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By Ginger - Site Admin on Monday, September 11, 2017 8:32 AM

On September 8, KHA submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the Medicare hospital outpatient prospective payment system (OPPS) proposed rule for calendar year (CY) 2018. The Association has significant concerns with this proposal's reductions in payment for 340B hospitals as well as changes to remove total knee replacement from the inpatient only list, which is unsafe and will negatively impact hospitals participating in the CMS Comprehensive Care for Joint Replacement (CJR) and the Bundled Payment for Care Improvements (BPCI) programs.

A copy of KHA's comments are available on the Policy page (members only) of www.kyha.com.

If you have any questions, please contact Nancy Galvagni at KHA (ngalvagni@kyha.com).

By Ginger - Site Admin on Wednesday, June 07, 2017 8:50 AM
The Centers for Medicare and Medicaid Services (CMS) invites you to join a webinar on Wednesday, June 7 at 1:00 p.m. (ET) on the Fiscal Year (FY) 2018 Inpatient Prospective Payment System (IPPS) and Long- Term Acute Care Hospital (LTCH) Proposed Rule, and Request for Information.

On April 28, CMS published the FY 2018 IPPS and LTCH Proposed Rule. This webinar will provide an overview of the proposed changes to the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs.

To register, visit http://engage.vevent.com/index.jsp?eid=2133&seid=269.

The audio portion of this webinar...
By Ginger - Site Admin on Wednesday, May 31, 2017 7:55 AM
The Centers for Medicare and Medicaid Services (CMS) encourages you to submit a formal comment on the fiscal year (FY) 2018 Inpatient Prospective Payment System and Long-Term Acute Care Hospital Proposed Rule by 5:00 p.m. (ET) on June 13.

The public can submit comments in several ways:

By electronic submission through the “submit a formal comment” instructions on the ...
By Ginger - Site Admin on Tuesday, May 02, 2017 8:04 AM
On April 28, KHA sent a letter to CGS, Kentucky’s Medicare administrator, objecting to the new sleep lab separate accreditation requirement and requesting a delay and grandfathering of all Joint Commission accredited hospitals.

The notice for the new requirement left less than two months for hospitals to secure the necessary accreditation to continue providing sleep study services to Medicare patients. This change in policy not only caught hospitals off guard, but provides an insufficient and unreasonable timeframe for hospitals to comply.

A copy of the full letter is available on the Policy page of the KHA website (under Advocacy).

If you have any questions, please contact Nancy Galvagni at KHA (ngalvagni@kyha.com).

By Ginger - Site Admin on Thursday, September 15, 2016 8:24 AM
On September 14, KHA submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed Medicaid disproportionate share hospital (DSH) rule addressing the treatment of third-party payers in calculating uncompensated care costs.

KHA and Kentucky's hospitals disagree with the position of CMS to require counting payments from Medicare and other private insurers to calculate uncompensated care costs for retention of DSH payments. The proposed rule would redefine a hospital's cost of care and is not authorized by statute.

The law states clearly that the only costs counted are Medicaid payments and payments made by uninsured patients, not payments made by other programs or insurers.

This proposal would harm many safety net hospitals, and would have devastating consequences for Kentucky's rural hospitals.

For a full copy of the comments, visit the Policy page in the Advocacy section of www.kyha.com.

If you have any questions,...
By Ginger - Site Admin on Wednesday, September 07, 2016 8:38 AM

On September 6, KHA submitted comments to the Centers for Medicare and Medicaid Services on the calendar year (CY) 2017 hospital outpatient prospective payment system (OPPS) proposed rule that would implement site-neutral provisions of the Bipartisan Budget Act of 2015 (BiBA).

Kentucky's hospitals are opposed to CMS' site-neutral proposal because the rule would not only apply to new off-campus outpatient facilities but also to existing hospital outpatient departments (HOPDs) that expand services or relocate to benefit their communities by lowering payment.

