IHA Federal Health Care Reform Summary Iowa’s Environment • 302,000 – Iowans do not have insurance. (approx 10 percent of population) • 171,000 – Iowans with non-group insurance and will be able to get affordable coverage through the health insurance exchange. • 187,000 residents could qualify for premium tax credits to help them purchase health coverage • 505,000 seniors would receive free preventive services Source: U.S. Department of Health and Human Services Iowa’s Environment • Small Businesses: – 76 percent of all Iowa businesses are considered small businesses. – 42 percent of those small businesses offered health coverage benefits in 2008.* – 48,600 small businesses could be helped by the small business tax credit to make insurance more affordable. * Source: Center for Financing, Access and Cost Trends, Agency for Healthcare Research and Quality, Medical Expenditure Panel Survey – Insurance Component, 2008 New Health Reform Law • Estimated to extend coverage to 32 million individuals – Covers 95 percent of those legally residing in U.S.; – Covers 92 percent of total residing in country • Estimated to cost $940 billion over 10 years (FY2010-2019) • Financed by: – Medicare and Medicaid provider payment reductions – Taxing high-premium health insurance plans – Raising the Medicare tax for high-income individuals, and – Annual fees on various industries in the health sector. Coverage Expands to 32 Million Individuals by 2019 Through: Medicaid Expansion, Exchanges, Premium Subsidies, and Insurance Reform Creation of a nationwide, high-risk insurance pool 2010 Medicaid expansion up to 133% FPL 2012 2011 Coverage for children with pre-existing conditions Dependent coverage for adults up to 26 years old Coverage for adults with pre-existing conditions 2014 2013 Individual Mandate Employer Requirements Establishment of State-Based Health Insurance Marketplaces Called “Exchanges” • Provider payments: negotiated rates • Premium subsidies for individuals and families with incomes up to 400% FPL Individual Mandate • By 2014 the law requires All U.S. citizens and legal residents to maintain minimum essential health care coverage. • There will be a tax penalty for those who fail to have coverage: $95 in 2014, $325 in 2015, $695 in 2016, and up to 2% of income by 2016. • Families will pay half of the penalty for children up to a $2,250 cap for the entire family. After 2016, the dollar amounts for the penalties will be increased by an annual cost of living adjustment. There is a hardship exemption. • Individuals who are below the tax filing threshold are exempted from this mandate. Employer Mandate Begins 2014 – “Play or Pay” • Employers with more than 50 employees that choose to not to provide health insurance will be assessed if any employees elect to receive the government tax credit. Employers will pay $2000 per full-time employee. (But are allowed to subtract 30 employees from the calculation.) • Requires employers that offer coverage to their employees to provide a free choice voucher to employees with incomes less than 400% FPL whose share of the premium exceeds 8% but is less than 9.8% of their income and who choose to enroll in a plan in the Health Insurance Exchange rather than using the company policy. Employer Mandate (cont.) • Requires employers with more than 200 employees to automatically enroll employees into health insurance plans offered by the employer. Employees may opt out of coverage. • Imposes a max 90-day waiting period limit before employees must be enrolled in the company’s coverage benefit. • Employers with 50 or fewer employees are exempt from any of these penalties. The Math • Critical Access Hospitals will see a modest increase in payments as the home health rural add-on will bring Iowa nearly $710,000 in additional funding. PPS Payment 2011 2012 Tweener Adjustment +$4.6 million +$4.6 million Geographic Variation +$12.5 million +20.7 million Coding Offset -$28 million TBD 2012 IPPS Marketbasket Update +$17 million* TBD 2012 IPPS Total: $6.1 million $25.3 + MB – coding offset • But Coding Offset issue could be addressed legislatively resulting in an increased net. • Increased Geographic Variation payments in FY 2012 should lessen the impact of potential additional coding offsets should they not be prevented by Congress and are proposed again by CMS and could result in a larger net payment gain despite the cuts. *Note: The net FY 2011 MB Update is 2.35 percent compared to 3.6 percent in 2009. The FY 2011 MB Update includes the .25 percent MB reduction as mandated in the health care