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Medicare’s 2024 proposed payment rules: opportunities and policy changes for physicians and hospitals

This week’s In Focus section is the first in a summer series of analysis and insights from Health Management Associates (HMA) on recent Medicare payment and policy developments. Our series kicks off with a big-picture take on the slew of regulations the Centers for Medicare & Medicaid Services (CMS) has released over the past two weeks. In future posts, we will dig deeper into several of the planned changes to highlight their potential impact on financial and operational decisions across the healthcare industry.

In July, CMS published three significant proposed Medicare rules for calendar year (CY) 2024: the Physician Fee Schedule (PFS) Proposed Rule, which includes proposed changes to the Medicare Shared Savings Program (MSSP); a proposed remedy to 340B-acquired drug payment policy for CY 2018−2022; and the Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System (OPPS-ASC) Proposed Rule. Comments on these proposals are due to CMS in early September.

HMA’s experts note several trends across these three Medicare payment regulations:

Health equity remains a significant focus of CMS and the Biden Administration.
The agency is expanding its coverage of behavioral health services under Medicare and enhancing payment and access for these services.
The long-term focus of CMS continues to be the transition toward value-based care.
Medicare is incrementally moving toward supporting care that is delivered where and how Medicare beneficiaries prefer, for example moving away from reimbursing largely for face-to-face services and supporting reimbursement for telehealth services in more situations.
CMS is creating pathways for reimbursement for a broader range of clinicians and caregivers who are addressing Medicare beneficiaries’ care needs.
CMS continues its efforts to improve hospital price transparency with policies aimed at encouraging providers to publicly report data.

Medicare policy experts at HMA and is affiliate, The Moran Company, summarize details on these regulations below. These colleagues work collaboratively to monitor legislative and regulatory developments in the physician, 340B, and outpatient and ASC policy arenas and to assess the impact of changes in these reimbursement systems. HMA’s Medicare experts interpret and model policy proposals and use these analyses to assist clients in developing their strategic plans and comment on proposed regulations. Moran annually replicates the methodologies CMS uses to set payments and recommends alternative payment policies to help support its clients’ comments on various rules and to help clients understand the impact of specific policies. In addition, HMA’s other partner companies, including Wakely and Leavitt Partners, are monitoring these issues from their unique perspectives.

For more information or questions about the policies described below, please contact Amy Bassano ([email protected]), Zach Gaumer ([email protected]), Andrea Maresca ([email protected]), Kevin Kirby ([email protected]), or Rachel Kramer ([email protected]).

Medicare Physician Fee Schedule Proposed Rule (CY 2024)

The Medicare PFS establishes payments and policies for physicians and other healthcare professionals. By statute, PFS payment rates will decline by 1.25 percent from CY 2023 to 2024. However, when coupled with budget neutrality adjustments for other policy changes, the proposed PFS conversion factor will decline by 3.34 percent. The impact of this reduction will vary by physician specialty.

Behavioral Health Services: CMS implements provisions in the Consolidated Appropriations Act (CAA), 2023, which would allow Medicare coverage and payment for the services of marriage and family therapists (MFTs) and mental health counselors (MHCs). CMS proposes to classify addiction counselors who meet certain requirements as MHCs. The rule outlines how these practitioners can enroll in Medicare and bill for services starting January 1, 2024. CMS is establishing new codes and payment for psychotherapy for crisis services and proposed refinements to Health and Behavior Assessment/Intervention codes to allow additional practitioners to bill for these services and to increase the valuations of timed behavioral health services. CMS seeks comment on ways to expand access to behavioral health services. CMS specifically is looking for information on digital therapies, remote physiologic monitoring, and remote therapeutic monitoring services.

Evaluation and Management (E/M) Office Visit Services: CMS proposed to implement separate payment for an add-on billing code to account for the additional resources associated with primary care or ongoing care related to a patient’s single serious or complex chronic condition. This complexity-based add-on code may be reported with all office and outpatient (O/O) and evaluation and management (E/M) visit level codes, and CMS estimates it will be reported for 38 percent of all O/O E/M visits initially. This estimate contributes to a significant portion of the relative value unit (RVU) budget-neutrality adjustment applied to the conversion factor. CMS also requests comments on evaluating E/M services more regularly and comprehensively including ways to improve data collection and methodologies to establish more timely improvements and accurate payments for E/M and other services.

Telehealth: CMS proposes several additions to the list of covered telehealth services and implements the various telehealth provisions included in CAA 2023, such as allowing the patient’s home to serve as an originating site. This provision would expand the scope of permitted telehealth providers and allow rural health clinics and federally qualified health centers (FQHCs) to provide telehealth services until December 31, 2024. In addition, CMS proposes opportunities for teaching physicians and medical residents to continue to use telehealth services to meet the supervision requirements via telehealth.

Caregiver Training Services: CMS proposed a new payment for practitioners who train caregivers to implement a treatment plan and support patients with diseases like dementia.

Payment for Community Health Integration, Social Determinants of Health (SDOH) Risk Assessment, and Principal Illness Navigation Provided by Social Workers, Community Health Workers, Care Navigators, and Peer Support Specialists: CMS is establishing opportunities for these services to be paid separately and account for the specific resources necessary to provide these services.

Dental Services: Although Medicare generally is prohibited from paying for dental services, CMS proposed to pay for certain dental services related to the treatment of head and neck cancers and when linked to other covered services used to treat cancer.

Discarded Drugs: The proposed rule continues the implementation process for a statutory requirement that drug and biological manufacturers refund amounts paid for discarded single-use prescription drug vials. CMS provides the list of products for which refunds would have been due in 2021, and the number of products included is expected to increase over time.

340B and Outpatient Offset Proposed Rule

In the 340B proposed rule, CMS proposed retrospective payments to 340B hospitals for incorrect payments made in CYs 2018−2022. After extensive litigation and a Supreme Court ruling, CMS will return to paying 340B hospitals for drugs using the formula of the average sales price (ASP) +6 percent, rather than the formula of the ASP −22.5 percent. In this proposed rule, CMS proposes to correct past underpayments to 340B hospitals by making lump sum payments to affected 340B hospitals. These retrospective payments are estimated to amount to $9 billion, and we anticipate payments will be made to hospitals at the beginning of CY 2024.

