CMS Region 5 Convenes Stakeholder Meeting in Chicago

May 28, 2019

The Centers for Medicare & Medicaid Services (CMS) Region 5 office convened an in-person meeting of state hospital associations and medical societies in Chicago on May 21. CMS Region 5 includes Wisconsin, Michigan, Illinois, Minnesota, Indiana, and Ohio. Face-to-face meetings, which are generally held annually, give associations an opportunity to hear updates on Medicare and Medicaid programs from CMS staff as well as respond directly to questions from attendees. WHA Vice President of Policy Development Laura Rose represented WHA at the meeting. CMS staff covered the following issues:

Provider-Based Departments and Site Neutrality: On May 3, CMS issued draft guidance on application of exclusive use requirements in the Medicare Conditions of Participation for PPS and CAH hospitals that implicates hospital co-location and shared services arrangements. WHA summarized the guidelines in the May 14 issue of The Valued Voice. Comments on the draft guidance are due July 2 and WHA will prepare comments on behalf of its members.

CMS staff and attendees engaged in a lengthy discussion on how to code patient visits to multiple provider sites in one day under the new guidelines. There was substantial confusion on which modifiers to attach to these visits when coding them to get the appropriate reimbursement. CMS staff will investigate this issue and provide additional guidance to the region, and WHA will follow up with members in a future Valued Voice article.

S-10 Audits: The three Medicare Audit Contractors in the region discussed Medicare’s Cost Report Worksheet S-10, which captures uncompensated care data. S-10 audits of charity care are intended to be used to distribute an $8 billion charity care pool. CMS is working with the contractors, providers, and hospital associations to improve the S-10 process. The contractors are conversing with CMS on the future of S-10 and how to reduce the number of cost report appeals. There are currently about 10,000 appeals annually and a lot of administrative work is involved in processing these appeals.

Patients over Paperwork: CMS is working on a prototype for a Document Requirements Lookup Service This service will allow providers to discover, in their electronic health records, what requirements exist for prior authorization, documentation and other issues. The service will offer templates and other tools for provider use in meeting these requirements. Coverage Requirements Discovery and Documentation Templates and Coverage Rules are currently being pilot tested. There are multiple ways to become involved, and interested providers are encouraged to contact CMS for further information.

Promoting Interoperability: CMS staff discussed a proposed rule released on February 11 which sets out requirements for providers to increase EHR interoperability. Comments on the proposed rule are due June 3, and WHA staff is in the process of preparing comments. The proposed rule includes requirements for health information exchange (HIE) and care coordination across payers. It also includes a Request for Information on how post-acute settings can improve interoperability. WHA staff will provide information in The Valued Voice to members on comments once they are submitted to CMS.

Opioid Initiative: CMS’ opioid initiative addresses prevention, treatment, and data gathering. Staff noted that two million people in the U.S. suffer from opioid use disorder, but only 20% get treatment. The Substance Abuse and Mental Health Services Administration website has information on provider distribution across the country. New models for care and payment (the Maternal Opioid Misuse and Integrated Care for Kids models) are attempting to align substance abuse treatment with primary care.

A safety edit, which establishes a seven-day limit on opioid prescriptions and stops the pharmacy from processing a prescription until an override is entered or authorized by the plan within Medicare Part D, has been established for “opioid naïve” recipients (patients who are not chronically receiving opioid analgesics on a daily basis). Patients in long-term care facilities, hospice or palliative care, and those being treated for active cancer-related pain are exempt from the policies.

An HHS inter-agency task force on pain management best practices has issued a draft report.

New Medicare Card: CMS staff noted that patients are not consistently using their new Medicare cards, which use a new Medicare Beneficiary identifier for Medicare transactions. CMS and Medicare Audit Contractors want to see more claims using the identifier because the full implementation date is January 1, 2020, and the current utilization rate is about 70% across the country.

Medicare Advantage: Currently, about 35% of Medicare recipients are on Medicare Advantage. CMS summarized changes to Medicare Advantage, which include:

  • A 2.5% increase in payment rates for this year
  • Encouraging use of naloxone by lowering copays to combat prescription opioid overuse
  • Providing more supplemental benefits in Medicare Advantage plans to address social determinants of health for the chronically ill

Attendees urged CMS to include the new Medicare beneficiary identifier on the Medicare Advantage cards. CMS was also encouraged to pursue more standardization of forms and processes used by all the different Medicare Advantage plans.

Quality Payment Program 2019 updates: CMS staff summarized the updates to the Quality Payment Program that were finalized in November 2018. WHA’s November 6, 2018, Valued Voice outlined the changes.

This story originally appeared in the May 28, 2019 edition of WHA Newsletter