HERB KUHN, DIRECTOR, CMM HOUSE SUBCOMMITTEE ON HEALTH OF THE COMMITTEE ON ENERGY AND COMMERCE
Chairman Deal, Representative Brown , distinguished members of the Subcommittee; I thank you for the opportunity to discuss with you some of the changes in payment for imaging services under the Medicare physician fee schedule. Spending for these services has risen dramatically in the past several years, prompting a number of recommendations by the Medicare Payment Advisory Committee (MedPAC), some proposals by CMS, and subsequent actions by the Congress to address the increased spending associated with the rise in the volume and intensity of these services. We want to insure that Medicare’s payment mechanisms encourage clinically appropriate use of resources and the highest quality of care, and we welcome input from you, the physician community, and other interested parties as we do so.
Background
Medicare spending for imaging services has been growing rapidly. Between 2000 and 2005, spending for imaging services paid under the physician fee schedule more than doubled from $6.6 billion to $13.7 billion, an average annual growth rate of 15.7 percent. This compares to an annual growth rate of 9.6 percent for all physician fee schedule services.
As we noted in a letter to MedPAC on April 7, 2006 (see table 1), while imaging services represented an estimated 14 percent of 2005 spending included in the sustainable growth rate calculation (SGR-related spending), they represented 27 percent of the total increase in such spending between 2004 and 2005. Spending for imaging services contributed 2.3 percentage points of the 8.5 percent increase in SGR-related spending reported in our April 7th letter to MedPAC. No other service category affects the increase in SGR-related spending so disproportionately.
Table 2 shows growth rates for imaging services for calendar years 2003, 2004 and 2005, overall and for four subcategories of imaging services: standard imaging, advanced imaging, echography, and imaging procedures. Overall, spending for imaging services grew at 16 percent per year for each of these years.
The “standard imaging” category includes services such as chest x-rays, contrast gastrointestinal imaging, nuclear medicine procedures, and PET scans. Spending for standard imaging procedures increased by an estimated eight percent during 2005 and by 43 percent from 2003 to 2005. This category represents an estimated five percentage points of the 14 percent share that imaging represents of 2005 SGR-related spending. This category contributes an estimated 0.4 percentage points to the 2.3 percent increase in imaging spending and to the 8.5 percent increase in SGR-related spending.
Spending for the “advanced imaging” category, comprised largely of CAT scans and MRI procedures grew by 25 percent during 2005 and 82 percent from 2003 to 2005. This category represents an estimated five percentage points of the 14 percent share that imaging represents of 2005 SGR-related spending. This category contributes an estimated 1.3 percentage points to the 2.3 percent increase in imaging spending and to the 8.5 percent increase in SGR-related spending.
The “imaging procedures” category includes services such as cardiac catheterization, fluoroscopy, and 3-D holographic reconstruction. Estimated spending for the imaging procedures category of services increased by 20 percent during 2005 and 47 percent from 2003 to 2005. This category represents an estimated one percentage point of the 14 percent share that imaging represents of 2005 SGR-related spending. This category contributes an estimated 0.1 percentage points to the 2.3 percent increase in imaging spending and to the 8.5 percent increase in SGR-related spending.
Estimated expenditures for the “echography” category of services increased by 17 percent during 2005 and grew 49 percent from 2003 to 2005. This category represents an estimated three percentage points of the 14 percent share that imaging represents of 2005 SGR-related spending. This category contributes an estimated 0.6 percentage points to the 2.3 percent increase in imaging spending and to the 8.5 percent increase in SGR-related spending.
No matter how one looks at it, Medicare spending for imaging services under the physician fee schedule is growing very rapidly and more rapidly than spending for other services tracked under the SGR system. While MedPAC suggested that some imaging services have shifted from being furnished in facilities, such as hospitals, to physicians’ offices, MedPAC also observed that about 80 percent of the growth in the volume and intensity of these services is unrelated to a shift in setting. The rapid increase in Medicare spending for imaging services, coupled with extensive geographic variation in their use, raises questions about whether such growth is appropriate and whether all imaging services are used appropriately.
Last week the Administration released the Mid-Session Review of the Budget. Part B spending was up from prior estimates. Spending for physicians’ services is estimated to have increased by 10 percent during 2005, and 7 percentage points of this growth was attributable to the volume and intensity of physicians’ services. The volume and intensity of physicians’ services has increased at rates of 6 to 7 percent per year for the past few years. Growth in spending for physicians’ services has been a notable contributor to the increases in the Part B premium. Rapid increases in spending for imaging services contribute significantly to the increase in spending for physicians’ services.
MedPAC Recommendations and the 2006 Medicare Physician Fee Schedule
Limiting Physician Self-Referrals
Section 1877 of the Social Security Act, known as the “Stark Law,” prohibits a physician from making a referral for certain designated health services, payable by Medicare or Medicaid, to an entity with which the physician or one of his/her close family members has a financial relationship, unless one of a specific list of exceptions applies. Among other things, the statute defines designated health services to include “radiology services, including magnetic resonance imaging, computerized axial tomography and ultrasound services” and “radiation therapy services and supplies”.
In its March 2005 report to Congress, MedPAC recommended inclusion of nuclear medicine services in a list of services for which a physician is prevented from making a self-referral under Medicare and Medicaid.
In the notice of proposed rulemaking (NPRM) for the 2006 physician fee schedule, we pursued this MedPAC recommendation and proposed including diagnostic and therapeutic nuclear medicine procedures under the designated health services categories for radiology and certain other imaging services, and radiation therapy services and supplies, respectively. After considering comments on this proposal, we finalized this policy in the 2006 physician fee schedule final rule. To provide time for the industry to adjust, we deferred the effective date of this policy until January 1, 2007.
Despite this change, most physicians in groups that own imaging equipment will be able to continue to make self-referrals for imaging services within their own group by qualifying for one of the broader exceptions to the law -- the “in-office ancillary services” exception. Thus, defining a given service as a designated health service and making it subject to the prohibition against self-referrals does not mean that it will no longer be delivered pursuant to a self-referral in all cases. This change in policy will therefore be only partially effective in addressing growth in the volume and intensity of that particular type of imaging services.
Taking Efficiencies into Account
In general, payment amounts under the Medicare physician fee schedule are calculated using the assumption that each service is furnished independently. Prior to 2006, fee schedule payments for imaging did not take into account efficiencies that occur when multiple services are furnished sequentially. For example, the fee schedule amounts for CT scans of the pelvis and abdomen are established as if each imaging service were the only one being furnished to a beneficiary during a given encounter. The March 2005 MedPAC report recommended reducing the technical component of fee schedule payments for multiple imaging services performed on contiguous body areas. The technical component of an imaging service captures the administration of the test; it does not include the professional interpretation of the test.
In the NPRM for the 2006 physician fee schedule, we proposed revising payment amounts for the technical component of certain imaging services in order to more accurately reflect the economies of subsequent procedures when multiple imaging services are furnished within one of 11 families of imaging procedures on contiguous body parts in the same session with the patient. Specifically, we proposed establishing payment amounts at 50 percent of the technical component of any subsequent imaging procedures performed on a single patient during a single session if the initial and subsequent services were performed on contiguous body parts within one of 11 families of imaging procedure codes. The 50 percent figure was based on our view that most of the clinical labor and supplies are not furnished twice. In response to comments on the proposal, we indicated in the final rule for the 2006 physician fee schedule that we planned to phase in the 50 percent reduction over two years, beginning with a 25 percent reduction in 2006. However, we indicated that we would continue to accept comments and any supporting information from the public, and consider whether it would be appropriate to modify the 50 percent payment reduction policy scheduled to take effect for 2007.
The statute requires that we make physician fee schedule changes, such as the multiple imaging policy, in a budget-neutral fashion relative to overall physician fee schedule expenditures. If changes result in increased spending compared to spending that would occur without them, then a reduction in payments is needed to achieve budget-neutrality. Similarly, if changes result in decreased spending compared to spending that would occur without them, an increase in payments for all services is needed to achieve budget-neutrality. Since the multiple procedure policy resulted in a decrease in spending, we increased payments for all 2006 physician fee schedule services in order to achieve budget-neutrality.
Assumptions Used in Setting Fee Schedule Payments for Imaging
The methodology for determining practice expense relative values for services that involve equipment such as that used in furnishing imaging services involves assumptions about how frequently the equipment is used. In its September 30, 2005, comments on the NPRM for the 2006 physician fee schedule, MedPAC raised concerns about the equipment utilization assumption for imaging services.
CMS’s method of calculating payments for the technical component of imaging services assumes that imaging equipment is used only 50 percent of the time. MedPAC suggested that imaging equipment could be assumed to be used more than 50 percent of the time, given the rapid growth in imaging services. In its June 2006 report to Congress, MedPAC continued its analysis of the equipment utilization assumption for imaging services and indicated: “If a machine is actually used most of the time, its cost is spread across more units of service, resulting in a lower cost per service than if it were operated half the time. Such equipment is currently overvalued by CMS”. In its June 2006 report to Congress, MedPAC also raised questions about the estimates of the cost of capital to purchase equipment such as imaging equipment.