In addition, CMS proposed a corresponding prospectively budget neutrality offset to the 340B spending increase that will reduce hospital outpatient payments for non-drug outpatient services by 0.5 percent each year beginning in 2025. Specifically, CMS proposes to maintain this reduction until $7.8 billion in spending has been offset, which it estimates will take 16 years. The impact of this policy on the hospital industry will be significant and will create groups of winners and losers. Winners will include 340B hospitals, despite the fact that the outpatient offset will also affect their payment rates. Losers will include non-340B hospitals, particularly if their service mix is heavily focused on outpatient surgical services. Overall, the industry will observe a reduction in outpatient spending of roughly $300 million to $600 million per year for each of the 16 years the policy is in place.

Hospital Outpatient Proposed Rule (CY 2024)

Under the OPPS proposed rule, CMS would update payments for outpatient and ASC services by 2.8 percent in CY 2024 from CY 2023. This change will increase payments for hospital outpatient services by $1.9 billion and for ASC services by $170 million. In addition, if the 340B proposal is finalized, the 0.5 percent payment offset would not reduce CY 2024 OPPS payment rates but would begin reducing outpatient payments in CY 2025.

Behavioral Health: CMS proposes to establish the Intensive Outpatient Program (IOP) for behavioral health services provided to Medicare beneficiaries. The IOP proposal addresses one of the main gaps in behavioral health coverage in Medicare and promotes access to related services. CMS will define IOP as a distinct outpatient program of psychiatric services provided to individuals with acute mental illness or substance use disorder. Services could be provided at hospital outpatient departments, community mental health centers, FQHCs, and RHCs. Further, the agency proposed to establish two IOP service codes for each provider type—one for days with three services per day and another with four or more services per day.

Price Transparency: CMS proposes to increase the rigidity of its price transparency reporting program in an effort to improve hospital industry compliance with the reporting of hospital charge data to the public.

The HMA Medicare team and reimbursement experts will continue to analyze these proposal alongside other policy and reimbursement changes that affect Medicare providers. We have the depth and breadth of expertise to assist with tailored analysis, to model policy impacts, and to support clients that intend to draft comment letters on this proposed rule.

CMS releases report on nonemergency medical transportation in Medicaid

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This week, our In Focus section reviews the Centers for Medicare & Medicaid Services (CMS) report to Congress on Non-emergency Medical Transportation (NEMT) in Medicaid, released June 20, 2023. CMS found that approximately 3 million to 4 million Medicaid beneficiaries used NEMT services annually between 2018 and 2021 and made recommendations related to Medicaid coverage of NEMT for medically necessary services.

Background

NEMT includes transportation services not limited to public transport, taxis, personal vehicle transport, non-emergency ambulances, air transport, and transportation network companies. Medicaid, unlike private insurers and Medicare, covers NEMT for any covered medical service for beneficiaries with an unmet transportation need. NEMT program administration varies from state to state and can be on a fee-for-service basis, carved out with third-party transportation brokers, or carved into the Medicaid risk-based managed care contracts. Under the Consolidated Appropriations Act, 2021, which made NEMT a statutory requirement, HHS must conduct and submit an analysis of nationwide Medicaid NEMT services to Congress. An initial report was submitted in June 2022.

Table 1. NEMT Service Delivery Models by State, 2018−2021

CMS conducted the analysis using Transformed Medicaid Statistical Information System (T-MSIS) data for calendar years 2018−2021. The analysis covered the number and percentage of Medicaid beneficiaries using NEMT, the average number of NEMT ride days, the types of medical services beneficiaries accessed when using NEMT, monthly trends in use of NEMT versus telehealth services before and during the COVID-19 public health emergency (PHE), and a comparison of the volume of NEMT services used by delivery model and state.

The T-MSIS data has some limitations and may not capture all Medicaid NEMT provided to beneficiaries due to differences in billing practices across states and providers. For example, if states claim certain medical service expenditures as administrative expenditures, T-MSIS will not capture it. Further, the number of ride days undercounts the total number of NEMT rides, as beneficiaries may receive multiple NEMT rides in a day. Because of these and other limitations, the data represents a subset of the NEMT that the Medicaid program covers.

Findings

Approximately 3−4 million Medicaid beneficiaries used NEMT annually in 2018−2021, representing 4−5 percent of Medicaid beneficiaries. Alaska, Minnesota, Arizona, Maine, and Wisconsin had the highest percentage of Medicaid beneficiaries who used NEMT, with up to nearly 11 percent in Alaska in 2021.

States that used a capitated broker model to deliver NEMT saw the highest use of these services. However, on average, states that used in-house NEMT delivery model claimed a relatively high percentage of NEMT expenditures as administrative expenditures, and NEMT administrative expenditures generally are not captured in the T-MSIS data.

Figure 1. Number of NEMT Ride Days per 10,000 Beneficiaries, by Delivery Model and Beneficiary Subgroup, 2021

*Source: The Centers for Medicare & Medicaid Services*

Medicaid enrollees with the highest NEMT usage rates included individuals in Money Follows the Person, receiving Section 1915c home- and community-based services, dually eligible for Medicare and Medicaid, and aging adults and people with disabilities. In addition, Medicaid members with certain physical and mental health conditions and those with a substance use disorder had higher rates of usage compared with the average Medicaid members. Medicaid enrollees in remote areas also used NEMT at the highest rates.

During the COVID-19 PHE, rates of NEMT dropped from 3.9 million beneficiaries, or 5 percent of all Medicaid members in 2019, to 3.5 million (4 percent) in 2020 and 3.3 million (4 percent) in 2021. In 2019−2020, the total number of annual NEMT ride days dropped by 37 percent, from 81.3 million to 53.1 million, but increased by more than 4 percent (to 55.5 million) in 2021. On average, the monthly number of NEMT ride days in 2021 remained about 30 percent below pre-PHE levels, and the number of beneficiaries using NEMT remained 23 percent below pre-PHE levels. The COVID-19 PHE caused telehealth to sharply increase. Throughout the PHE, telehealth was used more frequently than NEMT to access certain services.

