September 9, 2016
Volume 60, Issue 36

WHA Submits Comments on OPPS Proposed Rule
“CMS must revamp its proposed [HOPD] policy entirely” 

The Wisconsin Hospital Association submitted comments to the Centers for Medicare & Medicaid Services (CMS) on its FY 2017 proposed Outpatient Prospective Payment System (OPPS) Rule. Those comments focused primarily on problems with the agency’s implementation of the Bipartisan Budget Act 2015’s (BBA 2015) Section 603 related to payments under the OPPS for services in hospital outpatient departments (HOPDs). 

“WHA believes CMS must revamp its proposed policy entirely and establish one that provides for appropriate reimbursement to hospitals for services delivered and to ensure that Medicare patients have continued access to high quality care in their local communities,” said WHA President/CEO Eric Borgerding in the letter.

In its proposed rule, CMS states that complexities in its own systems would require it to make no payment in 2017 to hospitals for services that are not grandfathered under the BBA 2015 Section 603. 

“The agency has a responsibility to develop or use mechanisms it has used in the past to provide reasonable payment to hospitals. It should not implement these policies until it addresses this unfairness,” Borgerding said. 

Further, the agency proposes an extremely inflexible and limited view of the underlying statute. Under CMS’s proposal, grandfathered HOPDs would essentially not be allowed to relocate, rebuild or alter services without risking grandfathered status. 

“WHA disagrees with using this approach and believes CMS’s policy will work counter to providing the most efficient, patient-centered care because it will lock into place a delivery system structure based on a snapshot in history,” said Borgerding. “We believe CMS’s approach may result in less coordinated care and less access to care for Medicare beneficiaries for various services. We cannot believe this is an outcome Medicare or its beneficiaries would desire.”

WHA also urged CMS to specifically address partial hospitalization programs (PHPs), which provide critical, comprehensive mental health care services in the outpatient setting. WHA strongly believes these PHPs could be exempt from Section 603 and CMS’s implementation policies. 

“At issue with these critical mental health care services under Section 603 is that they are not reimbursable in a like way under any other Medicare reimbursement schedule. Further, CMS’s proposed policy would make no payment whatsoever to hospitals for establishing new, much-needed access points for these mental health care services,” Borgerding said. “WHA believes failure to address the PHPs will mean new outpatient treatment services will likely not materialize in communities where need is greatest.” 

WHA also provided comments on proposed changes included in the rule related to the Medicare and Medicaid Electronic Health Records Incentive Programs.

Read WHA’s full comment letter at

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Assembly Republicans Release Forward Agenda
Health care workforce, mental health policy key aspects of health care agenda

On September 7, Assembly Speaker Robin Vos (R-Burlington) and several members of the Assembly Republican caucus announced their 2016 version of the Forward Agenda, a document developed to identify key issues that Assembly Republicans plan to address in the upcoming session. Watch their announcement on Wisconsin Eye at under news conferences. 

In that document, the Republican caucus identified Wisconsin’s health care workforce shortage as a critical issue that needs to be addressed in the next legislative session—including the elimination of licensing burdens and exploration of additional ways to create more residency and clinical experience opportunities for physicians and other health care workers. 

The agenda also identified a need to review and reform Wisconsin’s mental health delivery regulations in order to change those regulations that are creating barriers for treatment in mental health care. 

The document also identified the need to look at incentivizing and encouraging more “transitions of care management programs” and other “team-based care approaches” that utilize further coordination of care in the Medicaid program.

“We applaud elements of the Assembly Republican’s ‘Forward Agenda’ that focus on key challenges facing Wisconsin’s health care system, including addressing issues related to providing mental health care, better coordinating care in the Medicaid program, and the critical challenge of ensuring an adequate supply of health care professionals to meet the growing demand for medical services in multiple settings,” said WHA President/CEO Eric Borgerding in a press statement released after the Speaker’s announcement. 