MedPAC argues that the upshot of CMS’s equipment utilization and capital cost assumptions is that Medicare payments for imaging services are too high. The June 2006 MedPAC report indicates, “increasing the equipment use assumption and lowering the interest rate assumption would reduce PE payment rates for services like CT and MRI studies.” The report contains a table with examples of alternative assumptions; payments for imaging services could be reduced by 40 to 50 percent with alternative assumptions. However, data to substantiate alternative equipment utilization assumptions are not available.
The Deficit Reduction Act of 2005
The Deficit Reduction Act of 2005 contains two major provisions that directly affect Medicare payments for imaging services.
Eliminating Budget-Neutrality for the Multiple Imaging Policy
Subsequent to the publication of the final rule for the 2006 Medicare physician fee schedule, section 5102(a) the Deficit Reduction Act (DRA) of 2005 exempted the multiple imaging savings from budget-neutrality. In other words, the DRA requires that, for the 2007 physician fee schedule, we do not offset the savings attributable to the multiple imaging payment reduction policy for 2006 and 2007 by increasing payments for other physician fee schedule services in 2007.
The Hospital Outpatient Department Cap on Physician Fee Schedule Imaging Payments
DRA establishes caps on physician fee schedule payments for certain imaging services at the payment levels established in Medicare’s hospital outpatient prospective payment system (OPPS). The provision requires that Medicare not pay more under the physician fee schedule than Medicare would pay under the OPPS for furnishing the same imaging procedure. This policy applies to the technical components of imaging services including X-ray, ultrasound, nuclear medicine, MRI, CT, and fluoroscopy services. A physician’s interpretation of the test for which Medicare will pay a separate fee is not affected by the provision. Screening and diagnostic mammograms are exempt from this policy change. This policy will begin in 2007.
An example of how this policy works can be seen in the case of an MRI of the brain or an MRI of the abdomen. In 2006, the Medicare physician fee schedule payment is $903 for the technical component of either of these MRIs. At the same time, Medicare pays hospital outpatient departments $506 for the exact same test. Thus, Medicare is paying almost $400 or 78 percent more for doing these MRI imaging tests purely depending on whether the test is performed in a hospital outpatient department or in a physician’s office (or other setting paid under the physician fee schedule). These comparisons do not include a physician’s interpretation of the test for which Medicare will pay a separate fee.
Among imaging procedures, there is little consistency in the percentage by which payments for the technical component under the physician fee schedule exceed payments under the OPPS. The percentage difference varies by procedure. We are still working on the proposed rules for 2007 for both OPPS and the physician fee schedule. The fee schedule NPRM will contain the specific impacts of the DRA imaging provision.
Conclusion
Medicare spending for imaging services has experienced very rapid growth. In addition, through 2006, Medicare is often paying significantly larger amounts under the physician fee schedule than the OPPS for the same imaging service furnished in the two different settings. MedPAC’s analysis of assumptions used to calculate payment amounts indicates payments for imaging services under the physician fee schedule are too high. However, there is a lack of information to support alternative assumptions.
We will implement the DRA provisions through notice and comment rulemaking. NPRMs for OPPS and the physician fee schedule are expected to be published this summer. Final rules will be published this fall and will be effective for services furnished on or after January 1, 2007.
We realize that significant technological advances in imaging capabilities have made a difference in clinical practice and in the lives of patients. However, we want to ensure that our payment systems reflect clinically appropriate care and do not provide inappropriate incentives for growth in volume and intensity of services with limited clinical benefit. To that end, CMS will continue to work with the physician community, other interested parties, and the Congress as we refine our payments for medical imaging. I thank the Subcommittee for its time and look forward to answering any questions you might have.
Source - http://www.cms.hhs.gov/apps/media/press/testimony.asp?Counter=1903
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Tuesday, September 18, 2007
Tuesday, September 11, 2007
CMS INCREASES MEDICARE PAYMENTS FOR BENEFICIARIES USING SKILLED NURSING FACILITY CARE FOR 2008
ACCURATE PAYMENTS CONTINUE TO ENSURE PROGRAM EFFICIENCY, QUALITY AND SUSTAINABILITY
Under new Medicare payment rates issued today by the Centers for Medicare & Medicaid Services (CMS), Medicare payments for beneficiaries using skilled nursing facility care will increase by approximately $690 million in fiscal 2008.
The 3.3 percent increase will be reflected in Medicare payment rates to skilled nursing facilities and hospitals that furnish certain skilled nursing and rehabilitation care to Medicare beneficiaries recovering from serious health problems. The final rule for the skilled nursing facility (SNF) prospective payment system (PPS) was placed on display at the Federal Register today.
"These new payment rates reflect our commitment to improving the quality of care in the long-term care setting while maintaining predictability and stability in payments for the providers who deliver those important services," CMS Acting Administrator Herb Kuhn said. "They will enable nursing homes and Medicare to continue to move forward in providing quality services for patients who need post-acute care. The SNF rule demonstrates our commitment to ensure that Medicare is affordable for current beneficiaries and is sustained for future generations by paying accurately and efficiently."
Under Medicare's SNF PPS, each skilled nursing facility is paid a daily rate based on the relative needs of individual Medicare patients, adjusted for local labor costs. The daily rate covers the costs of furnishing all covered skilled nursing facility services, including routine services such as room, board, nursing services, and some medical supplies together with related costs such as therapies, drugs and lab services; and capital costs including land, buildings and equipment. CMS uses a skilled nursing facility market basket to measure changes in the prices of an appropriate mix of goods and services included in covered skilled nursing facility stays. The price of items in the market basket is measured each year, and Medicare payments are adjusted accordingly.
The final rule revises and rebases the SNF market basket, which currently reflects data from fiscal year 1997, to reflect data from fiscal year 2004. The new payment rates also continue to include a special adjustment made to cover the additional services required by nursing home residents with HIV/AIDs.
"We are confident that the new payment rates will continue to ensure beneficiary access to the important services skilled nursing facilities provide," Mr. Kuhn said.
A full copy of the SNF PPS final rule for FY 2008 is available on the CMS website at http://www.cms.hhs.gov/snfpps/. It is expected to be published in the Federal Register on Friday, August 3, 2007.
Under new Medicare payment rates issued today by the Centers for Medicare & Medicaid Services (CMS), Medicare payments for beneficiaries using skilled nursing facility care will increase by approximately $690 million in fiscal 2008.
The 3.3 percent increase will be reflected in Medicare payment rates to skilled nursing facilities and hospitals that furnish certain skilled nursing and rehabilitation care to Medicare beneficiaries recovering from serious health problems. The final rule for the skilled nursing facility (SNF) prospective payment system (PPS) was placed on display at the Federal Register today.
"These new payment rates reflect our commitment to improving the quality of care in the long-term care setting while maintaining predictability and stability in payments for the providers who deliver those important services," CMS Acting Administrator Herb Kuhn said. "They will enable nursing homes and Medicare to continue to move forward in providing quality services for patients who need post-acute care. The SNF rule demonstrates our commitment to ensure that Medicare is affordable for current beneficiaries and is sustained for future generations by paying accurately and efficiently."
Under Medicare's SNF PPS, each skilled nursing facility is paid a daily rate based on the relative needs of individual Medicare patients, adjusted for local labor costs. The daily rate covers the costs of furnishing all covered skilled nursing facility services, including routine services such as room, board, nursing services, and some medical supplies together with related costs such as therapies, drugs and lab services; and capital costs including land, buildings and equipment. CMS uses a skilled nursing facility market basket to measure changes in the prices of an appropriate mix of goods and services included in covered skilled nursing facility stays. The price of items in the market basket is measured each year, and Medicare payments are adjusted accordingly.
The final rule revises and rebases the SNF market basket, which currently reflects data from fiscal year 1997, to reflect data from fiscal year 2004. The new payment rates also continue to include a special adjustment made to cover the additional services required by nursing home residents with HIV/AIDs.
"We are confident that the new payment rates will continue to ensure beneficiary access to the important services skilled nursing facilities provide," Mr. Kuhn said.
A full copy of the SNF PPS final rule for FY 2008 is available on the CMS website at http://www.cms.hhs.gov/snfpps/. It is expected to be published in the Federal Register on Friday, August 3, 2007.
CMS INCREASES PAYMENTS TO INPATIENT REHABILITATION FACILITIES FOR FISCAL YEAR 2008
ACCURATE PAYMENTS WILL CONTINUE TO ENSURE PROGRAM EFFICIENCY, QUALITY AND SUSTAINABILITY
Inpatient rehabilitation facilities (IRFs) will receive approximately $6.4 billion in payments from Medicare in fiscal year (FY) 2008, under a rule announced today by the Centers for Medicare & Medicaid Services (CMS). The rule will update payment rates and modify payment policies for services furnished to Medicare beneficiaries for discharges occurring on or after October 1, 2007, through September 30, 2008. The rule's provisions are estimated to increase Medicare payments to approximately 1,220 IRFs in FY 2008 by approximately $150 million.
"Today's rule is designed to ensure accurate payments for intensive rehabilitation care provided to Medicare beneficiaries in IRFs," CMS Acting Deputy Administrator Herb Kuhn said. "This continues Medicare's commitment to support beneficiary access to inpatient rehabilitation facility services while at the same time improving the appropriateness and consistency of payment for care across all post acute settings."