For a full copy of KHA's comments, members may visit the Policy page of the Advocacy section of www.kyha.com.

If you have any questions, please contact Nancy Galvagni at KHA (ngalvagni@kyha.com).

By Ginger - Site Admin on Wednesday, August 31, 2016 9:03 AM
CMS issued an invitation the public to comment on the Calendar Year (CY) 2017 Changes to the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) proposed rule . Comments are due by 5:00 p.m. (ET) next Tuesday, September 6.

The CY 2017 OPPS ASC proposed rule includes the following changes to the Medicare and Medicaid EHR Incentive Programs:

Eliminates the Clinical Decision Support (CDS) and Computerized Provider Order Entry (CPOE) objectives and measures beginning in 2017 and reduces the...
By Ginger - Site Admin on Tuesday, August 09, 2016 10:03 AM

The comment period for Kentucky's proposed Medicaid Waiver has been extended to August 14. The extension was posted by the Administration to the web yesterday.

Visit http://chfs.ky.gov/dms/kh for instructions on how to submit your comments if you missed the original July 22 deadline.

By Ginger - Site Admin on Friday, February 19, 2016 9:49 AM
On February 12, KHA submitted comments to the U.S. House Energy and Commerce Committee regarding site-neutral payment policies in response to a request from the Committee to the health care community for input.

The Association expressed concern over payment proposals that would reimburse hospitals at the same payment rates of facilities with lesser clinical capabilities. Since the costs of operating hospitals, which are the safety nets for so many communities, are much higher than other medical facilities, and Medicare and Medicaid reimburse providers at a much lower rate than the cost to care for patients, KHA urged the Committee to reject any further site-neutral payment policies.

KHA expressed disappointment in Section 603 of the Bipartisan Budget Act of 2015. The law would result in substantial reductions in payments for services furnished in provider-based hospital outpatient departments (HOPDs) and prevent beneficial outpatient services from being developed.

The full comment letter is...
By Ginger - Site Admin on Thursday, December 10, 2015 9:06 AM
The Centers for Medicare and Medicaid Services (CMS) on October 16 published a final rule with comment for the Electronic Health Record (EHR) Incentive Program that makes modifications to meaningful use requirements in 2015 through 2017 and sets the start date for Stage 3 of the program. For more details on the rule, see the AHA Regulatory Advisory.

CMS is accepting comments on the provisions of the meaningful use Stage 3 final rule through December 15. AHA will submit comments, and hospitals are strongly encouraged to submit their own comments to the agency. AHA has also provided a model comment letter to assist you. The model comment letter includes recommendations on how to improve the structure of the meaningful use program and increase flexibility to ensure program success by the greatest number of eligible providers. It also includes specific comments on the Stage 3 objectives.

...
By Ginger - Site Admin on Thursday, November 05, 2015 9:25 AM
On October 16, the Centers for Medicare and Medicaid Services (CMS) published a final rule with comment for the Electronic Health Record (EHR) Incentive Program that makes modifications to meaningful use requirements in 2015 through 2017 and sets the required start date for Stage 3 of the program as January 1, 2018. Although this is a final rule, CMS seeks comment on the final policies for the Stage 3 objectives and measures and the EHR reporting period for Stage 3 in 2017 and subsequent years. Public comments received may be considered as CMS plans for the incorporation of meaningful use into implementation of the new physician payment models introduced by the Medicare Access and CHIP Reauthorization Act of 2015 and in future hospital payment rulemaking. The deadline for comments...
By Ginger - Site Admin on Monday, July 27, 2015 8:14 AM

The U.S. House of Representatives Ways and Means Health Subcommittee will host a hearing to discuss rural health care disparities created by Medicare regulations on Tuesday, July 28 at 10:00 a.m. (ET) in Washington.

Oral testimony at this hearing will be from invited witnesses only; however, any individual or organization may submit a written statement for consideration by the committee and for inclusion in the printed record of the hearing.

To submit comments, please visit http://waysandmeans.house.gov/committeesubmissions/.