reform law. Key Hospital Provisions • Delivery System Reforms – Hospital Value-Based Purchasing Program – Pilot project to test bundled Medicare payments – Pilot project to form Accountable Care Organizations and share in Medicare cost savings – Center for Medicare and Medicaid Innovation to test payment service delivery models – Independent Payment Advisory Board Medicare Payment Bundling Pilot Effective dates: • By January 1, 2013 • By 2016, CMS must report results of pilot, making recommendations to Congress for its expansion Payment Bundling Pilot • Voluntary, five-year program • Bundle payments for ten conditions • Cover three days prior to hospital admission to 30 days following discharge • Include: • acute care inpatient; • outpatient, including ED; • physician services in and out of the hospital; and • post-acute care • Secretary will develop bundled payment rates and will test payments based on bids. • Payments cannot exceed what would otherwise be paid for the same services under current Medicare. • After January 1, 2016, the Secretary may expand the program Medicare Shared Savings Accountable Care Organization (ACO) Program Effective date: • By January 1, 2012 the Secretary must establish the program Impact: • $4.9 billion in shared savings between ACOs and the Medicare program nationwide over ten years Medicare Shared Savings Program • Groups of providers and suppliers can apply to be recognized as ACOs • ACOs must act as the primary care provider for at least 5,000 Medicare fee-for-service beneficiaries and agree to do so for at least three years • Share in savings achieve for the Medicare program • Hospitals can take the lead in establishing ACOs • ACOs may include: • group practice arrangements; • networks of individual physician practices; • partnerships or joint venture arrangements between hospitals and practitioners; • other groups of providers and suppliers; and • hospitals employing practitioners. Independent Payment Advisory Board (IPAB) Effective date: • By 2014 IPAB must begin making recommendations Impact: • $13 billion reduction nationwide over ten years IPAB • 15-member IPAB appointed by the President • By 2014 it must begin to submit reports to Congress that would reduce Medicare spending by targeted amounts if it is determined that there is excess cost growth in the Medicare program • 0.5 percentage point reduction in 2015, increasing to a 1.5 percentage point reduction in 2018. • Congress may modify or pass an alternative to the proposals, but is required to maintain the targeted level of Medicare savings for the year. • Should Congress fail to act, IPAB’s original proposal must be implemented. Exemptions From IPAB • Inpatient PPS, home health agencies, outpatient, psychiatric, rehabilitation, and LTC hospitals and hospices will be exempt from IPAB decisions until 2019. • Critical Access Hospitals are NOT exempt. Key Hospital Provisions • Provisions included to begin addressing geographic variation in Medicare spending • Enhanced payments for small and rural hospitals • Extends expiring Medicare provisions • Expands the 340B program • Financial penalties for “excessive” readmissions and “high” rates of hospital-acquired conditions • Physician-Owned Hospitals and Self-Referral Health Reform and PPS Hospitals • • • • • • • Hospital value-based purchasing program Payments to hospitals in “low-cost” counties Low-volume/tweener payment adjustment Readmission penalty Hospital Acquired Conditions penalty Medicare Payment Reductions and IPAB exemption DSH reductions Medicare Value-Based Purchasing Inpatient Value-Based Purchasing • Budget-neutral with each year’s pool fully distributed to hospitals in that same year • Credit for both improvement and attainment • Funded by IPPS payment reductions, beginning with a 1.0% reduction in FFY 2013 and increasing to 2.0% for FFY 2017 and subsequent years. • FFY 2014 include efficiency measures • Demonstration for CAHs and small volume rural hospitals Effective dates: • FFY 2013 implementation of VBP for inpatient hospitals •2012 establish a CAH and small volume rural hospital demonstration • By 2016 establish VBP pilot programs for inpatient rehabilitation, inpatient psychiatric, LTC and cancer hospitals and hospice Percent Carve-Out for VBP Pool 2.5 2.0 1.5 1.0 0.5 0.0 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Geographic Variation and Hospital VBP • The hospital VBP will consider Medicare spending per beneficiary on specific DRGs. – Concept is to calculate efficiency into Medicare payments and reward states that provide high