"Moreover, combined with payment system rules released today on skilled nursing facilities, we are demonstrating our commitment to ensure that Medicare is affordable for current beneficiaries and is sustained for future generations by paying accurately and efficiently," added Kuhn.
The final rule increases the IRF payments by 3.2 percent, based on the rehabilitation, psychiatric and long-term care hospital (RPL) market basket. The RPL market basket is designed to capture inflation in the costs of goods and services required to provide the specialized services offered by these facilities, similar to the market basket that applies to general acute care hospitals. The rule also increases the high-cost outlier threshold to $7,362 from $5,534 in FY 2007, based on an analysis of 2006 data, which indicates that this threshold would maintain estimated outlier payments at 3 percent of estimated total payments under the IRF PPS.
Although the higher threshold would mean that fewer cases would qualify for outlier payments, a lower outlier threshold would require an across-the-board reduction in the base payment for an IRF stay in order to maintain budget neutrality. The existing short-stay transfer policy was also clarified to indicate that short-stay transfer cases that meet the criteria to qualify for outlier payments are eligible to receive the additional payments.
The final rule also updates the IRF PPS wage index. When in FY 2006 the IRF PPS adopted the Core Based Statistical Area labor market designations developed by the Office of Management and Budget, we identified some geographic areas where there were no hospitals and, thus, no wage index data on which to base the calculation of the IRF PPS wage index. This situation does not currently affect any IRFs.
The final rule establishes a policy by which the average wage index from all contiguous counties can be used in the future as a reasonable proxy for the rural area within that State. (This policy does not apply in Puerto Rico.).
Finally, a policy commonly referred to as the "75 percent rule" is used by CMS to classify a provider as an IRF. Currently, in addition to a patient's principal diagnosis the comorbidities of a patient may be used to determine whether a provider met the requirements of the 75 percent rule. However, for cost reporting periods beginning on of after July1, 2008, comorbidities no longer can be used to determine whether a provider meets the requirements of the 75 percent rule.
Although CMS carefully examined comments regarding the 75 percent rule, at this time data analysis and clinical research do not support revising the current policy. However, CMS will examine its policies using future data to consider improvements to the classification policy as appropriate. The IRF Prospective Payment System (PPS) was first implemented for cost reporting periods beginning on or after January 1, 2002. The objective of implementing a PPS for IRFs was to increase the accuracy of the payments made to these specialized providers for the resources they use to furnish efficient quality care to Medicare beneficiaries. IRFs have received an increase in payment rates each Federal fiscal year since the IRF PPS was implemented. The payment update is designed to ensure accurate payments are made for intensive rehabilitation care provided to Medicare beneficiaries in IRFs. Promoting accuracy of payments for services to Medicare beneficiaries in IRFs supports Medicare's goal of being a prudent purchaser of health services.
For more information please refer to the CMS IRF PPS web site which is http://www.cms.hhs.gov/InpatientRehabFacPPS/. It is expected to be published in the Federal Register on Tuesday, August 7, 2007.
Inpatient rehabilitation facilities (IRFs) will receive approximately $6.4 billion in payments from Medicare in fiscal year (FY) 2008, under a rule announced today by the Centers for Medicare & Medicaid Services (CMS). The rule will update payment rates and modify payment policies for services furnished to Medicare beneficiaries for discharges occurring on or after October 1, 2007, through September 30, 2008. The rule's provisions are estimated to increase Medicare payments to approximately 1,220 IRFs in FY 2008 by approximately $150 million.
"Today's rule is designed to ensure accurate payments for intensive rehabilitation care provided to Medicare beneficiaries in IRFs," CMS Acting Deputy Administrator Herb Kuhn said. "This continues Medicare's commitment to support beneficiary access to inpatient rehabilitation facility services while at the same time improving the appropriateness and consistency of payment for care across all post acute settings."
"Moreover, combined with payment system rules released today on skilled nursing facilities, we are demonstrating our commitment to ensure that Medicare is affordable for current beneficiaries and is sustained for future generations by paying accurately and efficiently," added Kuhn.
The final rule increases the IRF payments by 3.2 percent, based on the rehabilitation, psychiatric and long-term care hospital (RPL) market basket. The RPL market basket is designed to capture inflation in the costs of goods and services required to provide the specialized services offered by these facilities, similar to the market basket that applies to general acute care hospitals. The rule also increases the high-cost outlier threshold to $7,362 from $5,534 in FY 2007, based on an analysis of 2006 data, which indicates that this threshold would maintain estimated outlier payments at 3 percent of estimated total payments under the IRF PPS.
Although the higher threshold would mean that fewer cases would qualify for outlier payments, a lower outlier threshold would require an across-the-board reduction in the base payment for an IRF stay in order to maintain budget neutrality. The existing short-stay transfer policy was also clarified to indicate that short-stay transfer cases that meet the criteria to qualify for outlier payments are eligible to receive the additional payments.
The final rule also updates the IRF PPS wage index. When in FY 2006 the IRF PPS adopted the Core Based Statistical Area labor market designations developed by the Office of Management and Budget, we identified some geographic areas where there were no hospitals and, thus, no wage index data on which to base the calculation of the IRF PPS wage index. This situation does not currently affect any IRFs.
The final rule establishes a policy by which the average wage index from all contiguous counties can be used in the future as a reasonable proxy for the rural area within that State. (This policy does not apply in Puerto Rico.).
Finally, a policy commonly referred to as the "75 percent rule" is used by CMS to classify a provider as an IRF. Currently, in addition to a patient's principal diagnosis the comorbidities of a patient may be used to determine whether a provider met the requirements of the 75 percent rule. However, for cost reporting periods beginning on of after July1, 2008, comorbidities no longer can be used to determine whether a provider meets the requirements of the 75 percent rule.
Although CMS carefully examined comments regarding the 75 percent rule, at this time data analysis and clinical research do not support revising the current policy. However, CMS will examine its policies using future data to consider improvements to the classification policy as appropriate. The IRF Prospective Payment System (PPS) was first implemented for cost reporting periods beginning on or after January 1, 2002. The objective of implementing a PPS for IRFs was to increase the accuracy of the payments made to these specialized providers for the resources they use to furnish efficient quality care to Medicare beneficiaries. IRFs have received an increase in payment rates each Federal fiscal year since the IRF PPS was implemented. The payment update is designed to ensure accurate payments are made for intensive rehabilitation care provided to Medicare beneficiaries in IRFs. Promoting accuracy of payments for services to Medicare beneficiaries in IRFs supports Medicare's goal of being a prudent purchaser of health services.
For more information please refer to the CMS IRF PPS web site which is http://www.cms.hhs.gov/InpatientRehabFacPPS/. It is expected to be published in the Federal Register on Tuesday, August 7, 2007.
CMS ANNOUNCES PAYMENT CHANGES FOR MEDICARE HOME HEALTH SERVICES
CMS ANNOUNCES PAYMENT CHANGES FOR MEDICARE HOME HEALTH SERVICES, IMPROVING BENEFICIARY ACCESS AND QUALITY AND EFFICIENCY OF CARE
The Centers for Medicare & Medicaid Services (CMS) today issued a final rule to refine and update the Home Health Prospective Payment System (HH PPS) for Calendar Year (CY) 2008. This final rule reflects the ongoing efforts of CMS to support beneficiary access to home health services and improve the quality and efficiency of care provided to Medicare beneficiaries through more accurate payments for services rendered. Refinements to the Medicare HH PPS as well as the annual update to the Medicare payment rates for home health services will disburse an estimated additional $20 million in payments to home health agencies in CY 2008.
“This rule continues the agencies effort to improve the efficiency and quality of care for Medicare beneficiaries,” said CMS Acting Deputy Administrator Herb Kuhn. “And when combined with payment system rules we recently released for inpatient hospitals, inpatient rehabilitation facilities, and skilled nursing facilities, we are demonstrating our commitment to ensure that the Medicare program is sustained for future generations by paying accurately and efficiently,” added Kuhn.
Medicare pays home health agencies through a prospective payment system (PPS) which provides for higher payment rates to care for those beneficiaries with greater needs. Payment rates are based on relevant clinical data from patient assessments required to be performed by all Medicare-participating home health agencies (HHAs).
Home health payment rates have been historically updated annually by either the full home health market basket, or by the home health market basket as adjusted by Congress. The home health market basket index measures inflation in the prices of an appropriate mix of items and services furnished by HHAs. Section 5201(c) of the Deficit Reduction Act (DRA) of 2005 requires an adjustment of the home health market basket percentage update for CY 2007 and subsequent years based on the submission of quality data. The home health market basket increase for CY 2008 is 3.0 percent, which results in $430 million in additional payments to home health agencies in CY 2008.
HHAs collect and report Outcome and Assessment Information Set (OASIS) data. For CY 2008, CMS plans to evaluate home health quality of care by using the submission of the OASIS assessments. Continuing to use the current OASIS instrument ensures that providers avoid the additional burden of reporting through a separate mechanism and the extra costs that are associated with the development and testing of a new reporting mechanism.
