The Hospital Payment Advisory Committee met on August 4 met to hear and discuss several presentation items including updates on: PY1 and 2 of CHIRP, Uncompensated Care, DSH Program, PPR and PPC, and other Medicaid program updates. The agenda can be found here. An archive, when posted, can be found here.
This report is intended to give you an overview and highlight of the discussions on the various topics taken up. It is not a verbatim transcript of the discussions but is based upon what was audible or understandable to the observer and the desire to get details out as quickly as possible with few errors or omissions.
- Chair Strupp – Will not be any action or informational rules brought up today; are a number of presentations requested by members
Update on the Program Year 1 and Program Year 2 Comprehensive Hospital Increased Reimbursement Program (CHIRP)
Jennifer Curro and Victoria Grady, HHSC
- Do not have any paper performance as of now; DPPs are required to submit reports to HHSC which vary based on program
- Annual evaluations will be sent to CMS
- HHSC will publish public information on performance
- In the middle of quality reporting; some providers will be sending corrections
- 410 total reported preliminary results; 167 reported on three measures and 243 reported on three measures plus additional
- Maternal health measures; 108 reported and 104 indicated they have participated in maternal safety bundles as of August 1, 2021
- Only 1 planning to not participate
- Severe maternal morbidity 2.4% average and C-section 25% average rate; below the statewide average
- Written transition procedures to notice about transition for psychiatric and non-
- 64% reported being connected somewhere to an HIE; 24% plan to start participating
- Children’s hospitals most likely to participate and INDs were least likely
- Higher percentage reported having more notices of transition for non-psychiatric
- CHIRP year 1 is going very well; have had growth in program due to additional case-load
- Made an additional IGT call
- Received CMS approval for CHIRP year 2 earlier this week
- Member Nunez – Crossover claims between URIP and CHIRP? How to reprocess those claims?
- Practice has always been reimbursements are based on discharges
- Member Clark – Question concerning lower percentage payment for TIPPS rate? No adjustment for IGT and lowered benefit by 75%
- Question will be addressed in agenda item 7
- Chair Strupp – Get updates from MCOs on what is included in CHRIP add on? Impact of COVID?
- Staff meeting with MCOs regularly; do not see issues raised that a significant amount of claims are being excluded; will not know until we get the encounter data from MCOs
- Chair Strupp – PY2, expect changes in guidance?
- Do not anticipate any significant changes
Status of Medicaid Disproportionate Share Hospital (DSH) Program Year Redistributions and update on the State Payment Cap discussion
Victoria Grady, HHSC
Trey Wood, HHSC
- Had additional payments related to DSH 2020 in an effort to draw all federal funds we can; looking at when redistributions need to be scheduled
- Looking into determining date of discovery
- Will look at DSH payment limits in the fall after HHSC has worked through LAR
- Member Nunez – Payment cap discussions will occur in 2023?
- Do not have a definitive plan yet
- Chair Strupp – Reconvene the DSH workgroup? Or will incorporate previous work?
- Will use previous work, if needed, they will reconvene
Uncompensated Care (UC) update
Victoria Grady, HHSC
- DY11 final payments will be issued shortly; initially planned early settlement dates to be in early October
- Currently examining changing that date to around September 30
- DY12 have confirmed a $4.5b pool size; will consider how funds are allocated among hospital and non-hospital types
- Chair Strupp – DY11 DSH offset calculations repay a portion so it will not affect UC payments?
- For recoupment; based on actual receipts
- Chair Strupp – Format need to go through if making voluntary early DSH payments?
- Member Nunez – HHSC considering moving up February 2023 UC payment to December to take advantage of the enhanced FMAP?
- Will continue to evaluate; have looked at moving things multiple times and is an option
- Chair Strupp – Timeline of when you will have an idea of how DY12 $4.5b allocation will work?
- Aim to make decision early as possible in the fall; likely UC decisions will be made in tandem with DSH
- Not contemplating changing methodology amongst hospital classes, but among dental/ambulance; deciding how to distribute equitably
Jimmy Blanton, HHSC
- SB 2 82(R) and SB 7 83(R) directed HHSC to implement strategies to reduce PPEs; specifically, readmissions and complications
- Provides background on the HQBP program; is competitive and risk adjustment accounts for differences in cases mix/severity
- PPE rate is compared to their expected rate
- Penalties increase when actual-to-expected ratios are 1.10 to 1.24 or 1.25 and greater
- Program was able to have somewhat stability due to COVID because it is based on relative performance
- Program changes: SFY20202 repots were changes to use event based on unweighted rates for PPRs and SFY2021 reports excluded neonatal jaundice admissions for PPR consideration
- Will be reflected in 3M software versions
- Over the last three reporting years, drop in those with penalties for PPRs and increase in PPCs
- Will meet to develop and discuss information for HHSC and 3M regarding clinical logic for PPRs and PPCs, will provide regular updates on the program, will meet 2/3 times a year
- Chair Strupp – 3M software used includes clinical logic to define complications related to COVID? How was that defined?
- Is a code, believe they are using it with all the diagnosis going into the model
- Are new codes including post-COVID codes; is consideration on how to incorporate that information; will follow up
- Member Beman – Threshold for sample sizes for smaller hospitals, at what point are they subject to penalty? Would like to see how that works
- Volume requirements 40 admissions at risk for PPR/PPC; for PPR lose about 100 hospitals due to volume requirements, lose significantly more for PPCs
- Member Hand – Strange that PPCs went up so much; Memorial Herman’s were either maxxed out or close to it
- Have looked at underlying data; have been changes in utilization patterns and case mixes at certain hospitals
- Member Hand – Would like to talk to you offline about Herman’s data and why PPCs were so high
- Chair Strupp – Large population that got carved out because of the COVID criteria?
- Not a “huge” number, but is “meaningful” and will break out that data by hospital
- Member Kemmel – Request reporting by each institution data for the COVID cases that were excluded
- Can get some aggregate analysis to you; notes that reports come to HHSC every six months
Discuss other Medicaid payment and supplemental payment programs (e.g., HARP, Private hospital GME, etc.)
Victoria Grady, HHSC
- TIPPS PY1 rates were designed for component 1 65%, component 2 25% and component 3 10%
- As a result of forecasting to maintain component 3, percentage rate was decreased to somewhere in the low 50%
- All component 3 funds will be expended
- FY22 final approved pre-prints and FY23 approved pre-prints are available
- Member Clark – Concern is not about change of percentage; corresponding adjustment for IGT that some entities were required to put up
- Capitated rates are supported by IGT; overviews the reconciliation process
- Member Clark – Expecting some type of adjustment post-completion?
- Member Stupp – Updates on any other programs?
- Private Heart and GME are in pending status;
- Public Heart received additional follow-up questions from CMS about the non-federal share; working on drafting responses and will contact local entities to help with providing response
- Member Clark – HARP could be retroactively paid if approved in FY21 and FY22?
- Member Clark – Component 3 rate for TIPPS has been released?
- Yes; on HHSC website
Rural Hospital Advisory Committee (RHAC) update
Rebecca McCain, Chair RHAC
- Reviewed presentations concerning the community CHART program, rural strategic plan, DPPS and DSRIP wind-down and final payments for that program
- No public comment
Proposed next meeting: November 3, 2022