Wednesday, February 23, 2022
The CMS IPPS for FY 2022 covers the accepted topics, including a 2.5 percent access in the connected bulk for accepted astute affliction hospitals. Some added highlights include:
Under the FY 2022 IPPS Final Rule, for bulk advertisement periods alpha on or afterwards October 1, 2021, hospitals’ GME (weighted and unweighted) and IME FTE counts listed in IRIS abstracts charge bout the absolute GME and IME FTE counts appear on Worksheets E-4 and E, Allotment A of the filed Medicare bulk report. Providers charge additionally use the new Extensible Markup Language (XML)-based IRIS book format, which is advised for bendability with FTE advertisement on the bulk report.
To abode apropos aloft in acknowledgment to the FY 2022 proposed rule, for bulk advertisement periods afore October 1, 2022, hospital bulk letters will not be alone if the IRIS and bulk abode FTE counts do not match. Additionally, to abode abeyant rounding errors, CMS will additionally authorize a altruism alpha for variances amid the bulk abode and IRIS data. CMS will additionally absolution a account of software vendors that accept been accurate to accommodated the new IRIS XML specifications.
CCA/New Address Slots. Separate from the IPPS Final Rule, CMS appear a final aphorism with animadversion aeon on Dec. 27, 2021 to apparatus sections of the Consolidated Appropriations Act of 2021 (CAA) that accommodate for 1,000 new address positions to be broadcast to condoning hospitals from 2023-2027. The CCA additionally allows condoning hospitals to authorize new FTE caps and per-resident amounts. Comments on the GME final aphorism are due February 25, 2022. The GME final rule:
Creates 1,000 new Medicare-funded address positions with up to 200 new positions per budgetary year to be broadcast alpha in FY 2023. Hospitals are prioritized based on HPSA array and four prioritization categories authentic by statute, and they may accept up to 5 FTEs per year depending on the breadth of the specific address program. Applications for anniversary FY are due by March 31 of the above-mentioned year and the online appliance arrangement is accessible at https:// www.cms.gov/Medicare/Medicare-Feefor-Service-Payment/AcuteInpatientPPS/ DGME.
Incentivizes the conception of new rural training clue (RTT) programs, and the accession of added RTTs to absolute burghal bulk programs of the aforementioned specialty, by giving both hospitals a rural clue FTE limitation or, for absolute programs, by adjusting such limitation. CMS will additionally accommodate added FTE citizen slots to any ACGME-accredited affairs in any specialty breadth the association absorb added than 50 percent of the absolute address affairs in a rural area. And during the five-year cap advance window for RTTs, FTE association accommodating in the RTT will not be included in the hospital’s 3-year rolling boilerplate adding (or the cap on the IME IRB arrangement on Medicare bulk reports) during the bulk advertisement periods above-mentioned to the alpha of the applicative hospitals’ bulk advertisement aeon that coincides with or follows the alpha of the sixth affairs year of anniversary rural track.
Allows hospitals that accustomed a actual low or $0 PRA that accommodated assertive belief to authorize new PRA if the hospital trains association in a bulk advertisement aeon alpha on or afterwards Dec. 27, 2020 and afore Dec. 26, 2026. And analogously allows hospitals that accept actual low FTE citizen caps and accommodated assertive belief to accept their cap “adjusted” if the hospital begins training FTE association in a new address affairs in a bulk advertisement aeon alpha on or afterwards Dec. 27, 2020 and afore Dec. 26, 2026.
In acknowledgment to the COVID-19 PHE, CMS accustomed the COVID-19 Treatments Add-on Acquittal (“NCTAP”) for acceptable discharges during the PHE. As CMS anticipates inpatient cases of COVID-19 above the end of the PHE, the NCTAP was continued through the end of the budgetary year in which the PHE ends. As allotment of the NCTAP, CMS provides added payments for acceptable inpatient cases that absorb the use of assertive new articles accustomed or accustomed to amusement COVID-19 (i.e., therapeutics). Hospitals are about reimbursed a anchored acquittal bulk for the casework they accommodate during an inpatient stay, alike if their costs beat that amount. Beneath accepted rules, hospitals may authorize for an added “outlier payment,” but alone back their costs for a accurate accommodating beat a assertive threshold. The NCTAP allows hospitals to authorize for added payments back they amusement patients with assertive new articles accustomed or accustomed to amusement COVID-19. A analysis qualifies for NCTAP if (1) a technology is acclimated that has FDA approval or an EUA with an adumbration for the analysis of COVID-19; (2) the analysis is acceptable for the 20% access in MS-DRG acquittal per the CARES Act, including the hospital documenting a absolute COVID-19 class test; and (3) the bulk of the analysis exceeds the MS-DRG payment. The added acquittal will be according to the bottom of: (1) 65 percent of the operating outlier alpha for the claim; or (2) 65 percent of the bulk of a COVID-19 break above the operating Medicare acquittal (including the 20 percent add-on acquittal beneath area 3710 of the CARES Act) for acceptable cases.
CMS additionally did not agree the angle to abandon the NCTAP on October 1, 2021, for a artefact that is accustomed for new technology add-on payments alpha in FY 2022. Instead, hospitals will be acceptable to accept both NCTAP and acceptable new technology add-on payments for accommodating stays that qualify. As with the NCTAP, this accouterment will administer “through the end of the budgetary year in which the PHE ends, with the new technology add-on acquittal abbreviation the absolute bulk of the NCTAP.” Additionally, the final aphorism has added allotment of additional payments for affection and therapies to amusement COVID-19 during the time of the current PHE.
In the FY 2022 IPPS final rule, CMS added a new admeasurement to the Hospital Inpatient Quality Advertisement (IQR) Affairs that will crave hospitals to abode the allotment of bloom affliction cadre (HCP) who accept accustomed a anesthetic advance adjoin COVID-19. CMS believes it is important to incentivize and clue healthcare provider anesthetic in astute affliction accessories to assure healthcare workers, patients, and caregivers. The numerator of this admeasurement is the accumulative cardinal of healthcare cadre acceptable to assignment in the healthcare ability for at atomic one day during the acquiescence aeon and who accustomed a completed anesthetic advance against COVID-19 back the date the vaccine was aboriginal accessible or on a again breach if revaccination is recommended.
The denominator of the admeasurement is the cardinal of healthcare cadre acceptable to assignment in the healthcare ability for at atomic one day during the acquiescence period, excluding bodies with contraindications to the COVID-19 anesthetic as declared by the CDC. The aboriginal advertisement aeon spanned October 1, 2021 through December 31, 2021 and will be applicative for payments in FY 2023. Then, for CY 2022 and consecutive years, CMS is proposing abstracts accumulating for a abounding year of data
CMS chose not to agree its angle to adapt the Medicaid atom of the DSH blueprint to absolute the Medicaid days to patients acceptable for inpatient hospital casework beneath an accustomed Accompaniment plan or beneath a Area 1115 waiver, breadth Area 1115 canicule would calculation alone if the accommodating accustomed inpatient hospital allowance advantage on those days. CMS affairs to abide to analysis this attached proposal.
CMS accomplished a angle to crave accompaniment Medicaid agencies to accept providers so that the Medicare accommodating cost-sharing amounts can be determined. This is all-important for providers acquisitive to affirmation Medicare bad debt to accede with Medicare’s “must bill” action to Medicaid for dually-eligible patients to attack to aggregate from Medicaid afore gluttonous Medicare bad debt reimbursement.
© Polsinelli PC, Polsinelli LLP in CaliforniaNational Law Review, Volume XII, Cardinal 54
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