This week, our In Focus section reviews the new Centers for Medicare & Medicaid Services (CMS) Medicare Fee-For-Service FY 2020 proposed rules: the Physician Fee Schedule (PFS), released on July 2019, and Home Health prospective payment system, released on July 11, 2019. For the hospital outpatient department (HOPD) and ambulatory surgical center (ASC) prospective payment systems (PPS) and the End-Stage Renal Disease (ESRD) PPS proposed rules, please see last week’s In Focus here.
Medicare
CMS Medicare Fee-For-Service FY2020 Proposed Rules: Hospital Outpatient Department and End-Stage Renal Disease
This week, our In Focus section reviews the new Centers for Medicare & Medicaid Services (CMS) Medicare Fee-For-Service FY 2020 proposed rules. On July 29, 2019, CMS issued the Calendar Year (CY) 2020 proposed rules for the Physician Fee Schedule (PFS), the hospital outpatient department (HOPD) and ambulatory surgical center (ASC) prospective payment systems (PPS), and the End-Stage Renal Disease (ESRD) PPS. These proposed regulations include payment rate and policy changes for the upcoming calendar year. The comment deadline for all three of these proposed rules is September 27, 2019.
California 2019-20 Budget Overview
This week, our In Focus section reviews the California fiscal 2019-20 budget. California Governor Gavin Newsom signed his first budget, and much of its related legislation on June 27, 2019. The budget appropriates $214.8 billion ($147.8 billion General Fund) in total spending with $19.2 billion in reserves. The total reserves includes $16.5 billion in the Rainy Day Fund, $1.4 billion in the Special Fund for Economic Uncertainties, $900 million in the Safety Net Reserve, and nearly $400 million in the Public School System Stabilization Account.
Dual Eligible Financial Alignment Demonstration Enrollment Update
This week, our In Focus section reviews publicly available data on enrollment in capitated financial and administrative alignment demonstrations (“Duals Demonstrations”) for beneficiaries dually eligible for Medicare and Medicaid (duals) in nine states: California, Illinois, Massachusetts, Michigan, New York, Ohio, Rhode Island, South Carolina, and Texas. Each of these states has begun either voluntary or passive enrollment of duals into fully integrated plans providing both Medicaid and Medicare benefits (“Medicare-Medicaid Plans,” or “MMPs”) under three-way contracts between the state, the Centers for Medicare & Medicaid Services (CMS), and the MMP. As of May 2019, approximately 372,600 duals were enrolled in an MMP. Enrollment was flat from May of the previous year.
HMA, CMCS Launch Resource for Medicaid Innovation Program
A team of HMA consultants, led by Izanne Leonard-Haak and Matt Roan, have collaborated with organizations under a Centers for Medicaid and CHIP Services (CMCS) contract to provide support to CMCS on the Medicaid Innovation Accelerator Program.
New Opportunities and Requirements for Integrated Managed Care Models for Medicare-Medicaid Dually Eligible Individuals Served by Health Plans
This week, our In Focus section provides a high-level overview and an analysis for how health plans should consider two related and significant policy statements from the Centers for Medicare & Medicaid Services (CMS) about opportunities to further integrate care for dually eligible individuals. Specifically, the CMS April 24, 2019, State Medicaid Director letter (SMDL) outlines new opportunities for states, largely working with health plans, to test models of integrated care, including opportunities to continue current financial alignment initiatives (FAIs).[i] CMS also issued final rules related to Medicare Advantage Dual Eligible Special Needs Plan (D-SNP) definitions and requirements for Medicare-Medicaid integration activities and unified grievances and appeals for calendar year 2021.[ii] Together, these guidance documents should present greater opportunities for health plans to partner with CMS and states to integrate care for dual eligible beneficiaries.[iii]
HMA Analysis of Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-Pocket Expenses Final Rule
On May 16, 2019, the Centers for Medicare & Medicaid Services (CMS) issued its final rule, Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-Pocket Expenses (Final Rule). The proposed rule, which was issued in November 2018, included a number of provisions intended to improve drug price transparency and expand use of utilization management tools to further Medicare Advantage and Part D cost-cutting efforts. However, in response to significant pushback from beneficiary advocates, physician groups, insurers, and pharmaceutical stakeholders, CMS elected not to implement key provisions. These include proposals to allow Part D plans to exclude protected class drugs from formularies as a result of price increases or if the drug is a new formulation of an existing single-source drug as well as proposed reforms to pharmacy price concessions that would require discounts be passed on to beneficiaries at the point of sale. Commenters in opposition to the pharmacy price concession proposal contend that these reforms would result in higher Part D premiums. While CMS has postponed addressing this provision in this Final Rule, the recently issued Department of Health and Human Services (HHS) Office of Inspector General (OIG) proposed rule, if finalized, may include fundamental changes to these pricing arrangements and other federal safe harbors to the anti-kickback statute.
HMA Summary of Fiscal Year 2020 Medicare Proposed Rules for Medicare Part A Providers
This week, our In Focus section reviews the Centers for Medicare & Medicaid Services (CMS)-issued Fiscal Year (FY) 2020 Medicare Part A proposed rules. Between April 17 and April 23, 2019, the CMS issued the proposed rules for general acute care hospitals paid under the Inpatient Prospective Payment System (IPPS), the skilled nursing facility (SNF) prospective payment system (PPS), the Inpatient Rehabilitation Facility (IRF) PPS, the Long-Term Care Hospital (LTCH) PPS, the Hospice PPS, and the Inpatient Psychiatric Facility (IPF) PPS. These proposed regulations include annual payment rate changes and other proposed policy changes. Comment deadlines for these rules vary.
HMA Conference to Feature Insights from 40+ Speakers, Including Health Plan CEOs, State Medicaid Directors, Providers
Pre-Conference Workshop: September 8, 2019
Conference: September 9-10, 2019
Location: Chicago Marriott Downtown Magnificent Mile
Health Management Associates is proud to announce its fourth annual conference on trends in publicly sponsored health care: The Next Wave of Medicaid Growth and Opportunity: How Payers, Providers, and States Are Positioning Themselves for Success.
The HMA conference has emerged as a premier informational and networking event, attracting more than 450 executives and policy experts. Speakers this year include state Medicaid directors and leaders from Medicaid managed care, hospitals, clinics, community-based organizations, and other providers.
CMS Announces Primary Cares Initiative
On April 22, 2019, the Centers for Medicare & Medicaid Services (CMS) Innovation Center announced the Primary Cares Initiative (PCI), which will present eligible providers and other entities with the opportunity to engage in value-based payment and direct contracting payment models for primary care beginning in January 2020. CMS designed PCI to reduce expenditures and preserve or enhance quality of care for beneficiaries in Medicare fee-for-service (FFS). PCI is comprised of two tracks, Primary Care First (PCF) and Direct Contracting (DC). The PCF track, which builds on the Comprehensive Primary Care Plus (CPC+) initiative, is intended for individual primary care practices and seeks to reward providers for reductions in hospital utilization and total cost of care through performance-based payment adjustments. Also, under the PCF track, practices that specialize in serving high-need and/or seriously ill populations will receive adjusted payments to account for the populations served. Providers that participate in these models will qualify as participating in an Advanced Alternative Payment Model and be eligible to receive full bonus payments under CMS’s Medicare Incentive Payment System (MIPS).