By Ginger - Site Admin on Tuesday, June 30, 2015 8:08 AM
On May 15, the Cabinet for Health and Family Services (CHFS) published proposed changes to the State Health Plan (SHP) – the state Certificate of Need (CON) criteria regulation. The Cabinet proposes to make significant changes to the technical notes section, remove several services from formal review including MRA, adult day, chemical dependency beds, ambulance services and outpatient Health Centers. Additionally, the Cabinet makes changes to the ambulatory surgery center (ASC) criteria, home health, inpatient physical rehabilitation and megavolt radiation therapy allowing for exceptions to the need criteria for hospitals and other providers. KHA is particularly concerned about proposed changes to ASC criteria which would include exceptions to population need-based methodology. For details, view this brief summary of the proposed changes.

The KHA CON Committee, chaired...
By Ginger - Site Admin on Thursday, June 25, 2015 9:00 AM
Last week, KHA expressed serious concern with certain aspects of the Centers for Medicare and Medicaid Services’ (CMS) proposal for implementing a site-neutral payment component to the Long-Term Care Hospital (LTCH) Prospective Payment System (PPS) for cost reporting periods beginning on or after October 1, 2015.

“KHA supports many of CMS’s proposals, such as the proposal to use a specific 15 Medicare-severity-LTC-diagnosis-related groups to identify the psychiatric and rehabilitation conditions that would be paid a site-neutral rate versus a standard LTCH PPS rate, and KHA supports the proposal to use the previously finalized pressure ulcer measure to meet IMPACT Act requirements,” wrote KHA Membership Services Director Pam Kirchem, commenting on LTCH provisions of the proposed inpatient and LTCH PPS rule for fiscal year 2016. “However, we believe that the proposed two outlier-related budget neutrality adjustments are unwarranted and result in inappropriately lower LTCH payments. We recommend CMS calculate...
By Ginger - Site Admin on Wednesday, May 06, 2015 8:54 AM
The Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) are inviting the public to submit comments on the recently released notices of proposed rulemaking (NPRMs).

Due May 29:

Stage 3 of Meaningful Use NPRM – Specifies the Stage 3 requirements for eligible professionals, eligible hospitals and critical access hospitals in the electronic health records...
By Ginger - Site Admin on Friday, May 01, 2015 8:26 AM

On April 30, KHA submitted comments to the Kentucky Office of Legal Services regarding 907 KAR 10:830 on the proposed diagnosis-related group (DRG) reimbursement methodology for the Medicaid fee-for-service population. The Association's comments addressed a long-standing concern and request by the Medicaid Hospital Technical Advisory Committee (TAC) for providing a transition period to new rates and retaining the existing rate appeal process. KHA also requested changes to maintain budget neutrality in updating rates and clarification on several other aspects of the proposed new methodology.

A copy of the comments is available on the Policy page of the Members Only section of www.kyha.com.

If you have any questions, please contact Nancy Galvagni at KHA (502-426-6220 or 800-945-4542 or via email at ngalvagni@kyha.com).

By Ginger - Site Admin on Wednesday, March 04, 2015 9:11 AM
The Office of Health Policy has announced it will host Certificate of Need (CON) “listening sessions” on March 16 and 17 to allow for further comments regarding the interest in modernizing CON. KHA will have staff at each of the meetings and encourages every hospital to send a representative to one of the two sessions and to make comments briefly at the session. As a reminder, you must register to attend and to speak.

Comments must be brief but should emphasize the importance of CON and the role of CON in stabilizing the health care delivery system in a time when significant change is taking place regarding payment and delivery incentives. Additionally, it is important to maintain CON for the existing services covered under the program, especially ambulatory surgical centers (ASCs).

A study on CON that was completed last Fall is available for your review.