The final rule will continue to provide for an adjustment to the payment rates for the non-reporting of OASIS assessment quality data. HHAs that submit the quality data as required under current regulations will receive payments based on the full home health market basket update of 3.0 percent for CY 2008. If a HHA does not submit quality data, the home health market basket percentage increase will be reduced by 2.0 percentage points and the HHA will only receive a 1.0 percent update for CY 2008. CMS posts the nationally accepted and approved quality measures on the Medicare Home Health Compare website located at www.Medicare.gov. This final rule adds two new National Quality Forum (NQF) endorsed measures, Emergent Care for Wound Infections, Deteriorating Wound Status and Improvement in Status of Surgical Wound, to the 10 measures that are currently reported for a total of 12 measures to be reported by HHAs in CY 2008.
CMS analysis of the latest available home health claims data, from CY 2005, indicates a 12.78 percent increase in the observed case mix since 2000. The case mix represents the variations in documented conditions of the patient population served by the HHAs. For the final rule, more detailed analysis was conducted on the 12.78 percent increase in case mix to see if any portion of that increase was associated with a real change in the actual clinical condition of home health patients. CMS examined data on demographics, family support, pre-admission location, clinical severity, and non-home health Part A Medicare expenditure data to predict the average case mix weight for 2005. As a result of this analysis, CMS recognizes that an 11.75 percent increase in case-mix is due to changes in coding practices and documentation rather than to treatment of more resource-intensive patients.
To account for the changes in case mix that are not related to home health patients’ actual clinical conditions, this final rule implements a reduction in the national standardized 60-day episode payment rate for 4 years. That reduction will be taken at 2.75 percent per year for three years beginning in CY 2008 and at 2.71 percent for the fourth year in CY 2011. CMS is requesting comment on one aspect of the final rule concerning the fourth year’s 2.71 percent reduction to the payment rates. CMS will continue to monitor for any further increase in case mix that is not related to a change in patient status, and may adjust the percentage reductions and/or implement further case-mix change adjustments in the future.
Currently HHAs are paid prospectively for 60-day episodes of care. HHAs are paid at different rates for patients, depending on their care needs based upon their clinical severity, their level of function, and their usage of HHA rehabilitation services. This final rule implements an improved case-mix model that accounts for comorbidities and the differing health characteristics of longer-stay patients. The model also accounts more precisely for the impact of rehabilitation services on resource use. The revised case mix system replaces the current therapy threshold of 10 visits per episode with three new therapy thresholds at 6, 14, and 20 therapy visits, with graduated payment levels between the thresholds, to reduce the impact of financial incentives on the delivery of therapy visits. These improvements increase the ability of the case-mix model to predict the intensity of resources used to treat home health beneficiaries over a 60-day period, and thus enhance the accuracy of Medicare’s payments to HHAs.
This rule also implements a modification to the low utilization payment adjustment (LUPA) and eliminates the significant change in condition (SCIC) payment adjustment. The rule implements an increased payment for LUPA episodes that occur as the only episode or the first episode during a period of home health care to account for front-loading of costs in an episode.
In light of concerns raised by providers and an analysis of recent home health data, CMS is changing the way we account for non-routine medical supplies (NRS) in the standardized 60-day episode payment rate. This rule implements a payment model for NRS based on 6 severity groups, similar to the clinical case-mix model, to more accurately reflect home health agency costs. CMS added a sixth severity level, to the 5 levels described in the proposed rule, to address episodes with extremely high NRS costs.
Taken together, these budget-neutral refinements will more accurately match HHA costs with payments received while maintaining the fiscal integrity of the Medicare system and encouraging quality care for beneficiaries.
Fact Sheet is available at:
http://www.cms.hhs.gov/apps/media/fact_sheets.asp
Press Release is available at:
http://www.cms.hhs.gov/apps/media/press_releases.asp
A link to the regulation and accompanying documents will be available at: http://www.cms.hhs.gov/center/hha.asp.
The Centers for Medicare & Medicaid Services (CMS) today issued a final rule to refine and update the Home Health Prospective Payment System (HH PPS) for Calendar Year (CY) 2008. This final rule reflects the ongoing efforts of CMS to support beneficiary access to home health services and improve the quality and efficiency of care provided to Medicare beneficiaries through more accurate payments for services rendered. Refinements to the Medicare HH PPS as well as the annual update to the Medicare payment rates for home health services will disburse an estimated additional $20 million in payments to home health agencies in CY 2008.
“This rule continues the agencies effort to improve the efficiency and quality of care for Medicare beneficiaries,” said CMS Acting Deputy Administrator Herb Kuhn. “And when combined with payment system rules we recently released for inpatient hospitals, inpatient rehabilitation facilities, and skilled nursing facilities, we are demonstrating our commitment to ensure that the Medicare program is sustained for future generations by paying accurately and efficiently,” added Kuhn.
Medicare pays home health agencies through a prospective payment system (PPS) which provides for higher payment rates to care for those beneficiaries with greater needs. Payment rates are based on relevant clinical data from patient assessments required to be performed by all Medicare-participating home health agencies (HHAs).
Home health payment rates have been historically updated annually by either the full home health market basket, or by the home health market basket as adjusted by Congress. The home health market basket index measures inflation in the prices of an appropriate mix of items and services furnished by HHAs. Section 5201(c) of the Deficit Reduction Act (DRA) of 2005 requires an adjustment of the home health market basket percentage update for CY 2007 and subsequent years based on the submission of quality data. The home health market basket increase for CY 2008 is 3.0 percent, which results in $430 million in additional payments to home health agencies in CY 2008.
HHAs collect and report Outcome and Assessment Information Set (OASIS) data. For CY 2008, CMS plans to evaluate home health quality of care by using the submission of the OASIS assessments. Continuing to use the current OASIS instrument ensures that providers avoid the additional burden of reporting through a separate mechanism and the extra costs that are associated with the development and testing of a new reporting mechanism.
The final rule will continue to provide for an adjustment to the payment rates for the non-reporting of OASIS assessment quality data. HHAs that submit the quality data as required under current regulations will receive payments based on the full home health market basket update of 3.0 percent for CY 2008. If a HHA does not submit quality data, the home health market basket percentage increase will be reduced by 2.0 percentage points and the HHA will only receive a 1.0 percent update for CY 2008. CMS posts the nationally accepted and approved quality measures on the Medicare Home Health Compare website located at www.Medicare.gov. This final rule adds two new National Quality Forum (NQF) endorsed measures, Emergent Care for Wound Infections, Deteriorating Wound Status and Improvement in Status of Surgical Wound, to the 10 measures that are currently reported for a total of 12 measures to be reported by HHAs in CY 2008.
CMS analysis of the latest available home health claims data, from CY 2005, indicates a 12.78 percent increase in the observed case mix since 2000. The case mix represents the variations in documented conditions of the patient population served by the HHAs. For the final rule, more detailed analysis was conducted on the 12.78 percent increase in case mix to see if any portion of that increase was associated with a real change in the actual clinical condition of home health patients. CMS examined data on demographics, family support, pre-admission location, clinical severity, and non-home health Part A Medicare expenditure data to predict the average case mix weight for 2005. As a result of this analysis, CMS recognizes that an 11.75 percent increase in case-mix is due to changes in coding practices and documentation rather than to treatment of more resource-intensive patients.
To account for the changes in case mix that are not related to home health patients’ actual clinical conditions, this final rule implements a reduction in the national standardized 60-day episode payment rate for 4 years. That reduction will be taken at 2.75 percent per year for three years beginning in CY 2008 and at 2.71 percent for the fourth year in CY 2011. CMS is requesting comment on one aspect of the final rule concerning the fourth year’s 2.71 percent reduction to the payment rates. CMS will continue to monitor for any further increase in case mix that is not related to a change in patient status, and may adjust the percentage reductions and/or implement further case-mix change adjustments in the future.
Currently HHAs are paid prospectively for 60-day episodes of care. HHAs are paid at different rates for patients, depending on their care needs based upon their clinical severity, their level of function, and their usage of HHA rehabilitation services. This final rule implements an improved case-mix model that accounts for comorbidities and the differing health characteristics of longer-stay patients. The model also accounts more precisely for the impact of rehabilitation services on resource use. The revised case mix system replaces the current therapy threshold of 10 visits per episode with three new therapy thresholds at 6, 14, and 20 therapy visits, with graduated payment levels between the thresholds, to reduce the impact of financial incentives on the delivery of therapy visits. These improvements increase the ability of the case-mix model to predict the intensity of resources used to treat home health beneficiaries over a 60-day period, and thus enhance the accuracy of Medicare’s payments to HHAs.
This rule also implements a modification to the low utilization payment adjustment (LUPA) and eliminates the significant change in condition (SCIC) payment adjustment. The rule implements an increased payment for LUPA episodes that occur as the only episode or the first episode during a period of home health care to account for front-loading of costs in an episode.
In light of concerns raised by providers and an analysis of recent home health data, CMS is changing the way we account for non-routine medical supplies (NRS) in the standardized 60-day episode payment rate. This rule implements a payment model for NRS based on 6 severity groups, similar to the clinical case-mix model, to more accurately reflect home health agency costs. CMS added a sixth severity level, to the 5 levels described in the proposed rule, to address episodes with extremely high NRS costs.
Taken together, these budget-neutral refinements will more accurately match HHA costs with payments received while maintaining the fiscal integrity of the Medicare system and encouraging quality care for beneficiaries.
