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23-hospital system rolls out student loan repayment program to attract nurses
Mercy Health, a 23-hospital system based in Cincinnati, has launched a student loan repayment program to attract and retain nurses in hard-to-fill roles, according to WVXU.
Due to tough competition for nurses and an increase in voluntary turnover, Mercy Health typically has between 1,500 and 2,000 openings for nursing positions. “We’ve seen voluntary turnover of almost 18 percent,” Allan Calonge, Mercy Health’s human resources vice president, told WVXU. “That’s quite a bit higher than it has been historically.”
Officials hope the new student loan repayment program will help address the problem. Mercy will make monthly contributions toward outstanding student loan debt for nurses who qualify. The system will contribute up to $20,000 to each nurse’s loans, according to WLWT.
“Talented nurses are vital to ensuring the health and well-being of our patients,” Mr. Calonge told WLWT. “Our new student loan repayment program is a win-win for us and our nurses.”
Trinity Health forms new 5-hospital system
Livonia, Mich.-based Trinity Health, which includes 93 hospitals in 22 states, has formed a new regional health system called Trinity Health Mid-Atlantic.
The new system will include the following hospitals: St. Mary Medical Center in Langhorne, Pa.; St. Francis Healthcare in Wilmington, Del.; Mercy Philadelphia Hospital; Mercy Fitzgerald Hospital in Darby, Pa.; and Nazareth Hospital in Philadelphia. Clinics, medical offices and other facilities associated with the hospitals will also be part of Trinity Health Mid-Atlantic.
Trinity said the formation of the new regional health system will streamline operational efficiencies, improve clinical collaboration by physicians, and lead to a more comprehensive outpatient strategy.
Supreme Court to hear DSH payments case
https://www.healthcaredive.com/news/supreme-court-to-hear-dsh-payments-case/533427/
Dive Brief:
- The U.S. Supreme Court agreed Thursday to review an appellate court ruling that HHS improperly changed the reimbursement formula for Medicare disproportionate share hospital payments.
- The crux of the case is whether HHS violated federal law by making the change in the DSH reimbursement calculation without public notice and comment.
- At stake for HHS is up to $4 billion in DSH reimbursements made between FY 2005 and 2013.
Dive Insight:
Policy changes since 2010 have cut payments to hospitals by billions of dollars, a report earlier this year from consulting firm Dobson DaVanzo & Associates forecast, with a prediction the cuts would reach $218.2 billion by 2028.
The cuts include $25.9 billion for Medicaid Disproportionate Share Hospital (DSH) payments, a key source of financing for hospitals that serve low-income populations.
HHS petitioned the high court to hear the case after the D.C. Circuit Court of Appeals ruled in favor of Minneapolis-based Allina Health Services and a group of hospitals. The decision, written by embattled Supreme Court nominee Brett Kavanaugh, overturned a lower court ruling that sided with HHS.
In his 2017 opinion, Kavanaugh concluded that HHS violated the Medicare Act when it revised its reimbursement adjustment formula with going through the usual rulemaking process. In particular, he rejected the government’s argument that the notice-and-comment requirement for regulations setting or modifying a “substantive legal standard” does not apply to “interpretive rules.”
Kavanaugh also held that HHS erred in including Medicare Part C enrollees with Part A enrollees in its new DSH payment calculations.
“That difference in interpretation makes a huge difference in the real world,” Kavanaugh wrote. “Part C enrollees tend to be wealthier than Part A enrollees. Including Part C days in Medicare fractions therefore tends to lead to lower reimbursement rates. Ultimately, millions of dollars are at stake for the Government and the hospitals.”
In its petition, HHS maintains that the appellate court’s decision would “significantly impair” its ability to administer annual Medicare reimbursements through the third-party contractors it employs to pay hospitals.
“The court of appeals’ decision threatens to undermine HHS’s ability to administer the Medicare Program in a workable manner,” the petition states. Given the time and cost involved in formal rulemaking, “converting the agency’s non-binding manuals and other interpretive materials into regulations requiring notice and comment would jeopardize the flexibility needed in light of Medicare’s complex and frequently changing statutory context and administrative developments.”
Three-fourths of Medicare Advantage denials overturned on appeal, OIG finds
Dive Brief:
- An investigation by the HHS Office of Inspector General found large numbers of overturned denials upon appeal from Medicare Advantage organizations, raising concerns that some needed payments and services aren’t going to providers and patients.