The announcement on the sessions is below, with emphasis added on the registration information. If you have any questions, please...
By Ginger - Site Admin on Monday, March 02, 2015 9:47 AM
On February 27, KHA submitted comments to the Cabinet for Health and Family Services (CHFS) on 902 KAR 20:400 regarding Limited Services Clinics. KHA's concerns  focused on on-call coverage, chart audits and the timeliness of physician notification when a patient receives chronic disease management at the clinic.

Of particular concern is the language in the regulation addressing after hours coverage by the clinic if it provides chronic disease management to patients. The on-call coverage could be provided simply through an answering service which refers patients to "another provider of the same services that is as geographically close as possible and is open at those hours." This would often be a hospital emergency department (ED) which would increase the occurrence of non-emergency visits to hospital EDs.

To view the comments in their entirety, please visit the Policy page of the Members Only section of www.kyha.com.

...
By Ginger - Site Admin on Monday, February 23, 2015 11:25 AM
About CON Modernization  The Office of Health Policy (OHP), the department of the Cabinet for Health and Family Services which oversees Certificate of Need (CON), will be hosting two listening sessions to take comments from providers and other stakeholders on how to modernize the CON program. The OHP published a memo in October 2014 (see Special Memorandum CON Modernization: http://www.kyha.com/members/) requesting comments on how to modernize the CON program to meet goals to transform healthcare delivery systems in Kentucky to promote value-based care delivery and the ability to better manage the continuum of care of patients. 

KHA conducted a thorough study of the CON program with the help of a consultant and submitted a report and comments to the OHP demonstrating that the Kentucky CON program is key to ensuring stability in the health care delivery market to allow for innovative models to promote health care delivery transformation....
By Ginger - Site Admin on Monday, December 08, 2014 1:19 PM

This morning, KHA submitted a Certificate of Need (CON) comment letter and CON study to the Office of Health Policy. That letter can be found on the KHA Website under the Advocacy Section.  

If you have not done so already, KHA encourages you to submit comments today in support of maintaining CON. Comments should be submitted to Diona Mullins via email at Diona.Mullins@ky.gov.  Hospitals may wish to craft their own comments, or simply write in support of the KHA comments and study.

If you have any questions, please contact Elizabeth Cobb at KHA (502-426-6220 or 800-945-4542 or via email at ecobb@kyha.com).

By Ginger - Site Admin on Monday, December 01, 2014 3:38 PM
KHA, under advisement of the KHA Certificate of Need Committee (CON) and the KHA Board of Trustees, has undergone a thorough review of the Kentucky CON program.  A confidential study, found under the members only section of the KHA Website,  was commissioned in response to a memorandum released by the Cabinet requesting comments on modernizing the CON program to support anticipated changes in health care delivery systems as well as questions and criticism in recent years regarding the value of CON.  The study was developed through thoughtful research and input from the KHA CON Committee, the KHA Board of Trustees and system leaders. The study represents a balanced approach in consideration of the significant number of comments KHA has received in recent months.

KHA requests that each member hospital review the confidential draft CON study and submit comments to the Cabinet by the December 8 deadline.  Click here for a copy of the Cabinet's memorandum on CON Modernization....
By Ginger - Site Admin on Monday, November 17, 2014 3:21 PM
The Office of Health Policy (OHP) published a memorandum on October 8, 2014, requesting comments by December 8, 2014, on modernizing the Kentucky Certificate of Need (CON) program.  The OHP sites changes in the health care delivery system and an emphasis on the Triple Aim as a driver in the need to modernize the CON program to ensure access to appropriate levels of care, growth in outpatient services and a focus on ensuring a comprehensive continuum of care.  

The OHP is requesting broad comments in the form of white papers or studies. KHA is undertaking a comprehensive study of the value of the CON program which will be released to our hospital members very soon.  The paper provides evidence supporting the KHA position to uphold a strong CON program in the effort to ensure access to high quality services where need is demonstrated through the CON process.  