Fact Sheet is available at:
http://www.cms.hhs.gov/apps/media/fact_sheets.asp
Press Release is available at:
http://www.cms.hhs.gov/apps/media/press_releases.asp
A link to the regulation and accompanying documents will be available at: http://www.cms.hhs.gov/center/hha.asp.
CMS ISSUES FINAL RULE PROHIBITING PHYSICIAN SELF-REFERRAL
CMS today issued final regulations prohibiting physicians from referring Medicare patients for certain items, services and tests provided by businesses in which they or their immediate family members have a financial interest.
This regulation is the third phase of the final regulations implementing the physician self-referral prohibition commonly referred to as the Stark law.
“These rules protect beneficiaries from receiving services they may not need and the Medicare program from paying potentially unnecessary costs,” said Herb Kuhn, CMS acting deputy administrator.
This third phase of rulemaking (Phase III) responds to public comments on the Phase II interim final rule published March 26, 2004 in the Federal Register. The rule does not establish any new exceptions to the self-referral prohibition, but rather makes certain refinements that could permit or, in some cases, require restructuring of some existing arrangements, CMS officials explained.
“We believe this final rule is consistent with the statute’s goals and directives, and protects our beneficiaries,” Kuhn said.
Based on public comments on the Phase II rule, this final regulation includes the following actions:
Provides enhanced flexibility in structuring non-abusive compensation arrangements. For example, the rules regarding physician recruitment and retention payments are expanded to permit recruitment of more physicians into extended areas when needed.
Provides relief for inadvertent violations of the self-referral prohibition under certain circumstances. For example, the rules permit parties that inadvertently exceed the limit on non-monetary compensation to continue to satisfy the requirements of the exception if the excess non-monetary compensation did not exceed 50 percent of the permitted amount and is repaid within 180 days of its receipt or the end of the calendar year, whichever is earlier.
Reduces the regulatory burden for compliance with certain exceptions. For example, the Phase III final rule eliminates the requirement that entities providing professional courtesy provide written notice to an insurer of a reduction of any coinsurance obligation.
Clarifies the agency’s interpretation of existing regulations. For example, the rule clarifies which provisions in office space and equipment lease agreements may be amended during the initial and subsequent terms of the agreements.
“As guardians of the Medicare program, we must be mindful of the potential impact that physician conflicts of interest can have on the Medicare program and its beneficiaries,” Kuhn said. “The rule we released today strikes the proper balance between protecting patients and the program, and providing needed flexibility to health care entities to ensure the provision of quality care to our beneficiaries without unnecessarily impeding non‑abusive arrangements.”
The final rule, which was put on display today, will be published in the September 5, 2007 Federal Register. For more information, visit the CMS Web site at: http://www.cms.hhs.gov/PhysicianSelfReferral/
This regulation is the third phase of the final regulations implementing the physician self-referral prohibition commonly referred to as the Stark law.
“These rules protect beneficiaries from receiving services they may not need and the Medicare program from paying potentially unnecessary costs,” said Herb Kuhn, CMS acting deputy administrator.
This third phase of rulemaking (Phase III) responds to public comments on the Phase II interim final rule published March 26, 2004 in the Federal Register. The rule does not establish any new exceptions to the self-referral prohibition, but rather makes certain refinements that could permit or, in some cases, require restructuring of some existing arrangements, CMS officials explained.
“We believe this final rule is consistent with the statute’s goals and directives, and protects our beneficiaries,” Kuhn said.
Based on public comments on the Phase II rule, this final regulation includes the following actions:
Provides enhanced flexibility in structuring non-abusive compensation arrangements. For example, the rules regarding physician recruitment and retention payments are expanded to permit recruitment of more physicians into extended areas when needed.
Provides relief for inadvertent violations of the self-referral prohibition under certain circumstances. For example, the rules permit parties that inadvertently exceed the limit on non-monetary compensation to continue to satisfy the requirements of the exception if the excess non-monetary compensation did not exceed 50 percent of the permitted amount and is repaid within 180 days of its receipt or the end of the calendar year, whichever is earlier.
Reduces the regulatory burden for compliance with certain exceptions. For example, the Phase III final rule eliminates the requirement that entities providing professional courtesy provide written notice to an insurer of a reduction of any coinsurance obligation.
Clarifies the agency’s interpretation of existing regulations. For example, the rule clarifies which provisions in office space and equipment lease agreements may be amended during the initial and subsequent terms of the agreements.
“As guardians of the Medicare program, we must be mindful of the potential impact that physician conflicts of interest can have on the Medicare program and its beneficiaries,” Kuhn said. “The rule we released today strikes the proper balance between protecting patients and the program, and providing needed flexibility to health care entities to ensure the provision of quality care to our beneficiaries without unnecessarily impeding non‑abusive arrangements.”
The final rule, which was put on display today, will be published in the September 5, 2007 Federal Register. For more information, visit the CMS Web site at: http://www.cms.hhs.gov/PhysicianSelfReferral/
Friday, September 7, 2007
Healthcare Glossary and Acronyms
The following two links are a Healthcare Glossary and Healthcare Acronyms provided by CMS. This is a great tool for that new Underwriter or Field Examiner - who is unfamiliar with the healthcare industry.
Source- http://www.cms.hhs.gov/apps/glossary/default.asp?Letter=ALL&Language=English
Source- http://www.cms.hhs.gov/apps/acronyms/results.asp?Letter=ALL&lstChars=Z&Search=Submit+Advanced+Search
Source- http://www.cms.hhs.gov/apps/glossary/default.asp?Letter=ALL&Language=English
Source- http://www.cms.hhs.gov/apps/acronyms/results.asp?Letter=ALL&lstChars=Z&Search=Submit+Advanced+Search
List of Typical Covenants for an Asset Based Loan
List of Typical Covenants for an Asset Based Loan:
- Accounts Receivable Turnover
- Average Days Outstanding
- Current Ratio
- Delinquency Ratio
- Fixed Charge Coverage Ratio
- Loss to Liquidation Ratio
- Minimum/Maximum Capital Expenditures
- Minimum Liquidity
- Monthly Aggregate Amount of Collections
- Net Worth
- Quarterly and Annual EBITDA
- Tangible Net Worth
- Total Accounts Receivable between 90 and 120 days
The definitions can be found at http://www.investopedia.com/dictionary/default.asp
Healthcare Collateral Consulting, LLC can perform a thorough remote review of the borrower's performance and any changes in its collateral. HCC can provide our clients with quarterly, semi-annual, or annual credit memorandums. This review can also include the spreading and analysis of financial statements, compliance with loan covenants, and trend analysis of key performance metrics.
David J. Lacasse, Managing Director/President
Healthcare Collateral Consulting, LLC
Fairfield County, Connecticut
Terms: Asset Based Business Lines of Credit
An asset based business line of credit is usually designed for the same purpose as a normal business line of credit - to allow the company to bridge itself between the timing of cashflows of payments it receives and expenses. The primary timing issue involves what are known as accounts receivables - the delay between selling something to a customer and receiving payment for it. A non asset based line of credit will have a credit limit set on account opening by the accounts receivables size, to ensure that it is used for the correct purpose. An asset based line of credit however, will generally have a credit limit that fluctuates based on the actual accounts receivables balances that the company has on an ongoing basis. This requires the lender to monitor and audit the company to evaluate the accounts receivables size, but also allows for larger limit lines of credits, and can allow companies to borrow that normally would not be able to. Finally, an asset based line of credit charges an interest rate high enough and has other terms which generally allow the lender to profitably collect the money owed to the company should the company default on payments to the lender. The most extreme form of an asset based line of credit is known as factoring, where the company sells off its receivables so that now its customers owe the lender. The lender mitigates its risk by controlling who the company does business with to make sure that the company's customers can actually pay.
Lines of credits to even riskier companies may require that the company deposit all of its funds into a "blocked" account. The lender then approves any withdrawals from that account by the company and controls when the company pays down the line of credit balance.
For more information, David J. Lacasse can be reached at healthcarecollateralconsulting@gmail.com or (203) 610-2515.
Lines of credits to even riskier companies may require that the company deposit all of its funds into a "blocked" account. The lender then approves any withdrawals from that account by the company and controls when the company pays down the line of credit balance.
For more information, David J. Lacasse can be reached at healthcarecollateralconsulting@gmail.com or (203) 610-2515.
Wednesday, September 5, 2007
Terms: Lines of Credit
A line of credit loan is designed to provide short term funds to a company in order to maintain a positive cash flow. Then, as funds are generated later in the business cycle, the loan is repaid. Most commercial banks offer a revolving line of credit, where a fixed amount is available. As funds are used, the "credit line" is reduced and when payments are made, the line is replenished. One advantage of a line of credit is that the no interest is accrued until the funds are withdrawn, but the line is immediately available for the company's cash flow needs.
Terms: Long Term Debt
Long term debt is one of the initial financing avenues a company should pursue. Most long term debt takes on the form of a loan where the interest and part of the principal are paid back in equal installments over the life of the loan. Some of the sources for business loans include the following:
- commercial banks
- government sponsored loan programs
- small business investment companies
- private lenders
Terms: Letters of Credit
A letter of credit is a guarantee from a bank that a specific obligation will be honored by the bank if the borrower fails to pay. Letters of credit can be useful when dealing with new vendors who may not be assured of a company's credit worthiness. The bank would then offer a letter of credit as an assurance to the vendor of payment. Although no funds are paid by the bank, the credit requirements for a line of credit and a letter of credit are similar.