Recommendations

CMS found that public transit was rarely used for NEMT, even though more than one-third of beneficiaries live in large, urban areas. In the report, CMS recommends that states should find opportunities to improve operations between NEMT and public transit networks to better coordinate services for beneficiaries.

CMS also recommends that states further examine the role of NEMT in improving the use of timely preventive care. Beneficiaries used NEMT to access preventive services at the highest rate of all service types examined. The analysis found some evidence that use of NEMT increases access to preventive services and is cost-effective, implying that increasing the uptake of NEMT may confer cost savings to states and the federal government.

Finally, CMS recommends that states increase awareness of the NEMT benefit. Medicaid beneficiaries’ knowledge of the benefit is low. CMS urges states to work with health plans and providers to share information with beneficiaries about the availability of NEMT.

Link to report

The CMS managed care proposed rule: three implications for local and regional MCOs

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Previously, HMA reviewed the provisions of the Medicaid and Children’s Health Insurance Program (CHIP) managed care access, finance, and quality proposed rule published by the Centers for Medicare & Medicaid Services (CMS) on May 3, 2023. CMS is accepting comments on the proposed rule through July 3, 2023. While the proposed rule, if finalized as put forward, will have a significant impact across Medicaid stakeholders including enrollees, managed care organizations (MCOs), providers, and state Medicaid agencies, this blog post outlines three specific aspects of the proposed the rule and their implications for a subset of MCOs: regional and local MCOs.

Medical Loss Ratio (MLR) Standards

In the proposed rule, CMS outlines three areas for revisions to its existing MLR standards which require MCOs to annually submit MLR reports to states and require states, in turn, to annually provide a summary of those reports to CMS. An MLR is calculated by adding the expenditures for incurred claims to the expenditures for activities that improve health care quality and fraud prevention activities (the numerator) and dividing this by adjusted premium revenue (the denominator). The three areas where CMS proposes revisions include: (1) requirements for clinical or quality improvement standards for provider incentive arrangements, (2) prohibited administrative costs in quality improvement activity (QIA) reporting, and (3) additional requirements for expense allocation methodology reporting.

Related to provider incentive arrangements (which are considered part of incurred claims), CMS proposes to require that contracts between MCOs and providers: (1) have a defined performance period that can be tied to the applicable MLR reporting period(s), (2) include well-defined quality improvement or performance metrics that the provider must meet to receive the incentive payment, and (3) specify a dollar amount that can be clearly linked to successful completion of these metrics as well as a date of payment. Furthermore, MCOs would be required to maintain documentation to support these arrangements and cannot rely upon attestations as documentation of compliance.

Related to QIA reporting, CMS proposes to explicitly prohibit MCOs from including indirect or overhead expenses when reporting QIA costs in the MLR. CMS notes that today, for example, expenditures for facility maintenance, marketing, or utilities may be included in the MLR even though such expenses do not directly improve health care quality. From the perspective of CMS, the inclusion of such expenditures in the MLR numerator may be resulting an inflated MLRs that then provide a distorted view of MCO performance.

Related to expense allocating reporting, CMS proposes to add requirements regarding how MCOs can allocate expenses for the purpose of calculating the MLR. Specifically, MCOs would need to describe in their methodology a detailed description of the methods used to allocate expenses, including incurred claims, quality improvement expenses, federal and state taxes and licensing or regulatory fees, and other non-claims costs. The goal of requiring this additional detail is to give state Medicaid agencies the ability to assess whether MLRs are accurately represented as a result of the methodology employed by an MCO to allocate expenses across lines of business (e.g., Marketplace, Medicaid, and Medicare).

For local and regional MCOs, the changes to MLR standards proposed by CMS will require meaningful efforts to ensure compliance. Provider incentive arrangements, most expansively, may need to be renegotiated to conform to the requirements and, at a minimum, may need to be documented in a more robust fashion to ensure evidence of compliance can be furnished upon request. The impact of QIA expenditures that are no longer able to be included in the MLR numerator will need to be modeled to ensure that a resulting failure to meet any minimum MLR requirements does not occur and, if this is projected to occur, a strategy will need to be developed and executed to ensure it does not. Expense allocation methodologies will need to be documented more extensively and evaluated for reasonability to ensure that they can withstand regulatory scrutiny when additional detail is provided to state Medicaid agencies.

Medicaid and CHIP Quality Rating System (MAC QRS)

In the proposed rule, CMS outlines a MAC QRS framework that includes: (1) mandatory quality measures, (2) a quality rating methodology, and (3) a mandatory website display format. State Medicaid agencies and MCOs will be required to adopt and implement the MAC QRS framework developed by CMS or adopt and implement an alternative managed care quality rating system. CMS will update the mandatory measure set at least every other year. Measures will have public notice through a call letter (or similar guidance) on any planned modifications with measures being based on: (1) value in choosing an MCO, (2) alignment with other CMS programs, (3) the relationship to enrollee experience, access, health outcomes, quality of care, MCO administration, or health equity, (4) MCO performance, (5) data availability, and (6) scientific acceptability.

State Medicaid agencies will be required to collect from MCOs the data necessary to calculate ratings for each measure and ensure that all data collected are validated. Additionally, state Medicaid agencies must calculate each measure and issue ratings to each MCO for each measure. Finally, the mandatory state website will be required to contain the following elements: (1) clear information that is understandable and usable for navigating the website itself, (2) interactive features that allow users to tailor specific information, such as formulary, provider directory, and ratings based on their entered data, (3) standardized information so that users can compare MCOs, (4) information that promotes beneficiary understanding of and trust in the displayed ratings, such as data collection timeframes and validation confirmation, and (5) access to Medicaid and CHIP enrollment and eligibility information, either directly on the website or through external resources.

For local and regional MCOs, the MAC QRS framework proposed by CMS will require assessing their capability to produce the mandated data upon request by state Medicaid agencies. It will also then require ensuring that all mandated data is available to be provided on an annual basis. To the extent possible, at the appropriate time, assessing baseline performance on measures and proactively developing and implementing strategies to improve performance will be prudent. Assessing the impact of the greater transparency around quality performance that the proposed MAC QRS will bring in order to understand the potential impact on competitive position will also be important.