“Good health care policy makes good politics, and WHA looks forward to continuing its partnership with all members of the Legislature to enact policies that strengthen and protect Wisconsin’s high-quality, high-value health care system,” said Borgerding.

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Disburse Conduit Funds by November 8
WI Hospitals State PAC & Conduit Progress; Next contributor list Sept. 23 

The Wisconsin Hospitals State PAC & Conduit campaign is making progress on raising funds, and with the November 8 election just two months away, disbursing those dollars now to candidates for state office who value hospitals and health systems is extremely important. 

“Now is the time for Wisconsin Hospitals conduit members to contribute to candidates across the state where support is needed,” said Nora Statsick, WHA political affairs.

As a reminder, individuals who contribute to the Wisconsin Hospitals Conduit retain full control over their funds. Once deposited, conduit funds remain until the account holder authorizes the release of those dollars to candidates or party committees of their choosing. 

“House Speaker Tip O’Neill coined the phrase, ‘All politics is local,’ and I know some donors prefer to contribute to candidates in their local area,” said Statsick. “However, it is important to keep an open mind and recognize the impact your funds can have in supporting party committees and candidates across the state who value hospitals.”

To check conduit balances or discuss disbursing conduit dollars to candidates, please contact Nora Statsick, WHA political affairs, at or by phone at 608-239-4535. 

The Wisconsin Hospitals State PAC & Conduit campaign topped $232,000 from 276 individuals, putting the campaign at 78 percent of its aggressive $300,000 goal. With elections on November 8, contribute and disburse conduit funds now in order to support candidates who value the role of hospitals and health systems in Wisconsin. Better candidates lead to better legislators who craft better laws. 

So far in 2016, 48 new contributors have come on board and 61 individuals have contributed at one of the campaign’s Club Levels, which begin at $1,500. In this pivotal year, state elections matter and participation is important. 

Contribute today to be on the next contributor list that will run in the September 23 edition of the WHA Valued Voice newsletter. Contribute online at or call WHA’s Jenny Boese at 608-268-1816.

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Today’s Challenges, Tomorrow’s Opportunities: A Future Leader’s Guide to Wisconsin Health Care
November 16, 2016 *** Marriott Madison West, Middleton

This important one-day event will focus on the role the next generation of health care leaders will play in effectively addressing health care trends. The day’s agenda features national health care consumerism expert Ryan Donohue of National Research Corporation, who will share national research on what’s important to today’s health care consumer. National patient experience expert Kristin Baird will focus on what future leaders can do to improve their organization’s patient experiences and bridge the gap between consumers and hospitals/health care systems.  Register here

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CMS Announces New Options for MACRA Compliance Beginning January 2017

On September 8, Andy Slavitt, acting administrator of the Centers for Medicare & Medicaid Services (CMS) announced new flexibility for eligible clinicians to meet the requirements of Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). MACRA repealed the Sustainable Growth Rate formula, and created new payment methods for clinicians. 

Although the final rule is not yet complete, the first reporting period under MACRA is set to begin January 1, 2017, and the first reimbursement adjustment for physicians under the program based on that reporting period would be in 2019. WHA and other organizations had expressed significant concern about the short implementation time frame and the significant learning curve and thus the ability of clinicians to avoid payment penalties under the program. WHA had the opportunity to express these views at an in-person meeting with Acting Administrator Slavitt in June (see related Valued Voice article.)

Using the umbrella term, Quality Payment Program (QPP), Slavitt said yesterday that clinicians will be able to “pick their pace” of participation by choosing among four options, with one of those options designed to ensure the clinician would not face a payment penalty in the first year. The four options as described by CMS are:

First Option: Test the Quality Payment Program.
As long as the clinician submits some data to the Quality Payment Program, including data from after January 1, 2017, the clinician will avoid a negative payment adjustment. This option is designed to ensure that the clinician’s system is working and that the clinician’s practice is prepared for broader participation in 2018 and 2019. 