Terms: Loan Workouts
A loan workout is the process of repaying a problem loan in a fashion that is most agreeable to the lender and the company. Among the steps involved in a successful workout are maintaining communication with the lender, creating a revised payment schedule, and forming a workout team composed of the company's management, representatives from the lending institution, and legal counsel to manage the process. One of the initial steps in workout proceedings is to recognize that repayment of the loan will not occur. The earlier the company recognizes that a problem exists, the greater their flexibility in dealing with the problem. Financial consultants who specialize in loan workouts are also available to coordinate the efforts of the company and the lender. These consultants can direct the workout team's efforts and suggest solutions to the problem.
We are looking for Directors and Associates.
We are looking for Directors and Associates. These positions require that you travel, when you are not on your road, you can work from home.
Associates must have a minimum of 2 years of asset-based lending, or healthcare business, or field examination experience and a bachelors degree in finance or accounting from an accredited university. Commercial credit and/or direct business experience is a plus. Great instincts and intuition is required. In addition, the candidate must be proficient in Microsoft Excel and have the ability to quickly learn a variety of field exam templates. Since all field exams are reviewed by directors prior to distributing to the client, the candidate must be able to accept constructive criticism and meet strict deadlines.
Directors must have a minimum of 4 years of asset-based lending, or healthcare business, or field examination experience, must have managed a staff of associates, and a bachelors degree in finance or accounting from an accredited university. Directors will manage both audits and manage a team of ambitious professionals. Directors will be responsible for overall management of the regional staff providing comprehensive due diligence and generating revenue/referrals.
Candidates must be able to answer this question: What does net collectible value or expected net value mean within healthcare providers?
This is a start-up company with huge potential for growth. Are you ready to grow this company? If you are interested in learning more, or would like to get in touch with me; just reply back to this email: djlacasse@gmail.com. Please included your name, resume in word, and phone number where I can reach you.
If you know of anyone who has Healthcare ABL audit experience and is looking for a better opportunity, please forward my information to them.
Look forward to hearing from you,
Associates must have a minimum of 2 years of asset-based lending, or healthcare business, or field examination experience and a bachelors degree in finance or accounting from an accredited university. Commercial credit and/or direct business experience is a plus. Great instincts and intuition is required. In addition, the candidate must be proficient in Microsoft Excel and have the ability to quickly learn a variety of field exam templates. Since all field exams are reviewed by directors prior to distributing to the client, the candidate must be able to accept constructive criticism and meet strict deadlines.
Directors must have a minimum of 4 years of asset-based lending, or healthcare business, or field examination experience, must have managed a staff of associates, and a bachelors degree in finance or accounting from an accredited university. Directors will manage both audits and manage a team of ambitious professionals. Directors will be responsible for overall management of the regional staff providing comprehensive due diligence and generating revenue/referrals.
Candidates must be able to answer this question: What does net collectible value or expected net value mean within healthcare providers?
This is a start-up company with huge potential for growth. Are you ready to grow this company? If you are interested in learning more, or would like to get in touch with me; just reply back to this email: djlacasse@gmail.com. Please included your name, resume in word, and phone number where I can reach you.
If you know of anyone who has Healthcare ABL audit experience and is looking for a better opportunity, please forward my information to them.
Look forward to hearing from you,
Experience:
Healthcare Collateral Consulting, LLC Associates are our most valuable asset. Our professional have numerous years of cumulative experience as healthcare asset-based lending examiners, managers, and supervisors with some of the nation's largest asset based lenders.
Tuesday, September 4, 2007
Healthcare Collateral Consulting, LLC would like to announce two new services.
Healthcare Collateral Consulting, LLC would like to announce two new services.
UCC Research: Healthcare Collateral Consulting, LLC can make available its clients UCC searches with greater reliability and security while helping to increase productivity through potential time and cost savings. HCC has access to an extensive database which allows customizable searches at listed prices to our clients. Public information from every state and in every field - UCC, real property, corporate charter, bankruptcy, tax liens and judgments are all covered. HCC can save time by accelerating the loan approval process and can increase productivity by centralizing UCC search function. HCC can search, manage and track the activity for you.
Monitoring Healthcare Facility Survey Results: Healthcare Collateral Consulting, LLC can offer its clients, facility survey results as a likely time saving opportunity. HCC can also recognize potential collateral issues with a revolving line of credit if the facility is non-compliant from its survey results. HCC has access to the Surveys, Certifications, and Reporting database – this includes facility characteristics and health deficiencies issued during the most recent state inspection and recent complaint investigations. Healthcare facilities are required to be in compliance with the State and Federal regulations, to receive payment under the Medicare or Medicaid programs. HCC can save its clients the burden of identifying non-compliant facilities and alerting them of any impending collateral issues. Healthcare Collateral Consulting, LLC can increase visibility and productivity by centralizing this survey monitoring function.
How do you get started?
If you are interested in learning more about our new services and would like a pricing guide. You can email your questions to: djlacasse@gmail.com. Please included your name, title, company name and phone number where you can be reached.
Regards,
David J. Lacasse Managing Director/President
Healthcare Collateral Consulting, LLC
Fairfield County, Connecticut
203-610-2515
Company Profile:
Healthcare Collateral Consulting, LLC ("HCC") offers outsourced due diligence services including field examinations, credit, underwriting, and risk analysis for healthcare lenders, including banks, asset-based lenders, private equity and institutional investors. HCC's associates have extensive healthcare experience in credit, collateral, underwriting, audit, workout management, operations, and account management. Our healthcare knowledge provides lenders with additional insight into healthcare trade risks that cannot be provided by most other accounting or audit firms.
UCC Research: Healthcare Collateral Consulting, LLC can make available its clients UCC searches with greater reliability and security while helping to increase productivity through potential time and cost savings. HCC has access to an extensive database which allows customizable searches at listed prices to our clients. Public information from every state and in every field - UCC, real property, corporate charter, bankruptcy, tax liens and judgments are all covered. HCC can save time by accelerating the loan approval process and can increase productivity by centralizing UCC search function. HCC can search, manage and track the activity for you.
Monitoring Healthcare Facility Survey Results: Healthcare Collateral Consulting, LLC can offer its clients, facility survey results as a likely time saving opportunity. HCC can also recognize potential collateral issues with a revolving line of credit if the facility is non-compliant from its survey results. HCC has access to the Surveys, Certifications, and Reporting database – this includes facility characteristics and health deficiencies issued during the most recent state inspection and recent complaint investigations. Healthcare facilities are required to be in compliance with the State and Federal regulations, to receive payment under the Medicare or Medicaid programs. HCC can save its clients the burden of identifying non-compliant facilities and alerting them of any impending collateral issues. Healthcare Collateral Consulting, LLC can increase visibility and productivity by centralizing this survey monitoring function.
How do you get started?
If you are interested in learning more about our new services and would like a pricing guide. You can email your questions to: djlacasse@gmail.com. Please included your name, title, company name and phone number where you can be reached.
Regards,
David J. Lacasse Managing Director/President
Healthcare Collateral Consulting, LLC
Fairfield County, Connecticut
203-610-2515
Company Profile:
Healthcare Collateral Consulting, LLC ("HCC") offers outsourced due diligence services including field examinations, credit, underwriting, and risk analysis for healthcare lenders, including banks, asset-based lenders, private equity and institutional investors. HCC's associates have extensive healthcare experience in credit, collateral, underwriting, audit, workout management, operations, and account management. Our healthcare knowledge provides lenders with additional insight into healthcare trade risks that cannot be provided by most other accounting or audit firms.
Indirect Medical Education (IME)
Indirect Medical Education (IME)
Section 1886(d)(5)(B) of the Act provides that prospective payment hospitals that have residents in an approved graduate medical education (GME) program receive an additional payment for a Medicare discharge to reflect the higher patient care costs of teaching hospitals relative to non-teaching hospitals. The regulations regarding the calculation of this additional payment, known as the indirect medical education (IME) adjustment, are located at 42 CFR §412.105. The additional payment is based on the IME adjustment factor. The IME adjustment factor is calculated using a hospital's ratio of residents to beds, which is represented as r, and a multiplier, which is represented as c, in the following equation: c x [(1 + r).405 - 1]. The multiplier c is set by Congress. Thus, the amount of IME payment that a hospital receives is dependent upon the number of residents the hospital trains and the current level of the IME multiplier.
The formula is traditionally described in terms of a certain percentage increase in payment for every 10-percent increase in the resident-to-bed ratio. For discharges occurring during FY 2003 and thereafter, the formula multiplier is 1.35. The formula multiplier of 1.35 represents a 5.5 percent increase in IME payment for every 10 percent increase in the resident-to-bed ratio.