KHA encourages every Kentucky hospital to submit a comment letter to the Cabinet for Health and Family Services in support of the CON program...
By Ginger - Site Admin on Monday, October 20, 2014 9:12 AM
This notice is to all hospital chief executive officers and directors of planning.  KHA is conducting an in-depth study of outpatient surgery and ambulatory surgery center (ASC) utilization to help in developing comments in support of the Certificate of Need (CON) Program.  The Cabinet issued a memorandum on October 8 requesting comments on the CON program, and also expressed interest in receiving comments about repealing the CON requirement for some services.   The Cabinet is interested in looking at expanding availability of outpatient services.  KHA is concerned this could include ASCs.  

KHA requests every hospital providing outpatient surgery to complete this electronic survey by October 24.  If this applies to your hospital, please complete the individual surveys for your hospital, and every owned or affiliated ASC that you operate. The survey includes questions about the numbers of surgery suites operated, hours of operation, clean up time, length of procedures, etc.  The data is important in helping...
By Ginger - Site Admin on Thursday, August 28, 2014 9:23 AM
On August 27, AHA submitted the comment letter to the Centers for Medicare and Medicaid Services (CMS) on its proposed rule for the calendar year (CY) 2015 outpatient and ambulatory surgery center (ASC) prospective payment systems (PPS). The letter urges the agency to carefully reconsider its proposed methodology of creating a Healthcare Common Procedure Coding System modifier to track services furnished in off-campus, provider-based hospital outpatient departments. It also recommends changes to the implementation of its new set of claims-level comprehensive ambulatory payment classifications to ensure that it does not negatively and disproportionately impact certain types of hospitals that have specialized case mixes. In addition, AHA opposes CMS’ proposal to require a physician order for all inpatient admissions as a condition of payment under the agency’s general...
By Ginger - Site Admin on Wednesday, August 27, 2014 9:25 AM
In June,the Cabinet for Health and Family Services proposed significant changes to 900 KAR 6:070 (The Certificate of Need Regulation on Formal Review). The proposed changes included removal of the requirement for an applicant to demonstrate geographic need during the formal review process. There are five separate and distinct criteria identified in statute that an applicant must meet for a Certificate of Need (CON) to be awarded including criteria in the State Health Plan and demonstration of need in the area where the services is being proposed, which are two separate criteria. The Cabinet proposed that an application would meet the geographic need criteria if the application was consistent with the need identified through criteria in the state health plan and the inventory of service utilization published annually. This proposed change, if made final in regulation, would have eliminated the separate geographic...
By Ginger - Site Admin on Wednesday, July 23, 2014 9:54 AM
Last week, KHA advised hospitals of proposed amendments filed by the Office of Inspector General (OIG) to significantly raise the annual licensure fees for hospitals and other licensed health facilities (902 KAR 20:008). The fee for hospitals with deemed status would be raised from $10 per bed to $25 per bed plus $1,000. This new fee would apply to all hospital types, and represents an average increase of approximately 200 percent.

Licensing fees have not been increased since 2003; however, a CPI increase from 2003-2014 would amount to roughly a 26 percent increase. The OIG has attempted to justify the exorbitant fee increase by citing that the current fees must be raised to a reasonable level commensurate with the cost of regulating health care facilities. This is especially problematic for hospitals since, by state law, hospitals which are accredited and have deemed status for Medicare participation are given deemed status for licensure and are not even surveyed each year. Under state regulations, the...
By Ginger - Site Admin on Monday, July 14, 2014 10:23 AM
The Cabinet for Health and Family Services has filed proposed amendments to 902 KAR 20:008 – License procedures and fee schedule – to substantially increase the annual licensure fees for all health facilities, including hospitals. To view the changes, visit http://www.lrc.ky.gov/kar/902/020/008reg.htm. All types of hospitals will be charged at the same rate, regardless of whether the hospital has deemed status for licensure. Currently, the per-bed rate for deemed status hospitals is $5.00 lower. The current and proposed rates are as follows:
By Ginger - Site Admin on Friday, June 27, 2014 10:03 AM
On June 1, the Office of Health Policy published proposed changes to 900 KAR 6.070 Certificate of Need (CON) Considerations for Formal Review. Comments will be accepted through June 30.  The proposed change would eliminate the need criteria, which is separate and distinct from criteria in the State Health Plan. Adoption of these changes would significantly change the CON program in Kentucky and would result in the unneeded proliferation of health care services because an application that complies with the State Health Plan would be presumed as meeting the “need” criteria even if the State Health Plan methodology is outdated or inaccurate.

