and revise the market basket update calculation, as well as several important changes to the RHQDAPU program for FY 2010 and beyond.
Changes to the FY 2010 Market Basket Update
In the Final Rule, CMS rebases and revises the structure of both the operating and capital market baskets for the FY 2010 update. The new calculation, which uses FY 2006 data rather than FY 2002, and adds several expense categories, results in a 2.1 percent market basket update for FY 2010 for hospitals that report quality data under the RHQDAPU program. This total market basket update is significantly lower than the market basket update available in FY 2009 of 3.6 percent. Hospitals that fail to report quality data under the RHQDAPU program are subject to a 2.0 percent reduction in their market basket update, resulting in eligibility for only a 0.1 percent update for FY 2010.
Click to continue...New Ambulatory Surgery Center (ASC) Survey Process
By: Howard L. Sollins and Lisa D. Stevenson
In response to an increase in health care associated infections and the growing number of procedures being performed at ASCs, the Centers for Medicare and Medicaid Services (CMS) developed a new ASC survey process that is being rolled out in 12 states. Maryland, Michigan, Maine, New Jersey, North Carolina, Oregon, Utah, Wyoming, Arkansas, Indiana, Florida and Kansas have all volunteered to implement the new survey process. As a result, more than 125 Medicare participating ASCs will be surveyed before September 30, 2009. This will affect any Medicare certified ASC, including freestanding, multi-specialty ASCs as well as an ASC that may be established alongside a medical office.
In conjunction with the Centers for Disease Control (CDC), CMS developed this new survey process to reduce the number of health care associated infections (HAIs) in ASCs. HAIs are infections patients acquire while receiving treatment for medical or surgical conditions. The CDC has seen an increase in the number of HAIs in outpatient settings such as ASCs. The new ASC survey process utilizes an infection control survey tool, a team approach to health surveys for medium and large ASCs, and a case tracer methodology, which tracks patients from admission to discharge.
Click to continue...Lost Revenue, Overpayments and Harsh Sanctions — Updated CMS Enrollment Rules
By: Donna J. Senft
Two changes to the Medicare enrollment rules are not well understood and, unfortunately, the financial implications are significant when the rules are not followed. More recently, CMS is announcing enrollment rule changes in conjunction with the publication of the physician fee schedule rules, rather than publishing regulations specific to the Medicare enrollment process, making it more difficult to monitor enrollment rule changes.
Failure to Report Certain Changes in Enrollment Data
Prior to the 2006 changes in the Medicare enrollment rules, there were no sanctions that could be assessed when a provider or supplier failed to timely update its enrollment data as required under federal rules. With the 2006 rule changes came the authority for CMS to deactivate or revoke billing privileges for certain provider and supplier actions or inactions, including the failure to update enrollment data or respond to a revalidation request. An overview of the 2006 enrollment rule changes appears in an Ober|Kaler Health Law Alert article, "New Enrollment Regulations: Protect Your Current Medicare Participation."
Click to continue...CMS Imposes Significant Limitations on "New" Medical Education Programs Qualifying for IME/GME Reimbursement
By: Thomas W. Coons
Reimbursement under Medicare's Graduate Medical Education (GME) and Indirect Medical Education (IME) payment methodologies is based, in large measure, on the number of full-time equivalent residents (FTE) training in the hospital's program. That number, in turn, is "capped" or limited by the number of FTEs who were training at the hospital during its most recent cost reporting period ending on or before December 31, 1996, subject to certain exceptions. The most notable exception to this cap is one for hospitals that become "new" teaching hospitals. Under CMS's regulations, if the hospital had no allopathic or osteopathic residents in its most recent cost reporting period ending on or before December 31, 1996, and it establishes a new training program on or after January 1, 1995, the hospital may establish a cap based on the number of residents in its new training program. 42 C.F.R. § 413.79(e)
Notably, CMS defines a new medical residency training program in uncomplicated terms, stating that "a new medical residency training program means a medical residency that receives initial accreditation by the appropriate accrediting body or begins training residents on or after January 1, 1995." 42 C.F.R. § 413.79(l). Thus, under the definition, it would seem that whether a program is considered "new" depends on what the accrediting organization determines. On July 31, 2009, however, CMS put on display its final inpatient prospective payment system (IPPS) rule for FY 2010, which contains significant "new program" IME/GME "clarifications," and describes many other considerations that hospitals must take into account.
Click to continue...Tips from the RAC Cave: "RAC Man and QIC Boy Wonder Unmasked"
By: Paul W. Kim and Mark A. Stanley
Thank you for following our RAC Cave series. We hope that you found some of these tips helpful.
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