quality at low cost. – States with lower spending per Medicare beneficiary would see higher payments. Geographic Variation—Payments to hospitals in “Low Cost” Counties • Immediate Funding: $400 million in FYs 20102011 to boost payments to PPS hospitals located in counties within the lowest quartile of total Medicare spending per enrollee. • 20 Iowa hospitals qualify • $33.1 million in increased payments to those hospitals over two years. Geographic Variation—Next Steps Additional steps: • Two IOM studies to evaluate and reform the Medicare system to address all geographic disparities for doctors and hospitals and implementation of IOM recommendations by December 2012. • Additional direction to the new Center for Medicare and Medicaid innovation to further test innovative models to incent high quality, low cost care across the provider spectrum. • Convene a National Summit on Geographic Variation Cost, Access, and Value in Health Care later this year. Rural PPS Hospitals • Low-volume/tweener payment adjustment • Effective FY 2011 and 2012 • A low-volume hospital will be defined as one that is more than 15 road miles from another comparable hospital and has up to 1,600 Medicare discharges. • Eligible Iowa hospitals must provide evidence to WPS (FI Contractor) that it meets the necessary requirements by September 1. Medicare Marketbasket Update Reductions and Productivity Offsets Marketbasket (MB) Update Cuts • Applied to: inpatient and outpatient hospital, inpatient rehabilitation, and inpatient psychiatric, LTCH, home health agencies, hospice Effective date: • 2010—update cuts begin • 2012—productivity offsets begin Impact: • $157 billion reduction nationwide over ten years Productivity Offsets • Applied in addition to the MB cuts • Current economy-wide productivity factor is 1.3% • Applied to all providers subject to MB cut plus skilled nursing facilities Productivity Marketbasket Cut Hospital Update Reductions 2.5 2.0 1.5 1.0 0.5 0.0 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Medicare and Medicaid Disproportionate Share Hospital (DSH) Reductions Effective date: FFY 2014 Impact: • $36 billion reduction to hospitals nationwide ($22 billion Medicare, $14 billion Medicaid) over ten years Medicare DSH • DSH payments reduced to 25 percent of current level in 2014. • A portion of the 75 percent cut will be used to establish a fund to pay for ongoing uncompensated care under a new payment method – these payments reduce each year and end after 2019. Medicaid DSH • Reductions set by the legislation. Percent Reduction in DSH Medicaid DSH Medicare DSH Percent Decrease in Uninsured 0% -20% -40% -60% -80% 2014 2015 2016 2017 2018 2019 Medicare Inpatient Hospital Readmissions Payment Policy Effective date: • FFY 2013 for inpatient acute care hospitals Impact: • $7.1 billion reduction nationwide over ten years Readmissions • Acute care hospitals with higher than expected riskadjusted readmissions rates will receive reduced payments for every discharge • In the first and second years, applies to three conditions: heart failure, heart attack, and pneumonia • Expand to additional conditions in future years, including all-cause readmissions • Establish a quality improvement program for hospitals with high severity-adjusted readmissions • Develop a Community Care Transition Program for hospitals with high readmissions rates Medicare and Medicaid Health Care-Acquired Conditions (HACs) Payment Policies Effective dates: • New Medicare HACs inpatient hospital policy begins FFY 2015 • By January 1, 2012, the Secretary must report to Congress on current hospital policy and recommend extension of it to other care settings • Medicaid HAC policy begins July 1, 2011 Medicare HACs • FFY 2015, inpatient hospitals in the worst 25th percentile of risk-adjusted HAC rates will be subject to a 1.0% penalty • The reduction will be applied in addition to current CMS payment adjustments for HACs Report to Extend the Current Medicare HAC Policy • Report by January 1, 2012 on extending the policy to other settings Medicaid HACs • Beginning on July 1, 2011, states must adopt policies ensuring that higher Medicaid payments are not made for cases with conditions covered by the Medicare HAC policy. Critical Access Hospitals CAHs are exempt from harmful payment reductions and policies, but included in IPAB. – Method II Billing issue corrected • The law ensures that CAHs are paid 101 percent of costs for all outpatient services they provide, regardless of the billing method elected, and for providing qualifying ambulance services. – Expands