Balanced Budget Act (BBA) of 1997 Reforms: the IME Multiplier -- The BBA reduced the level of the IME multiplier over a 4 year period because of a concern that the IME adjustment overpaid hospitals relative to their additional teaching costs. The BBA revised the IME formula to reduce the IME adjustment factor from 7.7 percent to 7.0 percent in FY 1998, 6.5 percent in FY 1999, 6.0 percent in FY 2000, and 5.5 percent in FY 2001 and subsequent fiscal years.
Balanced Budget Refinement Act (BBRA) of 1999 Reforms: the IME Multiplier -- The BBRA slowed the transition set by the BBA for the IME adjustment factor. For FY 2000, special payments were made to each hospital to maintain the IME factor at 6.5 percent. For FY 2001, the factor increased to 6.25 percent. The implementation of the factor at 5.5 percent was delayed until FY 2002.
Benefits Improvement and Protection Act (BIPA) of 2000 Reforms: the IME Multiplier -- The BIPA changed the IME payment add-on for FY 2001 to 6.25 percent for discharges occurring on October 1, 2000 and before April 1, 2001, and to 6.75 percent for discharges occurring after April 1, 2001 and before October 1, 2001. The IME adjustment would be 6.5 percent in FY 2002 and 5.5 percent in FY 2003 and subsequent years.
View the Direct Graduate Medical Education (DGME) Payments web page, located in the left navigational area, to see questions related to Medicare GME payments for residents training in non-hospital settings.
Source - http://www.cms.hhs.gov/AcuteInpatientPPS/07_ime.asp
Indirect Medical Education
The Social Security Act provides that prospective payment hospitals that have residents in an approved GME program receive an additional payment for a Medicare discharge to reflect the higher patient care costs of teaching hospitals relative to non-teaching hospitals. This additional payment is known as the IME adjustment and it is based on the IME adjustment factor. The IME adjustment factor is calculated using a hospital’s ratio of residents to beds and a multiplier, which is set by Congress. Thus, the amount of IME payment that a hospital receives is dependent upon the number of residents the hospital trains and the current level of the IME multiplier. Based on the multiplier set in the Medicare Modernization Act, for discharges occurring during FY 2007, the IME multiplier will be set at 1.32.
http://www.cms.hhs.gov/apps/media/press/factsheet.asp?Counter=1835&intNumPerPage=10&checkDate=&checkKey=&srchType=1&numDays=3500&srchOpt=0&srchData=&keywordType=All&chkNewsType=6&intPage=&showAll=&pYear=&year=&desc=false&cboOrder=date
Section 1886(d)(5)(B) of the Act provides that prospective payment hospitals that have residents in an approved graduate medical education (GME) program receive an additional payment for a Medicare discharge to reflect the higher patient care costs of teaching hospitals relative to non-teaching hospitals. The regulations regarding the calculation of this additional payment, known as the indirect medical education (IME) adjustment, are located at 42 CFR §412.105. The additional payment is based on the IME adjustment factor. The IME adjustment factor is calculated using a hospital's ratio of residents to beds, which is represented as r, and a multiplier, which is represented as c, in the following equation: c x [(1 + r).405 - 1]. The multiplier c is set by Congress. Thus, the amount of IME payment that a hospital receives is dependent upon the number of residents the hospital trains and the current level of the IME multiplier.
The formula is traditionally described in terms of a certain percentage increase in payment for every 10-percent increase in the resident-to-bed ratio. For discharges occurring during FY 2003 and thereafter, the formula multiplier is 1.35. The formula multiplier of 1.35 represents a 5.5 percent increase in IME payment for every 10 percent increase in the resident-to-bed ratio.
Balanced Budget Act (BBA) of 1997 Reforms: the IME Multiplier -- The BBA reduced the level of the IME multiplier over a 4 year period because of a concern that the IME adjustment overpaid hospitals relative to their additional teaching costs. The BBA revised the IME formula to reduce the IME adjustment factor from 7.7 percent to 7.0 percent in FY 1998, 6.5 percent in FY 1999, 6.0 percent in FY 2000, and 5.5 percent in FY 2001 and subsequent fiscal years.
Balanced Budget Refinement Act (BBRA) of 1999 Reforms: the IME Multiplier -- The BBRA slowed the transition set by the BBA for the IME adjustment factor. For FY 2000, special payments were made to each hospital to maintain the IME factor at 6.5 percent. For FY 2001, the factor increased to 6.25 percent. The implementation of the factor at 5.5 percent was delayed until FY 2002.
Benefits Improvement and Protection Act (BIPA) of 2000 Reforms: the IME Multiplier -- The BIPA changed the IME payment add-on for FY 2001 to 6.25 percent for discharges occurring on October 1, 2000 and before April 1, 2001, and to 6.75 percent for discharges occurring after April 1, 2001 and before October 1, 2001. The IME adjustment would be 6.5 percent in FY 2002 and 5.5 percent in FY 2003 and subsequent years.
View the Direct Graduate Medical Education (DGME) Payments web page, located in the left navigational area, to see questions related to Medicare GME payments for residents training in non-hospital settings.
Source - http://www.cms.hhs.gov/AcuteInpatientPPS/07_ime.asp
Indirect Medical Education
The Social Security Act provides that prospective payment hospitals that have residents in an approved GME program receive an additional payment for a Medicare discharge to reflect the higher patient care costs of teaching hospitals relative to non-teaching hospitals. This additional payment is known as the IME adjustment and it is based on the IME adjustment factor. The IME adjustment factor is calculated using a hospital’s ratio of residents to beds and a multiplier, which is set by Congress. Thus, the amount of IME payment that a hospital receives is dependent upon the number of residents the hospital trains and the current level of the IME multiplier. Based on the multiplier set in the Medicare Modernization Act, for discharges occurring during FY 2007, the IME multiplier will be set at 1.32.
http://www.cms.hhs.gov/apps/media/press/factsheet.asp?Counter=1835&intNumPerPage=10&checkDate=&checkKey=&srchType=1&numDays=3500&srchOpt=0&srchData=&keywordType=All&chkNewsType=6&intPage=&showAll=&pYear=&year=&desc=false&cboOrder=date
National Provider Identifier (NPI) Alert:
National Provider Identifiers (NPIs) will be required on claims sent on or after October 1, 2007. On March 2, 2007, CMS released a memo regarding the clarification of the provider number nomenclature. Please note that following the implementation of the National Provider Identifier (NPI), the Medicare/Medicaid Provider Number will continue to be issued to certified providers/suppliers and used on all Survey and Certification, and patient assessment transactions. In order to distinguish its role from that of the NPI, the Medicare/Medicaid Provider Number has been renamed the Centers for Medicare & Medicaid Services (CMS) Certification Number (CCN).
The NPI is a Health Insurance Portability and Accountability Act (HIPAA) Administrative Simplification Standard. The NPI is a unique identification number for covered health care providers. Covered health care providers and all health plans and health care clearinghouses will use the NPIs in the administrative and financial transactions adopted under HIPAA. The NPI is a 10-position, intelligence-free numeric identifier (10-digit number). This means that the numbers do not carry other information about healthcare providers, such as the state in which they live or their medical specialty. Beginning May 23, 2007 (May 23, 2008, for small health plans), the NPI must be used in lieu of legacy provider identifiers in the HIPAA standards transactions. Covered entities may invoke contingency plans after May 23, 2007.
Source - http://www.cms.hhs.gov/NationalProvIdentStand/
Source -
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http://www.fdhc.state.fl.us/National_Provider_Identifier_NPI_Alert.shtml
For more information contact:
David J. Lacasse, Managing Director/President
Healthcare Collateral Consulting, LLC
Fairfield County, Connecticut
djlacasse@gmail.com
The NPI is a Health Insurance Portability and Accountability Act (HIPAA) Administrative Simplification Standard. The NPI is a unique identification number for covered health care providers. Covered health care providers and all health plans and health care clearinghouses will use the NPIs in the administrative and financial transactions adopted under HIPAA. The NPI is a 10-position, intelligence-free numeric identifier (10-digit number). This means that the numbers do not carry other information about healthcare providers, such as the state in which they live or their medical specialty. Beginning May 23, 2007 (May 23, 2008, for small health plans), the NPI must be used in lieu of legacy provider identifiers in the HIPAA standards transactions. Covered entities may invoke contingency plans after May 23, 2007.
Source - http://www.cms.hhs.gov/NationalProvIdentStand/
Source -
/National_Provider_Identifier\u003cWBR\>_NPI_Alert.shtml\u003c/a\>\u003c/div\>",1]
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http://www.fdhc.state.fl.us/National_Provider_Identifier_NPI_Alert.shtml
For more information contact:
David J. Lacasse, Managing Director/President
Healthcare Collateral Consulting, LLC
Fairfield County, Connecticut
djlacasse@gmail.com
Why are our services unique?
Healthcare Collateral Consulting, LLC has mission to provide superior, cost effective, value added services to our clients. Why pay a large firm thousands of dollars a day for an onsite engagement, which does not included travel expenses. When in today's hi-tech virtual world, HCC is just a click away from providing you a remote review for almost half the cost. Billing is by the hour and is only charged when there is work to be completed. Unlike the onsite review, when examiners are sitting around waiting for information and still billing you their daily rate. Healthcare Collateral Consulting, LLC also provides onsite services per client's request.
"HCC's services are designed to provide a customized solution from healthcare finance professionals. Something the traditional competing firm can not provide".