Every KHA member should submit comments outlining concerns with these regulations to the Cabinet on or before Monday, June 30. Hospitals can submit their own comments or you may say that you support the comments submitted by KHA. It is also important to get legislators involved in this issue. KHA is particularly interested in getting support of the Regulation Review Committee...
By Ginger - Site Admin on Friday, March 28, 2014 2:38 PM
On March 27, KHA submitted comments to the Centers for Medicare and Medicaid Services (CMS) regarding the proposed Conditions of Participation (CoP) rule regarding emergency preparedness requirements for Medicare and Medicaid participating providers and suppliers.

A copy of KHA's comment letter is available at http://www.kyha.com/wp-content/uploads/2014/03/KHAResponsetoCMSCOPEPRules.pdf.

The AHA released a Regulatory Advisory on this topic. It is available at http://www.kyha.com/wp-content/uploads/2014/03/EmergencyPreparednessCOP_ProposedRule_RegulatoryAdv.pdf.

For further information, please contact Richard Bartlett at KHA (502-426-6220 or 800-945-4542 or via e-mail at rbartlett@kyha.com)....
By Ginger - Site Admin on Friday, February 28, 2014 3:06 PM
On February 28, KHA, on behalf of its members, submitted comments to the Kentucky Department for Medicaid Services (DMS). The comments addressed the DMS’ proposed amendments to the regulation which outlines cost sharing requirements for Medicaid recipients. KHA has specific concerns related to the changes proposed on copayments for nonemergency visits to the hospital emergency room.

The amendments specifically make two significant changes with respect to services provided in hospital emergency rooms. First, the copayment amount will increase from a maximum of $6.00 to $8.00 for a nonemergency visit in an emergency room. Second, the regulation will require that this copayment be deducted from the Medicaid payment the hospital receives when, previously, the copay was collected without deducting it from the hospital’s total Medicaid reimbursement for the service. These changes are very problematic and will only add to reduced hospital payment for the services they provide to low income patients at a time...
By Ginger - Site Admin on Friday, February 28, 2014 2:58 PM

On February 28, KHA, on behalf of its members, submitted comments to the Kentucky Department for Medicaid Services (DMS). The comments addressed the DMS’ proposed amendments to the outpatient hospital coverage regulation. The Association is concerned with some of the proposals and objects to the exclusion of coverage for occupational therapy provided in a hospital outpatient setting and requested that this be reversed.

For details, view the copy of KHA’s full comments. The document includes a notated copy of the Schedule of Benefits.

If you have questions, please contact Nancy Galvagni at KHA (502-426-6220 or 800-945-4542 or via e-mail at ngalvagni@kyha.com).

By Ginger - Site Admin on Friday, January 31, 2014 10:45 AM
In the fall of 2013, the Cabinet for Health and Family Services (CHFS) requested comments on the State Health Plan criteria and, more specifically, for recommendations on how the State Health Plan should be updated to meet the changing health care needs as a result of implementation of the Affordable Care Act (ACA). The KHA Certificate of Need (CON) Committee, under the direction of Committee Chair Vicki Darnell, thoroughly reviewed the Plan from October through December. The CON Committee, after thoughtful discussion on each component of the Plan as well as consultation with workgroups on specific areas of the plan, finalized recommendations. The Committee recommended that acute care services would not increase in need drastically and therefore would not require any change to the criteria. The Committee did recommend that criteria be added to the plan to address approval of Alternative Birth Centers. The Committee also noted growing challenges with access to care for subsets of the long-term care community...
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