Second Option: Participate for part of the calendar year. 
The clinician may choose to submit Quality Payment Program information for a reduced number of days. This means the first performance period could begin later than January 1, 2017 and the clinician’s practice could still qualify for a small positive payment adjustment. 

Third Option: Participate for the full calendar year. 
For practices that are ready to go January 1, 2017, data may be submitted for a full calendar year. This means the first performance period would begin January 1, 2017, and the clinician could qualify for a modest positive payment adjustment. CMS indicates that it has seen physician practices of all sizes successfully submit a full year’s quality data, and expects many will be ready to do so. 

Fourth Option: Participate in an Advanced Alternative Payment Model in 2017.
Instead of reporting quality data and other information, the law allows participation in the QPP by joining an Advanced Alternative Payment Model, such as Medicare Shared Savings Track 2 or 3 in 2017. If the clinician receives enough Medicare payments or sees enough Medicare patients through such a model in 2017, the clinician could qualify for a five percent incentive payment in 2019.

Additional details will be described more fully in the final rule, which CMS indicates will be released by November 1, 2016. WHA has already held one webinar on the part of MACRA called the Merit-Based Incentive Program (MIPS). A second webinar focusing on the Advanced Alternative Payment Models will be held later this fall. Information about this webinar will be shared in a future edition of The Valued Voice

The notice from CMS regarding these four options for participation can be found here.

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WHA and HSHS Testify at Rural Broadband Committee
Telemedicine, health care access tied to broadband

WHA and Hospital Sisters Health System (HSHS) testified to the Legislative Study Committee on Rural Broadband September 7, that affordable, fast and reliable broadband is becoming increasingly connected to improving and ensuring access to health care in Wisconsin, particularly in rural areas of the state, and made recommendations for advancing rural broadband infrastructure.

Matthew Stanford, general counsel, WHA; Kevin Groskreutz, chief information officer for ancillary systems, Western Wisconsin Division, Hospital Sisters Health System; and David Mortimer, director, Innovation Institute, Hospital Sisters Health System, provided testimony to and answered questions from the Committee, which is charged with reviewing the Wisconsin Broadband Expansion Grant Program, including discussing grant criteria and considering alternative methods for encouraging construction of broadband infrastructure.

As the Committee considers how to prioritize state support for rural broadband, WHA recommended the Committee consider that a rural community’s access to health care is impacted by its broadband infrastructure in three key ways:

“One health care access challenge that many rural residents of Wisconsin face is the travel distance between their homes and jobs and health care services,” says Stanford. “For the Medicaid program, travel distance also has a direct impact on Medicaid program expenditures, because Medicaid pays transportation costs for its enrollees to see a health care provider.” 

“Outlying rural health clinics, telemedicine technologies, and e-visits and home health monitoring technologies can help bridge distance-based access to care barriers in rural areas, but those strategies all rely on an affordable, fast and reliable broadband infrastructure,” explains Stanford.

“Access to broadband really leads to improved outcomes,” said Groskreutz. HSHS - St. Joseph’s Hospital in Chippewa Falls and HSHS Sacred Heart Hospital in Eau Claire along with other organizations in the Chippewa Valley applied for and were awarded a grant in 2014 to expand broadband services in rural Eau Claire County. Groskreutz and Mortimer explained that the expansion enabled by the grant benefited both residences as well as health services such as emergency medical services. For example, the expansion enabled EMS to help doctors prepare for incoming patients by transmitting EKG data to the hospital from the field. 

“It’s a win-win for the community and it increases access in areas where we have more and more of a digital divide,” Mortimer said. “In terms of health care, it’s very difficult to have access to the providers you need.”

Stanford, Groskreutz and Mortimer made recommendations for the committee to consider as it reviews the Wisconsin Broadband Expansion Grant Program and ways the State of Wisconsin can work to address rural broadband needs, including: Committee Chair Sen. Howard Marklein (R-Spring Green) said the next meeting will be held in October and will focus on developing specific potential legislative proposals that could be recommended by the Committee.