Look forward to hearing back from you,
David J. Lacasse Managing Director/President
Healthcare Collateral Consulting, LLC
Fairfield County, Connecticut
djlacasse@gmail.com
Healthcare Collateral Consulting, LLC has mission to provide superior, cost effective, value added services to our clients. Why pay a large firm thousands of dollars a day for an onsite engagement, which does not included travel expenses. When in today's hi-tech virtual world, HCC is just a click away from providing you a remote review for almost half the cost. Billing is by the hour and is only charged when there is work to be completed. Unlike the onsite review, when examiners are sitting around waiting for information and still billing you their daily rate. Healthcare Collateral Consulting, LLC also provides onsite services per client's request.
"HCC's services are designed to provide a customized solution from healthcare finance professionals. Something the traditional competing firm can not provide".
Look forward to hearing back from you,
David J. Lacasse Managing Director/President
Healthcare Collateral Consulting, LLC
Fairfield County, Connecticut
djlacasse@gmail.com
Press Release from ABFJournal.com
New Entrant: Healthcare Collateral Consulting Opens for Business
Tuesday, September 04, 2007 - Healthcare Collateral Consulting, LLC (HCC) announced it has been established as a new outsourcing strategy for healthcare lenders. The firm provides outsourced due diligence services including field examinations, credit, underwriting, risk analysis and account management for healthcare lenders, including banks, asset-based lenders, private equity and institutional investors. HCC's associates have extensive healthcare experience in credit, collateral, underwriting, audit, workout management, operations, and account management. The company's healthcare knowledge provides lenders with additional insight into healthcare trade risks that cannot be provided by most other accounting or audit firms. "Many of the players in healthcare lending are focusing on booking transactions without adequate back-office and due diligence support, which has created a void in the marketplace for the type of due diligence and account management services we offer," said David J. Lacasse, president and managing director at HCC. "HCC's services are designed to provide a customized solution from healthcare finance professionals." Lacasse has more than 11 years of experience in asset-based lending and healthcare finance, most recently managing the loan portfolio for a prior healthcare finance business since 2004. Healthcare Collateral Consulting, LLC has mission to provide superior, cost effective, value added services to our clients. HCC is committed to establishing strong relationships with its clients and providing innovative outsourcing solutions with the highest quality of service. HCC's services are designed to provide a customized solution and include: collateral exams, financial assessments, performance & loan compliance reviews, portfolio/account management, underwriting/due diligence, scheduling engagements & staffing, UCC research, facility survey monitoring, revolving line of credit simulation, and hard-asset verifications.
http://www.abfjournal.com/story.asp?id=20633
Tuesday, September 04, 2007 - Healthcare Collateral Consulting, LLC (HCC) announced it has been established as a new outsourcing strategy for healthcare lenders. The firm provides outsourced due diligence services including field examinations, credit, underwriting, risk analysis and account management for healthcare lenders, including banks, asset-based lenders, private equity and institutional investors. HCC's associates have extensive healthcare experience in credit, collateral, underwriting, audit, workout management, operations, and account management. The company's healthcare knowledge provides lenders with additional insight into healthcare trade risks that cannot be provided by most other accounting or audit firms. "Many of the players in healthcare lending are focusing on booking transactions without adequate back-office and due diligence support, which has created a void in the marketplace for the type of due diligence and account management services we offer," said David J. Lacasse, president and managing director at HCC. "HCC's services are designed to provide a customized solution from healthcare finance professionals." Lacasse has more than 11 years of experience in asset-based lending and healthcare finance, most recently managing the loan portfolio for a prior healthcare finance business since 2004. Healthcare Collateral Consulting, LLC has mission to provide superior, cost effective, value added services to our clients. HCC is committed to establishing strong relationships with its clients and providing innovative outsourcing solutions with the highest quality of service. HCC's services are designed to provide a customized solution and include: collateral exams, financial assessments, performance & loan compliance reviews, portfolio/account management, underwriting/due diligence, scheduling engagements & staffing, UCC research, facility survey monitoring, revolving line of credit simulation, and hard-asset verifications.
Healthcare Collateral Consulting, LLC - “An Innovative Outsourcing Strategy for Healthcare Lenders and Investors”
Healthcare Collateral Consulting, LLC (HCC) provides lenders in Healthcare and Life Sciences with additional insight into healthcare trade risks that cannot be provided by most other consulting or audit firms. Healthcare Collateral Consulting, LLC ("HCC") offers innovative cost-saving services including field examinations, credit, underwriting, risk analysis, account management, and executive recruiting for healthcare lenders, including banks, asset-based lenders, private equity and institutional investors. HCC's associates have extensive healthcare experience in credit, collateral, underwriting, audit, workout management, operations, and account management.
For a typical engagement, the savings you will realize from the traditional competing firm is up to 45% for remote work and up to 25% for work done onsite.
Why are my services unique?
Healthcare Collateral Consulting, LLC has mission to provide superior, cost effective, value added services to our clients. Why pay a large firm thousands of dollars a day for an onsite engagement, which does not included travel expenses. When in today's hi-tech virtual world, HCC is just a click away from providing you a remote review for almost half the cost. Billing is by the hour and is only charged when there is work to be completed. Unlike the onsite review, when examiners are sitting around waiting for information and still billing you their daily rate. Healthcare Collateral Consulting, LLC also provides onsite services per client's request.
"HCC's services are designed to provide a customized solution from healthcare finance professionals. Something the traditional competing firm can not provide".
David J. Lacasse Managing Director/President
Healthcare Collateral Consulting, LLC
Fairfield County, Connecticut
HealthcareCollateralConsulting@gmail.com
For a typical engagement, the savings you will realize from the traditional competing firm is up to 45% for remote work and up to 25% for work done onsite.
Why are my services unique?
Healthcare Collateral Consulting, LLC has mission to provide superior, cost effective, value added services to our clients. Why pay a large firm thousands of dollars a day for an onsite engagement, which does not included travel expenses. When in today's hi-tech virtual world, HCC is just a click away from providing you a remote review for almost half the cost. Billing is by the hour and is only charged when there is work to be completed. Unlike the onsite review, when examiners are sitting around waiting for information and still billing you their daily rate. Healthcare Collateral Consulting, LLC also provides onsite services per client's request.
"HCC's services are designed to provide a customized solution from healthcare finance professionals. Something the traditional competing firm can not provide".
David J. Lacasse Managing Director/President
Healthcare Collateral Consulting, LLC
Fairfield County, Connecticut
HealthcareCollateralConsulting@gmail.com
“A New Outsourcing Strategy for Healthcare Lenders”, Healthcare Collateral Consulting, LLC (HCC) has been formed. The firm provides outsourced due diligence services including field examinations, credit, underwriting, risk analysis and account management for healthcare lenders, including banks, asset-based lenders, private equity and institutional investors. HCC's associates have extensive healthcare experience in credit, collateral, underwriting, audit, workout management, operations, and account management. Our healthcare knowledge provides lenders with additional insight into healthcare trade risks that cannot be provided by most other accounting or audit firms.
“Many of the players in healthcare lending are focusing on booking transactions without adequate back-office and due diligence support, which has created a void in the marketplace for the type of due diligence and account management services we offer,” said David J. Lacasse, Managing Director at HCC. "HCC's services are designed to provide a customized solution from healthcare finance professionals ".
Healthcare Collateral Consulting, LLC has mission to provide superior, cost effective, value added services to our clients. HCC is committed to establishing strong relationships with its clients and providing innovative outsourcing solutions with the highest quality of service.
HCC's services are designed to provide a customized solution and include:
Collateral Exams
Financial Assessments
Performance & Loan Compliance Reviews
Portfolio/Account Management
Underwriting/Due Diligence
Scheduling Engagements & Staffing
UCC Research
Facility Survey Monitoring
Revolving Line of Credit Simulation
Hard-asset Verifications
About HCC’s Management
Managing Director and President - David J. Lacasse has more than 11 years of experience in asset based lending and healthcare finance, most recently managing the loan portfolio for a prior healthcare finance business since 2004. For more information, David can be reached at healthcarecollateralconsulting@gmail.com or (203) 610-2515.
“Many of the players in healthcare lending are focusing on booking transactions without adequate back-office and due diligence support, which has created a void in the marketplace for the type of due diligence and account management services we offer,” said David J. Lacasse, Managing Director at HCC. "HCC's services are designed to provide a customized solution from healthcare finance professionals ".
Healthcare Collateral Consulting, LLC has mission to provide superior, cost effective, value added services to our clients. HCC is committed to establishing strong relationships with its clients and providing innovative outsourcing solutions with the highest quality of service.
HCC's services are designed to provide a customized solution and include:
Collateral Exams
Financial Assessments
Performance & Loan Compliance Reviews
Portfolio/Account Management
Underwriting/Due Diligence
Scheduling Engagements & Staffing
UCC Research
Facility Survey Monitoring
Revolving Line of Credit Simulation
Hard-asset Verifications
About HCC’s Management
Managing Director and President - David J. Lacasse has more than 11 years of experience in asset based lending and healthcare finance, most recently managing the loan portfolio for a prior healthcare finance business since 2004. For more information, David can be reached at healthcarecollateralconsulting@gmail.com or (203) 610-2515.
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