the 340B program – now accepting applications from eligible hospitals. Tax-Exempt Status of Hospitals Effective date: • These provisions apply to taxable years beginning after the date of the enactment, except the community health needs assessment, which is applicable two years later New Requirements for Tax-Exempt Hospitals • Establishes additional criteria for hospitals to maintain their Section 501(c)3 tax-exempt status: • Implementation of strategies to meet community needs—based on the findings of periodic health needs assessments. • Adoption of financial assistance policy that limits charges and prohibits extraordinary collection actions. • Failure to meet the community health plan requirements will result in a $50,000 fine. • Requires the Secretary to report to Congress on the levels of charity care, bad debt, unreimbursed costs of non means-tested government programs, and the cost of community benefit activities incurred by taxexempt, taxable, and public hospitals. Physicians • Medicare Payment Incentives for Primary Care/ General Surgery Providers: – Primary care providers will receive a 10 percent bonus payment for five years, beginning January 1, 2011. (Practitioners in specialties of family medicine, internal medicine, geriatric medicine, pediatric medicine, nurse practitioners, clinical nurse specialists, and physician assistants qualify.) – Qualifying practitioners providing care in a health professional shortage area (HPSA) will also receive the 10 percent bonus – General surgeons providing care in a HPSA will receive a 10 percent bonus on major procedure codes for five years, beginning January 1, 2011. Physicians • Geographic Variation and Physicians: Provides immediate funding of $400 million for the to increase payments to physicians practicing in areas with below average payment rates. • This will directly increase Iowa providers’ reimbursements under Medicare Part B by 5 percent in 2010 and 5 percent in 2011. Next Steps: Implementing Health Care Reform • • Major Provider Medicare and Medicaid changes will be implemented over the next 3-5 years CMS is in the process of prioritizing implementation and has already released instructions to its contractors to begin implementing: • • • • • Ground ambulance add-on payments Air ambulance services “Super rural” ambulance add-on payments Extension of the outpatient hold-harmless provision Extension of reasonable cost payment for clinical lab tests performed by hospitals with fewer than 50 beds in qualified rural areas • Extension of moratorium that allows independent laboratories to bill for the technical component of physician pathology services furnished to hospital patients • Extension of exceptions process for therapy caps • Physician Self-Referral • • Focus is on critical regulatory process – Watch for special rules to implement the law Upcoming Geographic Disparities Summit and continued pressure to begin IOM studies Health Information Technology (IT) • The Economic Stimulus bill provided $19 billion to encourage the adoption of electronic health records in hospitals as well as in the physician community. • CMS has defined standards for qualification including requiring hospitals to adopt new technologies, report progress as well as additional quality measures to be considered “meaningful users” of health information technology. • CMS’ heard the call from hospital advocates and did add more flexibility for hospitals and made some positive improvements to the regulation, though some additional concerns remain. Health IT Iowa Health IT • IHA and Iowa Health System have each been awarded grants to help increase broadband connections among hospitals in the state. • Progress is currently underway to connect Iowa’s hospitals to the Iowa Communications Network. • Once connected, hospitals will be better prepared to connect to the health insurance exchanges and will have much of the needed broadband infrastructure to ease the transition toward electronic health records. Stay Up-to-Date with IHA Join the Iowa Hospital Advocacy Network: www.ihaonline.org/advocacy More than 17,000 Iowa hospital employees are members of the Iowa Hospital Action Network. Receive “call-to-action” emails when issues arise at the State House or on Capitol Hill. The e-mails provide a quick and easy way to contact state and federal legislators in support or in opposition to legislation affecting hospitals or health care in Iowa. Follow IHA on Twitter: www.twitter.com/iowahospital Follow @iowahospital on Twitter! 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