Network Adequacy Requirements

In the proposed rule, CMS outlines important network adequacy requirements meant to further timely access to care for Medicaid and CHIP managed care enrollees. Two of these are focused upon here: (1) appointment wait time standards and (2) secret shopper surveys. Other policies to enhance access are also included in the proposed rule including, for example, a requirement that state Medicaid agencies conduct an annual enrollee experience for each MCO.

For appointment wait time standards, CMS proposes that state Medicaid agencies develop and enforce wait time standards for routine appointments for four types of services: (1) outpatient mental health and substance use disorder (SUD) for adults and children, (2) primary care for adults and children, (3) obstetrics and gynecology (OB/GYN), and (4) an additional service type determined by the state Medicaid agencies in an evidence-based manner (in addition to the previous three noted). The maximum wait times must be no longer than 10 business days for routine outpatient mental health and SUD appointments and no longer than 15 business days for routine primary care and OB/GYN appointments. State Medicaid agencies could impose stricter wait time standards but not more lax ones. The wait time standard for the fourth service type selected by state Medicaid agencies will be determined at the state level.

For secret shopper surveys, state Medicaid agencies will be required to utilize an independent entity to conduct annual secret shopper surveys to validate MCO compliance with appointment wait time standards and the accuracy of provider directories to identify errors as well as providers that do not offer appointments. For an MCO to be compliant with the wait time standards, as assessed through the secret shopper surveys, it would need to demonstrate a rate of appointment availability that meets the wait time standards at least 90% of the time. State Medicaid agencies would be required to develop remedy plans when MCO compliance issues are identified which designate the party responsible for taking action, outline the appropriate steps to be taken to address the issue, and document the intended implementation timeline.

For local and regional MCOs, the wait time standards and secret shopper surveys present opportunities to prepare to ensure compliance and to collaborate with state Medicaid agencies. For preparation, undertaking secret shopper surveys ahead of implementation to determine the current performance relative to maximum wait times may be advisable. Additionally, there is an opportunity to collaborate with state Medicaid agencies regarding the selection of the fourth service type for which wait time standards will be established.

For More Information

If you have questions about how HMA can support your efforts related to the proposed rule’s implications for local and regional MCOs, please contact our experts below.

CMS releases national healthcare expenditure and enrollment projections through 2031

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This week, our In Focus section reviews the projected healthcare expenditure and enrollment data from the Centers for Medicare & Medicaid Services (CMS) Office of the Actuary, published June 14, 2023. The Office of the Actuary provides annual updates to historical and projected National Health Expenditure data on Medicare, Medicaid, CHIP, and other public insurance programs, as well as commercial healthcare insurance.

CMS projects that the average annual growth for national healthcare spending from now through 2031 will be 5.4 percent. CMS estimated that the number of insured individuals in the United States was projected to reach a high of 92.3 percent in 2022 and would decrease to 90.5 percent by 2031. CMS projects 93.6 million Medicaid and CHIP members will account for more than $1.2 trillion in annual spending in 2031 and that 76.4 million Medicare beneficiaries will account for more than $1.8 trillion in expenditures that year. A summary of other key takeaways from the actuarial report follows.

Enrollment Projections

Approximately 92 million people were enrolled in Medicaid and CHIP programs in 2021. Enrollment is projected to have reached a high of 97.6 million in 2022 and is expected to fall between 2023 and 2026 because of Medicaid redeterminations. CMS projects the largest loss in 2024, with 8 million people leaving Medicaid and CHIP that year alone. By 2026, enrollment is projected to hit a low of 89.7 million and start to rise back up in the subsequent years until reaching 93.6 million enrollees in 2031.

Table 1. Historical and Projected Medicaid/CHIP Enrollment (in Millions)

Figure 1. Historical and Projected Medicaid/CHIP Enrollment (in Millions)

Medicare enrollment is projected to continue growing steadily. CMS estimates that Medicare beneficiaries totaled 63.6 million in 2022. By 2031, Medicare enrollment is expected to climb to 76.4 million.

Expenditure Projections

Medicaid expenditures are expected to grow by 5 percent on average in 2022−2031. In 2022, the Medicaid annual growth rate was projected to be −2.1 percent. Following the public health emergency unwinding, average expenditure growth would pick up to 5.6 percent in 2025−2031.

CMS estimated that total Medicaid and CHIP annual spending in 2022 was $828.4 million; by 2031, it is projected to hit $1.2 trillion. For context, private health insurance is projected to reach nearly $2.1 trillion in 2031.

Table 2. Historical and Projected Medicaid/CHIP Expenditures (in Billions)

Figure 2. Historical and Projected Medicaid/CHIP Expenditures (in Billions)

Medicare spending is projected to grow to more than $1.8 trillion in 2031 from $944.2 million in 2022. During this time, average annual expenditure growth is projected to be 7.5 percent. In 2022, spending growth dropped to 4.8 percent compared with 8.4 percent in 2021 because fee-for-service beneficiaries were using fewer emergency department services and as a result of reinstated payment rate cuts associated with the Medicare Sequester Relief Act of 2022.

Medicaid Expenditure Projections by Category

CMS provides a historical and projected breakdown of expenditures by category for Medicaid only (CHIP is bundled with Department of Defense and other public spending). Table 3 summarizes the projected change in annual expenditures for several categories of services and other expenditures. It also shows each category’s percentage contribution to total Medicaid expenditures and the compounded annual growth rate (CAGR) in 2021−2031 for each category of spending. Hospital spending, personal care/residential/other, and physician/clinical expenditures are projected to continue to be the largest contributors to overall Medicaid expenditures, together equaling approximately 65 percent of total expenditures in 2021 and a projected 66 percent in 2031.

