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AMERICAN ASSOCIATION OF HEALTHCARE ADMINISTRATIVE MANAGEMENT CENTRAL OHIO PATIENT ACCOUNT MANAGERS Annual Fall Conference OHA UPDATE Charles Cataline Senior Director, Health Policy Ohio Hospital Association charlesc@ohanet.org. Agenda. Ohio Hospital Franchise Tax Update
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AMERICAN ASSOCIATION OF HEALTHCARE ADMINISTRATIVE MANAGEMENT CENTRAL OHIO PATIENT ACCOUNT MANAGERS Annual Fall Conference OHA UPDATE Charles Cataline Senior Director, Health Policy Ohio Hospital Association charlesc@ohanet.org AAHAM / COPAM Annual Fall Conference
Agenda • Ohio Hospital Franchise Tax Update • CMS Medicaid DSH Audit & Reporting • Medicare FFY 2011 IHPPS & OPPS • Medicare RAC & MAC Updates • BWC IHPPS & OPPS • Etc., etc… AAHAM / COPAM Annual Fall Conference
SFY 2010-11 BudgetHospital Franchise Tax Program – As Enacted Tax on Hospitals: $728 M Federal Matching Funds: $1.76 B Total State Revenue: $2.49 B Return to Hospitals: 5% Medicaid Rate Update: $307.7 M Supplemental Payments (UPL): $267.2 M Total Return to Hospitals: $574.9 M Hospitals Out $153 Million State Retains Over $1.9 Billion in Medicaid Revenue 3 AAHAM / COPAM Annual Fall Conference
Ohio Hospital Franchise Tax: OHA Advocacy Initiatives Summer 2010 • Fairness & equity • Return $150 million to hospitals by: • Reducing tax rate from 1.61% to 1.5% • Removing uncompensated care from tax base • Removing Medicare costs from the tax base • Administration includes hospital proposal in initial 2012-13 budget submission • Legislature passes budget consistent with hospital proposal and OHA Board recommendations (including $150 million and equity if not successful short-term) AAHAM / COPAM Annual Fall Conference
Latest Response from Office of the Governor • Returns $150 Million to Hospitals in Aggregate for 2011 Program • Reduces Assessment • Adds Tiered Assessment • Removes Medicare Costs From Base AAHAM / COPAM Annual Fall Conference
Ohio’s 2012-2013 Budget Challenges • Anticipated $8.2 to $9.1 Billion General Revenue Fund Deficit • Ongoing Uncertainty About Enhanced Federal Medicaid Matching Payments (eFMAP) • Recent, Rapid Growth in Medicaid Spending • One-time Funding Sources are Exhausted AAHAM / COPAM Annual Fall Conference
Medicaid Strategies: Short-Term BalanceOther State Responses 2010 2011 Number of States AAHAM / COPAM Annual Fall Conference Health Management Associates
HUT 2 Task Force Recommendations to OHA Board Any future assessment program must: • Be fair & equitable • Get hospital dollar back in aggregate • Have hospital community involved in design and oversight of program • Incorporate “safeguard” mechanisms to protect hospitals, e.g. a sunset • Ensure hospitals avoid harmful Medicaid cuts • Ensure managed care plans’ cooperation • Be minimized by using other revenue sources • Ensure HCAP is preserved for hospitals AAHAM / COPAM Annual Fall Conference
CMS Medicaid DSH Audit & Reporting • Standardized Policies, Definitions & Formats • Includes Definitions & Guidelines on Allowance of Uncompensated Care Cost • Based in MMA, Final Rule in Dec. 19, 2008, FR • Retro to SFY2006, 1st Reports due Fall 2010 • States’ FFP at Risk • Independent Audits of State DSH Programs Required • Based on Cost Reports & Audited Statements / Records • Could Involve Hospital-Specific Audits; Double-Check Accuracy of HCAP Policies, Logs and Cost Report Data • Ohio RFP for Independent Auditor Out Soon • Federal Law in the Works to Block Parts of Process AAHAM / COPAM Annual Fall Conference
Medicare FFY 2011 IHPPS Final Rule • Aug. 16 FR, Includes PPACA Provisions • Negative Update to Standardized Amount Is This the First Year of Many Like This to Come? • 2.6% MB minus 2.9% for “Coding Creep” & .25% for PPACA • Outlier Threshold Decreased to $23,075 • No Significant Changes to Wage Index • This Fight is not Over! • Significant Increase in Quality Reporting Elements • No New Hospital-Acquired Conditions • “Clarification” to CAH Tax Policy Will Have Big Repercussions • DRG Window Re-Re-Clarified AAHAM / COPAM Annual Fall Conference
Medicare IHPPS 2011 Ohio Estimated Payments AAHAM / COPAM Annual Fall Conference
Medicare CY 2011 OPPS • 2.4% MB Update with .25% PPACA Cut; APCs Frozen • Additional Quality Reporting Measures (30 by 2014) with Mandated 2.0% cut to Non-reporters & Data-Validation to 800 Randomly Selected Hospitals • Dual(ing?) Supervision Requirements for “Nonsurgical Extended-Duration Therapeutic Services” • Lower Fixed-Dollar Outlier Threshold • Fewer Inpatient-Only Procedures • Many Preventative Services Have Reduced or Waived Co-payments AAHAM / COPAM Annual Fall Conference
Medicare Administrative Contractor • J-15 (OH & KY) MAC Award to CIGNA Immediately Protested by Highmark & NGS • No Decision due Until Nov. 3 at the Earliest • If CIGNA or Highmark (or Someone Else) Wins, Expect Six-month Transition • NGS States it Will be Processing Bills Through 2011 Regardless • “800 Lb Gorilla” is CMS Plan to Re-bid and Expand MAC Jurisdictions in 2015 AAHAM / COPAM Annual Fall Conference
Medicare Recovery Audit Contractor OHA RAC Summit Scheduled November 3 CGI Still Slowly Rolling Out; Complex Into 3rd & 4th Cycle and Medical Necessity Reviews to Start Soon • Expect Increased Volume as CGI Gains Experience • Get a Tracking System; Report Results to AHA RACTrac • PPACA Expands RAC to Medicaid (What about MIP?!) Several Areas of Concern Being Reported to OHA • Still Some Problems with Missing Demand Letters • Timing of Requests, Reviews, Responses, Discussion, Appeal, Recovery and Interest • Medicare Remittance Advice AR v. Actual Payment • Physician Signatures on Orders • Multiple Reviews on the Same Account • What About Secondary Payers and Patients?! AAHAM / COPAM Annual Fall Conference
Bureau of Workers’ Compensation • Outpatient Medicare-based PPS Effective 1/1/11; Testing Underway • Medicare v. BWC PPS Chart Available at http://www.ohanet.org/Issue/BWC • (See Announcement Section) • BWC Won’t Adopt Most Medicare/PPACA Programs and Cuts • BWC Audit RFP Out AAHAM / COPAM Annual Fall Conference
Other Updates • Watch for PPACA-Based Requirements on for Financial Assistance, Collection & Charge Limits • Medicare Provider Enrollment and CMS 855 Enforcement • Medicare Zero-Bill Requirement Expansion • Medicare Billing Timeliness Edits • Medicaid Information Technology System • Medicaid National Drug Coding • 2010 Federal Poverty Limit Guidelines Frozen • Watch for Medicare ESRD PPS In 2011 AAHAM / COPAM Annual Fall Conference