- Between 2014 and 2016, MAOs reversed 75% of their own denials, or about 216,000 a year, according to a report released Thursday. Additional denials were overturned by independent reviewers at higher levels of the appeals process.
- The numbers are particularly troubling because of the infrequency with which beneficiaries and providers used the appeals process — for just 1% of denials at the initial appeal level, according to the report.
Dive Insight:
The findings are important in light of the growing popularity of Medicare Advantage. Payers like the stability of the marketplace, and it’s popular with patients, too. In a recent Avalere Health study, MA beneficiaries with chronic conditions had 23% fewer inpatient stays and 33% fewer emergency department visits than people enrolled in Medicare fee-for-service plans.
That said, neither providers nor patients want to feel like they regularly have to appeal payment or service denials, especially with out-of-pocket costs on the rise.
Of the roughly 216,000 overturned denials, more than 80% were payments to providers for services the beneficiary had already received. The remainder — 18% — were for preauthorization of services not yet rendered.
But while some denials are justified, filing and processing appeals puts a burden on providers, MAOs and beneficiaries, especially those needing immediate care, OIG says.
“Further, although overturned payment denials do not affect access to services for the associated beneficiaries, the denials may impact future access,” the report states. “Providers may be discouraged from ordering services that are frequently denied — even when medically necessary —to avoid the appeals process.”
OIG also points to CMS audits that show “widespread and persistent” problems with MAO denials of payment and care. In 2015, for instance, CMS cited more than half of audited contracts for inappropriate denials and 45% for sending incomplete denial letters. The latter could hinder efforts to successfully appeal a denial, the report notes.
While the agency imposed penalties and sanctions against the affected MAOs, more action is needed, the HHS watchdog says.
Specifically, OIG recommends CMS boost oversight of MAO contracts, with an eye toward identifying those with high overturn rates, and take enforcement actions when needed. The report also calls on CMS to address chronic issues around inappropriate denials and deficient denial letters and inform beneficiaries of serious MAO violations.
CMS agreed to all three suggestions.
Hospitals prepare for uncompensated care payment change
https://www.healthcaredive.com/news/hospitals-prepare-for-uncompensated-care-payment-change/530719/
Hospitals will soon get paid for uncompensated care differently, and though supporters of the change say it will create a fairer measurement, hospitals are leery about how the move will affect their bottom lines.
Starting Oct. 1, CMS will begin a three-year phase-in for how it pays hospitals for uncompensated care. No longer will they get paid based solely on a Medicaid, dual-eligible and disabled patient headcount. Instead, hospitals will need to provide patient-level detail of the services performed, as well as total uncompensated care totals.
Rita Numerof, co-founder and president of Numerof & Associates, told Healthcare Dive that counting heads is easier for hospitals, but it’s not always accurate. That distortion can result in institutions having an “unfair advantage” in terms of payments under the Disproportionate Share Hospital program. Instead, CMS will now gauge the actual care experience.
Numerof said the move looks to target flaws in the current payment model and improve transparency and accountability. “I think that looking at the services that are provided rather than just looking at the number of people and making an assumption about what their utilization is is a lot more accurate,” she said.
Chuck Alsdurf, director of healthcare finance policy and operational initiatives at Healthcare Financial Management Association, told Healthcare Dive the change “levels the playing field” for hospitals. However, several issues and concerns remain.
Worksheet S-10 and uncompensated care
CMS recently released its hospital inpatient prospective payment system final rule for fiscal year 2019, which included a provision that will require hospitals to use Worksheet S-10 to provide patient-level compensated care information that can be used to make payments to disproportionate share hospitals.
That patient-level data includes forms in which hospitals must attest to a patient’s eligibility, such as whether the person meets the criteria through disability, dual eligibility or Medicaid.
At the same time, CMS will audit Worksheet S-10 data in the fall and says it will continue provider education efforts and look to improve Worksheet S-10 instructions.
CMS made the change to improve the accuracy in the way that DSH payments are made. “Historically, the approach has been a head-count approach, essentially taking a look and totaling up the number of Medicaid patients, dual patients and those that are disabled,” Numerof said.
The new method isn’t as easy as a headcount, but it improves accuracy and is closer to what a hospital is actually owed.