Table 3. Historical and Projected Medicaid-Only Expenditures by Category, 2021-2031 (in Billions)

Link to National Health Expenditure Data

To treat residents with OUD, nursing facilities must improve practices and reduce stigma

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This week, our In Focus section highlights a Health Affairs Forefront post, “To Treat Residents With OUD, Nursing Facilities Must Improve Practices and Reduce Stigma,” published June 8, 2023. Health Management Associates (HMA) consultants Dina Besirevic, Kamala Greene Genece, Debbi Witham, David F. Polakoff, and Barry J. Jacobs wrote the article.

The HMA colleagues note that two recent healthcare industry trends are converging to change the admission criteria and clinical practices that some skilled nursing facilities (SNFs) use. Driving one movement is the opioid epidemic in which increased prevalence of fentanyl and its medical complications are spurring the need for posthospital discharge SNF admissions. The other stems from the low occupancy rates in many SNFs since the pandemic. As a result, more SNFs are considering filling beds by admitting individuals with opioid use disorder (OUD) for the first time.

In many respects, this a positive development. The need for skilled nursing care, such as medication-assisted treatment (MAT), for individuals with OUD has never been greater. A March 23, 2023, US Drug Enforcement Administration public safety alert reported that recently analyzed fentanyl samples in 48 of the 50 states had been adulterated with xylazine, or “tranq,” a veterinary sedative added to prolong an opioid high. According to the Substance Abuse and Mental Health Services Administration (SAMHSA), extensive xylazine use commonly causes severe skin wounds requiring weeks of intravenous antibiotics and skilled wound care to prevent amputations. Providing well-managed post-acute care for these patients could lead to improved outcomes.

But admitting and treating individuals with OUD now poses multiple challenges for SNF staffs and administrators. Many of these healthcare workers lack training in OUD pharmacological and support care. Some have stigmatizing attitudes toward individuals with OUD. To address these concerns, SNFs across the country have developed different practice models. Examples include:

Laguna Honda in San Francisco trains its staff to understand OUD, recognize the signs of resident opioid use, and work closely with nearby OUD providers to provide all OUD treatment.
At Highbridge Woodycrest Center in the Bronx, NY, the storage and administration of MAT is managed by the SNF staff through a collaborative relationship with a community-based provider, Bronx Care Health System, which prescribes the medications and then delivers them to the facility.
At other SNFs, SNF physicians and nurse practitioners prescribe buprenorphine with consultation as needed from community-based OUD providers.

HMA’s experts in OUD and SNFs are working collaboratively to assist SNFs interested in exploring the clinical, financial, and operational opportunities and challenges with this emerging line of business. For questions or inquiries, please contact our experts below.

Link to Health Affairs post.

Takeaways from the early Medicaid unwinding actions

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This week, our In Focus checks in on the Medicaid unwinding work and key issues HMA experts are watching as more states resume their normal policies and processes for determining eligibility. A total of 19 states started disenrollments effective for April or May coverage, and 22 additional states plan to start ending coverage this month. States are scheduled to submit the next monthly report by June 8, 2023.

Background

As explained in earlier In Focus articles, (January 12, 2023; November 12, 2022; and April 6, 2022) federal COVID-19 relief laws allowed states to receive higher federal funding for Medicaid as long as the state did not terminate Medicaid coverage for anyone enrolled in Medicaid during the public health emergency (PHE). One result of the continuous coverage policy was sustained growth in Medicaid enrollment; more than 21 million additional individuals were continuously enrolled in Medicaid for up to three years between February 2020 and March 2023. In December 2022, Congress ended the Medicaid continuous coverage policy after March 31, 2023. States were allowed to begin processing redeterminations as early as February 2023 and start disenrolling ineligible individuals as early as April 2023.

Preparations for the Medicaid unwinding have been under way for well over two years. The Centers for Medicare & Medicaid Services (CMS), states, Medicaid health plans, providers, beneficiary advocates, and other interested stakeholders have been working to ensure that the policies, outreach, and assistance are in place to support this massive eligibility renewal and redetermination initiative.

What Do We Know… Or Not Know?

Most of the available forecasts project between 10-15 million enrollees will lose Medicaid coverage. The Health Management Associates (HMA) insurance mix model projects that more than 10 million of the approximately 90 million Medicaid enrollees are at risk for disenrollment. HMA’s model illustrates the variety in state approaches to managing the resumption of eligibility redeterminations as well as key insights related to the differential impact by Medicaid eligibility categories.

Based on published information, the number of individuals who were disenrolled from Medicaid in April through May is likely to approach 500,000. In these early days of the unwinding period, HMA experts are closely reviewing the reports and engaging with key stakeholders in individual states. Several issues already are garnering more attention, such as the impact on child enrollment, churn and experiences in states using the extended reconsideration period flexibility, among others. Stakeholders will want to monitor how these and other program nuances evolve over the next year.
We do not yet have robust or consistent data from the states that have resumed their normal processes for determining eligibility. States must submit disenrollment reports to CMS each month, and CMS must publish this information. The states are not, however, required to publish this information on their website. While some states have chosen to publish the data or plan to do so, there is no consistent approach to the specific data states post. For example, while most states publishing a state data dashboard are sharing the number of renewals they are processing each month, only slightly more than half also are sharing the number of renewals resulting in coverage terminations.
CMS is not expected to publish the state data before the end of June. Once this information is available, the state unwinding reports may provide a more comprehensive and consistent picture of enrollment over the next year.

In addition, the total number of “procedural terminations” currently is difficult to determine. Lack of consistent public reporting creates gaps in the data about the number of individuals disenrolled because they did not provide a timely response to the state’s request for more information (or for other procedural reasons). As Medicaid stakeholders know, the procedural disenrollment number is critical because these individuals could still be eligible for the program.

Early disenrollment numbers should be analyzed carefully and in the context of the state. As noted earlier, the full eligibility renewal and disenrollment reports are unavailable at this time. We do know, however, that the available data is best analyzed in the context of the state’s unwinding plan (e.g., how the state is sequencing its eligibility reviews). The sequencing, pace, staffing, messaging consistency, partner outreach and assistance, and other factors will result in variation in state experiences. States are actively analyzing the data as the information is released and considering course corrections that may be needed, which could affect enrollment.
Ongoing federal and state collaboration is improving preparations and allowing partners to address concerns as they arise. CMS and states have been transparent about the magnitude of the Medicaid unwinding and the fact that challenges will be inevitable throughout this process. The experiences reported by the first tranche of states to begin their unwinding period reinforce those points. They also provide important lessons for states that are or will shortly resume normal eligibility operations.