To watch WisEye’s coverage of this hearing, go to and click on Committees.

A copy of WHA’s testimony can be found here.

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UW Launches Nation’s First Rural Residency Program in Ob-Gyn

With a nationwide shortage of obstetricians and gynecologists, especially in rural areas, the department of obstetrics and gynecology at the University of Wisconsin School of Medicine and Public Health has started the nation’s first rural-residency program to train and provide care to women in rural Wisconsin.

Residency is medical training where newly-graduated doctors practice medicine under the supervision of an attending physician. The Ob-Gyn residency program lasts four years.

“Residents who train in certain settings are more likely to locate their practices in similar settings. We want to give them experience in these underserved areas,” said Dr. Ellen Hartenbach, residency program director and professor of Ob-Gyn at UW. “Since we started the program we’ve already heard from other medical schools in the country interested in starting a similar program. We see a need that has to be addressed.”

Hartenbach adds, “Some women need to drive more than an hour to see an Ob-Gyn. This program plans to train doctors to practice in the rural areas.”

According to the American College of Nurse-Midwives, nearly half the counties in the U.S. do not have an obstetrician/gynecologist. The American Congress of Obstetricians and Gynecologists estimates there will be between 6,000 and 8,800 fewer Ob-Gyns than needed in the United States by the year 2020 and a shortage of possibly 22,000 by the year 2050.

The recruitment for the first rural-track resident is underway. A new rural-track resident will join the program each year.

“We are specifically looking for doctors who want to practice in these rural communities. We train them and hopefully they will stay in Wisconsin,” said John Street, educational program manager for the rural residency program. “This is the perfect example of the Wisconsin idea: work being done at the University going beyond Dane County.”

A report on the physician workforce released last month by the Wisconsin Council on Medical Education and Workforce (WCMEW) emphasized the importance of in-state residencies. WHA President/CEO Eric Borgerding said his Association has focused its efforts on ensuring that as physicians graduate from medical school there is an opportunity for them to complete a medical residency in a Wisconsin community, and then establish practice there. 

“This new Ob-Gyn residency program is another very positive step forward in addressing specific shortages in rural areas,” according to Borgerding. “We know in-state residencies are extremely important in retaining physicians in our state. If a graduate of a Wisconsin medical school completes a residency here, there is a 70 percent chance that physician will practice in Wisconsin.” 

The 2021 Ob-Gyn residency class will have one member, who will be dedicated to hospitals outside of Madison. The training for the resident will begin in July 2017 and the first year will be spent in Madison.

Starting in 2018, the resident will complete rotations in hospitals and clinics in Monroe, Portage, Ripon, Waupun and Watertown. The goal will be to expand to more rural areas in Wisconsin eventually.

The Wisconsin Rural Physician Residency Assistance Program and the UW School of Medicine and Public Health provided funding for this position.

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WHA Legal & Regulatory Webinar Series Highlights Hot Topics for Hospitals 

This fall, several more hot topics will be featured as part of WHA’s Legal & Regulatory Webinar Series.
The upcoming topics include:

Online registration for these sessions, as well as all other sessions scheduled as part of the series, can be found at

There is no registration fee for webinars in this series, but pre-registration is required. The series is intended for WHA hospital and corporate members as a member benefit, and includes a range of topics, each presented by a representative of a WHA corporate member law firm. 

In addition, if you missed any of the previous webinars from this series, the slide decks and audio recordings are available on demand in the WHA Member Portal. Currently, that includes the sessions: “A Practical Approach to Complying with EMTALA” (presented 7-13-16); “Examining the DOL’s Final White Collar Exemption Regulations” (presented 7-19-16); and “Managing Risk in Telemedicine Platforms” (presented 8-31-16). 

If you do not have a member account in the WHA members-only portal, go to and click on “Register” to create an account. If you have questions about how to register, contact Tammy Hribar at or 608-274-1820.