According to the agency, about half of hospitals that receive uncompensated care payments felt the need to modify their S-10 data. Alsdurf said that’s not a large enough number to assume the data is accurate or reliable. “HFMA members view this as half of the hospitals possibly submitted imprecise data based on vague instructions that impact their hospital payments. So, at the current time, we do not feel this model is clear or accurate enough to utilize for such a significant distribution of funds,” he said.
Critics charge that the change might hurt Medicaid expansion states and help hospitals in states that didn’t expand the program. Now, hospitals calculate Medicaid Patient Days and send that information along to CMS. However, supporters of the change say that non-expansion states with fewer Medicaid recipients now lose out on uncompensated care payments compared to expansion states.
In a letter to CMS about the change, Dallas-based Parkland Memorial Hospital CEO Frederick Cerise said his facility is one of the largest providers of uncompensated care in Texas, which has not expanded Medicaid.
He said Parkland supports the change and called using S-10 data a “more exact measure.” The system provided $2.37 billion in uncompensated care in FY 2015. More than three-fourths of the system’s payer mix is unfunded (nearly half) or Medicaid (almost one-third).
The American Hospital Association agrees that Worksheet S-10 has the potential to provide a more accurate measure of uncompensated care costs. However, Erika Rogan, senior associate director of policy at AHA, told Healthcare Dive in a statement the group has concerns about the “accuracy and consistency of the S-10.”
Meanwhile, America’s Essential Hospitals, which represents more than 325 member hospitals with much of the country’s uncompensated care, sent a 44-page letter to CMS in June listing a series of concerns and recommendations to resolve the issues.
“The high cost of providing complex care to struggling Americans leaves our hospitals with limited resources, driving them to find increasingly innovative strategies for high-quality care,” AEH CEO Bruce Siegel said. “But improving care coordination and quality while staying true to a mission of helping those in need can be a delicate balance. This balance is threatened by payment cuts to hospitals.”
What does the change mean for hospitals?
Uncompensated care costs in community hospitals are on the rise after years of decreases following the Affordable Care Act.
Uncompensated care is bad debt charges plus financial assistance charges. This includes caring for uninsured patients unable to pay their bills. Uncompensated care doesn’t include underpayments from Medicare or Medicaid.
The AHA earlier this year said 4,840 community hospitals provided a total of $38.3 billion in uncompensated care in 2016, up from $35.7 billion at 4,862 community hospitals in 2015. And uninsured numbers have increased in the years since 2016, so those numbers are likely higher now.
Hospitals are concerned about any change that might result in them losing out on uncompensated care funding. However, what the change will mean for hospitals depends on multiple factors, including patient mix, location and how much the facility already relies on uncompensated care payments.
The AHA had hoped CMS would put into place protections to shield hospitals hurt by the change. In its comments to CMS, the hospital group requested a stop-loss policy that would kick in if hospitals lost more than 10% of DSH payments in a year after using the S-10 worksheet. AHA estimated that nearly one-fifth of hospitals might face that problem in FY 2019. AEH also requested a stop-loss policy.
Ultimately, CMS didn’t put in that provision. Numerof said she understands the agency’s choice. Hospitals need to understand where the market is headed and build infrastructure and systems to meet those demands accordingly. She added that no other business would request stop-loss protection based on changes like the S-10.
Concerning community relations, Alsdurf doesn’t expect the change will have an impact. “Hospitals will continue to provide care to those who cannot afford it, so I don’t think this change will have any impact on the community, positive or negative,” he said.
How should hospitals prepare?
There are still questions about the S-10, but hospitals can’t wait for CMS to provide all answers and clarifications. The change is here and hospitals need to move forward with the information available to them.
This process means maximizing uncompensated care payments in the new system. One step is for hospitals to make sure their charity care and bad debt policies are updated and that those policies are followed, so they receive the level of payments they’re owed.
Alsdurf said hospitals are already collecting Medicaid days data. Now they’ll have to add another piece. He expects the change will be minor for reporting and data gathering practices.
“Until they receive feedback from CMS on their data, it’s hard to do much other than make sure they feel good about the data … I’d suggest they begin running reports from their billing systems and reconciling the data (if they haven’t already) to the S-10 worksheet for FY 2014 to present,” Alsdurf said.
He added that hospitals should also continue to review their data as CMS provides more explicit instructions about S-10 in the coming months.
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HENRY KOTULA 