What to Watch

HMA’s experts are working with states, Medicaid health plans and their partners, providers, and advocacy organizations to identify and implement solutions to some of the known challenges. We also are looking ahead to forthcoming data, qualitative input, and other important developments that may inform federal and state policies and operations beyond the unwinding period.

Unwinding trends. Though it is too early to definitively identify trends, HMA experts are monitoring the early state data, and we are prepared to analyze the CMS reports once they are published. We anticipate the CMS published data could be more instructive regarding the impact of the unwinding on enrollment, including states or regions that could benefit from additional outreach and assistance strategies, disproportionate impacts on certain demographic groups, new flexibilities that states may want to consider, and steps that health plans, hospitals and health systems, providers, and other partners could advance.
State operational plans. As of late May, CMS officials reported they have not asked any state Medicaid agency to develop a corrective action plan related to the unwinding; however, this does not mean that federal officials do not have concerns about the experiences and data being reported out of certain states. States, their business partners, and advocates will all benefit from monitoring shifts in state plans, potential future CMS resources and direction to states such as additional reporting or modifying eligibility processes.
Coverage Program Transitions. Significant attention has been appropriately placed on the Medicaid disenrollment numbers. HMA experts also are closely watching for new data on the number of individuals who successfully transition and enroll in qualified health plans offered in the Health Insurance Marketplaces. In the short term, the Medicaid unwinding could have a notable impact on total enrollment in Marketplace plans as well as provider payer mix. This could affect longer-term policy, strategy, and operational decisions for officials at the federal and state levels, managed care organizations, providers, and other stakeholders. For example:
- Health insurers should assess the opportunity to participate in the Marketplace program. Other insurers may need to develop new strategies to remain competitive in the Marketplace.
- Providers have similar assessments to conduct related to changes in the number of uninsured people to whom they deliver care, as well as their payer mix and the Marketplace plan networks in which they participate.
- Policymakers may revisit Marketplace regulations and standards in response to enrollment growth, enrollee demographics, and acuity of enrollees in Marketplace plans.

Medicaid agencies, health plans, all types of Medicaid providers, and advocacy organizations should continue to analyze their immediate needs during the Medicaid unwinding. They should also be planning to identify and incorporate lessons from this transition period, as well as preparing for policy and operations changes in the post-unwinding environment.

HMA: What We’re Watching

On June 8, 2023, the Health Care Payment Learning & Action Network (LAN) will hold a virtual meeting focused on accountable primary care. The LAN — an initiative supported by the Centers for Medicare & Medicaid Services (CMS) Innovation Center — is a group of public and private health care leaders that provide thought leadership, strategic direction, and ongoing support to accelerate our care system’s adoption of alternative payment models (APMs). During the session, CMS Administrator Chiquita Brooks-LaSure and the Innovation Center’s Deputy Administrator and Director Liz Fowler will share their vision for accountable primary care.

Over the past several months CMS leaders have discussed their intent to accelerate the transition to value-based care and more accountable primary care. They have identified key principals and hinted at certain components of a potential new primary care model. Additionally, the Innovation Centers’ earlier strategy documents have highlighted the imperative to include payers beyond Medicare, importantly Medicaid and commercial insurers, in models to achieve person-centered accountable and equitable care.

This meeting is notable because the Innovation Center’s models can drive transformational shifts in health care delivery and payment across public and private payers at the system and practice levels. Providers, health systems, insurers, and other interested stakeholders will want to closely monitor the LAN discussion for more information about CMS’ evolving thinking and future opportunities related to a potential model for accountable primary care. HMA experts are available to work with health care organizations and stakeholders to interpret and respond to developments flowing from the LAN session.

LAN meeting registration and information is available here.

If you have any questions, contact our experts below.

What does passage of the “debt ceiling” bill mean for the healthcare workforce?

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On May 31, the House passed H.R. 3746 – the Fiscal Responsibility Act of 2023, otherwise known as the “debt ceiling” bill, which increased the federal debt limit, established new discretionary spending limits, rescinded unused funds, and expanded work requirements for federal programs. It was passed by the Senate on June 1 and will soon be signed into law. What does all this have to do with healthcare workforce? Well, part of the rescindment plan comes from $28 billion in unused pandemic funding, with a substantial portion of those funds that were allocated for healthcare workforce efforts. This includes funds set to be used for mental health and substance use disorder training, grants to improve mental health and burnout in the healthcare workforce, and additional educational and training grants for promoting future workforce. Overall, part of $28 billion specifically includes removal of $1.7 billion from the Centers for Disease Control and Prevention (CDC) and $13.4 billion from the Department of Health and Human Services (DHHS), including $10.4 billion from public health and social services emergency funds.

Washington DC Capitol dome detail with waving american flag

So, what does this mean for the healthcare workforce? It means healthcare organizations will need to continue to optimize their current and future workforce plans, without additional funding that could provide some relief.

At Health Management Associates (HMA), our healthcare workforce experts have not only partnered with health system leaders to identify real-world solutions, we have directly experienced the same challenges, because our team includes physicians, nurses, advanced practice providers, and former health system operations and financial executives who share the same lived experiences.

HMA offers a number of workforce solutions to healthcare communities across the spectrum. We cannot fill all your staffing gaps tomorrow; however, we can give you an innovative, model-of-care plan designed to lower costs, increase revenue, and position organizations for long-term financial success and operational sustainability.

With HMA’s Delivery System Optimization Team, organizations will benefit from:

An experienced team of health system leaders, bedside clinicians, and workforce subject matter experts with real-world experience and modern health care delivery solutions

A thorough quantitative and qualitative assessment including:
- Workforce capacity, needs, and gap analysis.
- Leadership and governance structure evaluation.
- Key regulatory and policy gap analysis.
- Compensation and benefits review.
- Clinical and/or non-clinical workflow evaluation.
- Provider billing practices and quality metric capture.
- Provider and staff utilization analysis.