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Enrollment Conference September 19-20—Registration Closes September 13 
Open enrollment for the health insurance exchange coming November 1

The Wisconsin Enrollment Conference is an important educational and networking forum on health insurance access and enrollment will take place on September 19-20 at the Kalahari Resort in Wisconsin Dells. This year, as in past years, the Wisconsin Hospital Association is a sponsor for this event. Since the first health insurance exchange open enrollment period in 2013, hospitals and health systems have devoted staff and resources to help patients understand and enroll in coverage. 

The Conference will have speakers from the Centers for Medicare and Medicaid Services, Kaiser Health News, the National Committee for Quality Assurance, the Department of Health and Human Services Regional office, and numerous local experts. Additionally, by attending the conference, certified application counselors (CACs), navigators, and health insurance agents and brokers can fulfill state training or eight continuing education credits as required by the Wisconsin Office of the Commissioner of Insurance. 

Visit the conference website to register and learn more.

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WCMEW and Wisconsin Collaborative for Rural GME to Host Conference November 15

Highlighting work done to expand graduate medical education (GME) in Wisconsin, the Wisconsin Council on Medical Education and Workforce (WCMEW) and the Wisconsin Collaborative for Rural GME (WCRGME) will be jointly hosting a one-day event that will highlight the challenges and opportunities in expanding GME programs in Wisconsin. “Celebrating Successes & Exploring Opportunities” will be held November 15 at the Inn on the Park in Madison.

The Summit will begin with a “State of the State” on Wisconsin’s GME Efforts, followed by two panel discussions on Wisconsin’s state-funded GME Grant Programs, one including grantees that have started new programs, and another with those that have expanded existing programs.

The afternoon will use a small-group discussion format to focus on: “Investing in Success – garnering broad community support”; “Distance Learning –effectively using technology to deliver training and support remotely”; “Centralizing Rural Training – developing partnerships for efficiency.”

Registration will be open soon. Watch for more information in The Valued Voice.

This event is jointly presented by the Wisconsin Council on Medical Education and Workforce (WCMEW) and the Wisconsin Collaborative for Rural GME (WCRGME).

WCMEW is a multi-stakeholder organization whose purpose is to facilitate strategies to assure an adequate supply of health care providers to meet the needs of Wisconsin citizens today and into the future.

WCRGME was established to address the shortage of rural primary care physicians through the expansion of graduate medical education (GME). It is a network of organizations developing and maintaining rural residency rotations, rural training track residency programs and rural fellowships.

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Help WHA Tell Your Story in the 2016 Community Impact Report

WHA is in the planning stages for its 2016 Community Impact Report. The report will feature stories submitted by members that illustrate the commitment our members have to improve the health of the people who live and work in their communities. Here is a link to the last report.

The report is divided into three categories:

The contributions that hospitals and health systems make to the communities overall health status are often overlooked. At WHA, we believe there is power in numbers. That is why we broadened our request for stories into a new area to include activities related to the implementation of the community health needs assessment. 

The deadline for submitting articles is October 1, 2016. Send them to Mary Kay Grasmick at or call 608-274-1820 for more information on this project.

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Fast Facts from the WHA Information Center: September is Thyroid Cancer Awareness Month

The American Cancer Society has estimated 62,450 new cases of thyroid cancer in 2016. Thyroid cancer is commonly diagnosed at a younger age than most other adult cancers. Nearly 3 out of 4 cases are found in women. And, about two percent of thyroid cancers occur in children and teens.

Data from the WHA Information Center collected in 2015 showed there were 132 inpatient stays for thyroid cancer in Wisconsin and 8,398 outpatient visits, which included outpatient surgery, emergency room, observation and ancillary services over the same time period. 

For more information on thyroid cancer, visit

Data provided by the WHA Information Center (WHAIC). WHAIC ( is dedicated to collecting, analyzing and disseminating complete, accurate and timely data and reports about charges, utilization, quality and efficiency provided by Wisconsin hospitals, ambulatory surgery centers and other health care providers.

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