What organizations receive is:

A customized, comprehensive phased implementation plan that:
- Improves cash flow and maximizes revenue.
- Reduces turnover, increases retention, and improves health system culture.
- Optimizes the ‘Model of Care’ delivery while still maintaining quality and safety.
- Provides solutions for long-term financial success and operational sustainability.
- Offers on-going executive and leader coaching services to help provide support through the change management process.

Today’s healthcare workforce challenges are unwavering, especially given the recent passage of the “debt ceiling” bill. From significant workforce shortages, to rising costs and competition, to decreasing employee engagement and burnout, today’s health systems face tremendous challenges. But by understanding workforce and health system needs and identifying gaps and inefficiencies, employers can fully utilize the employees they have to their highest potential and deliver care more effectively and efficiently. Here at HMA, our delivery system optimization team can help health care communities struggling with workforce challenges do just that.

Contact our healthcare delivery system experts, who can partner with your organization to design a custom workforce solution for you.

HMA annual conference on innovations in publicly sponsored healthcare

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Innovations in Publicly Sponsored Healthcare: How Medicaid, Medicare, and Marketplaces Are Driving Value, Equity, and Growth

Pre-Conference Workshop: October 29, 2023
Conference: October 30−31, 2023
Location: Fairmont Chicago, Millennium Park

Health Management Associates has announced the preliminary lineup of speakers for its sixth annual conference, Innovations in Publicly Sponsored Healthcare: How Medicaid, Medicare, and Marketplaces Are Driving Value, Equity, and Growth.

Hundreds of executives from health plans, providers, state and federal government, investment firms, and community-based organizations will convene to enjoy top-notch content, make new connections, and garner fresh ideas and best practices.

A pre-conference workshop, Behavioral Health at the Intersection of General Health and Human Services, will take place Sunday, October 29.

Confirmed speakers to date include (in alphabetical order):

Jacey Cooper, State Medicaid Director, Chief Deputy Director, California Department of Health Care Services
Kelly Cunningham, Administrator, Division of Medical Programs, Illinois Department of Healthcare and Family Services
Karen Dale, Chief Diversity, Equity, and Inclusion Officer, AmeriHealth Caritas
Mitchell Evans, Market Vice-President, Policy & Strategy, Medicaid & Dual Eligibles, Humana
Peter Lee, Health Care Policy Catalyst and former Executive Director, Covered California
John Lovelace, President, Government Programs, Individual Advantage, UPMC Health Plan
Julie Morita, MD, Executive Vice President, Robert Wood Johnson Foundation
Anne Rote, President, Medicaid, Health Care Service Corp.
Drew Snyder, Executive Director, Mississippi Division of Medicaid
Tim Spilker, CEO, UnitedHealthcare Community & State
Stacie Weeks, Administrator/Medicaid Director, Division of Health Care Financing and Policy, Nevada Department of Health and Human Services
Lisa Wright, President and CEO, Community Health Choice

Publicly sponsored programs like Medicare, Medicaid, and the Marketplaces are leading the charge in driving value, equity, and growth in the U.S. healthcare system. This year’s event will highlight the innovations, initiatives, emerging models, and growth strategies designed to drive improved patient outcomes, increased affordability, and expanded access.

Early bird registration ends July 31. Group rates, government discounts, and sponsorships are available.

New experts join HMA in April 2023

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HMA is pleased to welcome new experts to our family of companies in April 2023. This diverse team brings significant expertise in Medicare, Medicaid, regulatory strategies, and managed care, strengthening HMA’s capabilities in healthcare consulting across areas like actuarial support, regulatory compliance, and strategic leadership in Medicare Advantage and Medicaid programs.

Jed Abell

Consulting Actuary I

Surah Alsawaf

Senior Consultant

Elrycc Berkman

Consulting Actuary II

Monica Bonds

Associate Principal

Yucheng Feng

Senior Consulting Actuary I

Melanie Hobbs

Associate Principal

Ryan McEntee

Senior Consultant I

Child and family wellbeing: May is National Foster Care Month

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This is part of an ongoing series highlighting efforts in Human Services and Family Wellbeing.

During the month of May, National Foster Care Month provides an opportunity to raise awareness on issues related to foster care and to celebrate those who are dedicated to serving our children, youth, and families. Yet it is important to note that unfortunately issues surrounding children and youth experiencing foster care are not limited to one month a year. As noted in our recent child well-being blog, Child welfare services face challenges every day to prevent, treat, and reduce risk of maltreatment, neglect, trauma, housing instability, and violence in communities. All these issues contribute to the significant number of children and youth who enter or remain in the foster care system. These issues are year-round and decades in the making. They need to be seen as a priority for public health and community wellbeing and not just the jurisdiction and responsibility of child welfare agencies.

To positively impact the number of children and youth experiencing foster care, there are some strategies that can be implemented now to promote change:

We must meaningfully elevate the voices of those with lived experience to help us design systems that meet their needs. For foster care, working to hear and understand the voices of youth based on how they have experienced foster care will help create opportunities to improve the system from those most impacted. Further, the meaningful elevation of these voices helps to ensure their input is not contributing towards tokenism and re-traumatization.
Multi-system involvement is important. We can work together to enhance access, increase prevention-oriented services, improve community health, and well-being, and achieve better outcomes using an equity lens, but proposed system reforms cannot be successful without shared ownership within the community and across government agencies. This requires building a responsive and integrated system of care approach to allow communities to seek solutions with the necessary support of the highest leadership within their organizations.
Continue to find ways to assure that mandated reporters and staff who work within child welfare understand that poverty is not neglect, and poverty alone should not be a reason children and youth are removed from their home(s).
System redesign is needed. From front end reporting and assessment, to working with court systems, to building up networks of caring service providers, each component of the current child welfare system and human services partners can strive to find areas needing improvement and collectively change the experiences for children and youth engaged in the child welfare system.
Focus on mental health. This year’s theme from the Children’s Bureau for national foster care month is “Strengthening Minds, Uplifting Families” and is dedicated to supporting children and youth mental and behavioral health as the largest unmet need related to foster care. According to the Children’s Bureau, Up to 80 percent of children experiencing foster care have significant mental health issues, compared with approximately 18 to 22 percent of the general population.[1]

HMA can help public sector and community partners align themselves to improve and develop new delivery systems that will work to address inequalities and disparities as communities strive to meet the needs of children, youth and families impacted by issues like mental health and substance use disorder, domestic violence, child abuse and neglect, food insecurity, housing instability, incarceration and other traumas that impact them greatly.

HMA can help support foster care prevention or reunification program efforts in the following ways:

Creating additional human service system integration of prevention services to help support families and youth experiencing child welfare interventions or foster care.
Increasing Medicaid providers who offer more Evidenced Based and Informed Practices (EBP) among Community Based Organizations (CBO), Providers, and Local Government.
Supporting Managed Care Organizations to develop programs specifically designed to support the wellbeing of children and youth in the foster care system and their families.
Connecting the Family First Prevention Services Act (FFPSA) & Medicaid funding together to ensure that funding supports the need and enhance service implementation.
Working to implement School Based Mental Health programs in communities. We can help convene stakeholders, create process flows, and support the development of sustainable funding for such programs.
Increasing the meaningful use of youth voice for true collaboration in system redesign.
Enhancing judicial engagement with the child welfare system in a way that supports meaningful youth and family voice and representation in court while maintaining the child welfare system’s responsibilities around assuring child safety. Making the court process less traumatic for children and youth and more part of a solution for them will support better outcomes.
Recognizing longstanding racial inequities in foster care experiences that can and should be addressed holistically in communities and supporting efforts to understand the root causes for the disparities in foster care placement.

Read other parts of this blog series:

If you have questions on how HMA can support your efforts in Child and Family Wellbeing, please contact our experts below.

[1] Data: National Foster Care Month Outreach Toolkit | Child Welfare Information Gateway

The continuing crisis in the public health workforce

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The Current Public Health Environment

The public health workforce is in the midst of a crisis, dealing with staff shortages, accelerated retirements and unfilled positions.

The current climate was exacerbated by Covid-19, but many challenges began long before 2020’s pandemic. The public health system underwent a significant contraction following the Great Recession in 2008-2009, losing more than 40,000 positions in state and local governments across the country. While some of those positions were regained with Covid-19 funds during the pandemic, recruitment, diversity and retention remain as challenges, especially for hard to fill positions in nursing and epidemiology. Public health staff report high rates of burnout due to the Covid-19 response and the political climate that resulted, including suffering symptoms of post-traumatic stress disorder. It is likely that there will be staff shortages for the foreseeable future, increased retirements, and departures to other parts of the healthcare industry competing for skills with higher compensation.

New Funding Streams Available

State and local health departments have been receiving significant amounts of one-time money, including the Centers for Disease Control and Prevention (CDC) recent allocation of $3.5 billion specifically for governmental public health efforts.

Health Resources and Services Administration (HRSA) has created a new workforce research center for public health. The AmeriCorps program has developed a specific public health component. These new initiatives were designed to build and support the workforce in governmental public health. As state and local health departments receive or apply for these various sources of workforce development funding, HMA can provide existing technical assistance and training to minimize inefficiencies and duplication of efforts that might be created by a fragmented approach across state and local units of government developing independent approaches to the utilization of WFD funds.

HMA Workforce Expertise

The public health group at Health Management Associates (HMA) is made up of more than 100 colleagues with expertise in public or population health improvement, experienced working with national, state or local organizations seeking to improve public health outcomes. If your organization is looking to improve your public health workforce efforts, it is important to utilize expertise and consolidate efforts across the country so each unit of government is not “reinventing the wheel.” HMA can help multiple organizations in developing plans and coordinating processes for recruiting, training and development of the public health workforce.

HMA understands the skills that are needed to achieve high-performing public health and accountable care. Our expertise developing workforce within safety net delivery systems and accountable care organizations involve transferrable skills for the current challenges in building and developing the public health workforce. We have expertise in recruiting and are creating new training and retraining methods to meet the needs of public health teams, accountable care organizations, graduate medical education, nursing education, learning collaboratives, online training and team simulation training. We understand the care coordination, care management and IT support systems needed to backstop the workforce and meet quality and equity goals.

Illinois requests Section 1115 waiver extension to address HRSNs and eliminate inequities

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This week our In Focus section reviews the Illinois Healthcare Transformation 1115 Waiver Extension request, posted for review on May 12, 2023.

In pursuing this waiver extension, Illinois joins a growing list of states taking advantage of new Centers for Medicare & Medicaid Services (CMS) policy flexibilities to address health-related social needs (HRSNs) through Medicaid and test community-driven initiatives that are focused on improving health equity, improving access to care, and promoting whole-person care.

The Illinois waiver incorporates two of the most significant new opportunities in the CMS demonstration waiver flexibilities by proposing to incorporate housing supports for people who are experiencing or at risk of homelessness. The waiver also would extend community reintegration services for justice-involved adults and youths for up to 90 days before their release from incarceration. For a full list of proposed benefits and demonstrations, see Table 1.

Table 1. Summary of Illinois Medicaid 1115 Waiver Extension

Source: Illinois Department of Health and Family Services. Illinois Healthcare Transformation Section 1115 Demonstration Extension Overview.

The Illinois waiver represents an unprecedented opportunity to demonstrate the long-term, positive impact of providing HRSN services to achieve health equity and create a sustainable, community-driven system for delivering those services. The demonstration proposes to offer a range of HRSN services that are focused on the unmet needs of people who are homeless and housing insecure, are justice-involved, have behavioral health conditions, are pregnant, are unemployed, are food insecure, and/or have been exposed to violence or are at risk of violence with the goal of eliminating health disparities.

The waiver projects a five-year total of $4.4 billion in HRSN services expenditures and another $800 million in HRSN-related infrastructure, indicating Illinois’ long-term commitment to healthcare transformation and to building an equitable, accessible, and high-quality delivery system.

For additional information, please email [email protected].

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HMA: What We’re Watching

Source: Illinois Department of Health and Family Services. Illinois Healthcare Transformation Section 1115 Demonstration Extension Overview.