fah hospital policy blog

Perspectives on health policy affecting America’s hospitals and the patients we serve.

FAH, Member Company Participate in Red Tape Relief Roundtable

April 13, 2018 | FAH Policy Blog Team

Category: FAH News, Health Care Delivery, Medicare

The House Ways and Means Health Subcommittee held a Red Tape Relief Initiative roundtable earlier this week focused reducing regulatory burdens on hospitals.

Committee leaders framed this as a unique chance for Members to hear from industry professionals about how Congress can improve Medicare so that it works more effectively for both patients and medical providers.

FAH President and CEO Chip Kahn was there alongside Dr. Christopher Ott, HCA Physician Services Group’s chief medical officer.

Dr. Ott addressed the bipartisan group of Committee Members highlighting two main Medicare issues – the redesign of the programs hospital value-based programs and MedPAC’s recent recommendations regarding standalone emergency department (ED) services.

In regard to hospital value-base programs, Dr. Ott pointed out that FAH general supports efforts to reduce the number of measures, eliminate burden and focus on measures that are meaningful to patients and providers. However, he pointed out that many quality measures are behind the times.

When discussing MedPAC’s recent stand-alone ED policy recommendations, Dr. Ott supported the flexibility given to rural facilities, but outlined serious concerns with the possible rules for urban EDs. He told legislators that the proposed changes could lead to diminished access points and treatment options for patients.

Many of the points highlighted by Dr. Ott are echoed in a letter FAH sent to Ways and Means Committee leaders last year on the topic of red tape relief. You can read that complete letter here.

The roundtable is part of the three part process outlined by the committee that is supposed to ultimately culminate with Congressional action.

FAH Affiliated Hospital Named to “Top Places to Work in Healthcare” List

April 13, 2018 | FAH Policy Blog Team

Category: FAH News, Health Care Delivery

Becker’s Hospital Review recently released its 2018 list recognizing the top places to work in healthcare.  Ardent Health Services' Bailey Medical Center  in Owasso, Oklahoma was included in the list which “highlights hospitals, health systems and healthcare companies that promote diversity within the workforce, employee engagement and professional growth.” As a 73-bed acute care hospital, Bailey Medical Center was recognized with Ardent Healthcare's Ardent Cup as an outstanding facility four times from 2012 to 2017, and it earned a five-star CMS rating in 2017. Some of the hospital's unique employee benefits include up to $2,500 in coverage of weight loss surgery, an annual free health screening that helps participants receive discounts on their premiums, and a health advocate program to help employees and their families navigate medical claims issues, negotiate fees for noncovered services and find elder care services.  You can view the entire list here.

FAH Responds to Senate Request about Health Care Price and Information Transparency

March 23, 2018 | FAH Policy Blog Team

Category: Transparency

Today, FAH submitted a letter in response to a request from Senators Cassidy, Bennet, Grassley, Carper, Young, and McCaskill. The Senators recently launched a bipartisan effort to increase health care price and information transparency to empower patients, improve quality, and lower costs. The letter notes FAH members’ support of efforts to promote transparency and provide information to enhance consumer choice and offered principles for Congress to consider regarding the release of such information. This information is not only important for consumers prior to receiving medical services, but also is important when they are selecting their health insurance coverage; and it should be clear, accessible, and actionable and focus on what patients want and need to know – their out-of-pocket costs and their provider networks. It should also be coupled with quality information so consumers can make informed decisions based on both the cost and quality of care. The letter makes numerous recommendations for improving quality measurement and public reporting, including with regard to the Star Ratings Program and the use of electronic health records (EHRs).

For insured patients, insurers are in the best position to provide pricing information to their enrollees as they have access to information about the entire episode of care. Additionally, FAH recommends adoption of the “surprise billing” section of the National Association of Insurance Commissioners’ (NAIC) Model Act. The NAIC model protects insured patients from surprise bills when they receive services in an in-network hospital but some of those services are delivered by an out-of-network physician. For uninsured consumers, health care providers and state databases are sources of pricing information, recognizing that there are limitations to this information due to the involvement of multiple providers in an episode of care and the uniqueness of each patient. The letter also cautions against the release of negotiated rates between insurers and providers, as such information is not useful or actionable for patients and could have anticompetitive effects.  

Lastly, the letter notes the extraordinary number of regulatory requirements with which hospitals must comply and recommends actions Congress and the Administration could take to lessen these requirements and improve health outcomes and efficiencies.

You can find a complete copy of the letter here.

Axios Vitals’ Report on Medicare Margins Misses Key Data Point from MedPAC Report

March 22, 2018 | FAH Policy Blog Team

Category: FAH News, Medicare

In a good report full of facts and figures, it is tempting to pick out one or two and claim they prove your point. Unfortunately, this morning’s (March 22nd) Axios Vitals selectively used data from MedPAC’s March Report to Congress to suggest that hospitals lose money on Medicare because they are inefficient. The blurb entitled “Let’s talk about hospitals’ Medicare margins” misses what is arguably MedPAC’s most compelling data point:  331 “relatively efficient” hospitals experienced a negative Medicare margin in 2016.  It’s on page 86 – just two pages past the points highlighted by Axios.

It’s always a good idea to read the whole story. 

Here are some additional facts to consider from the March report. Medicare hospital margins have been negative since 2003.  More recently, since 2013, margins will have fallen a stunning 116 percent by 2018 based on MedPAC’s projection that Medicare hospital margins will fall to an historic low of negative 11 percent.  This should come as no surprise because the average net increase in Medicare’s hospital payment rate over that time – 1.1 percent -- is less than half the average rate of increase – 2.6 percent -- in the market basket of goods and services used to determine the annual hospital inflation update. 

That wide gulf is due largely to cuts imposed on hospitals through legislation and regulation.  And frankly, it is not sustainable, especially as public payments – especially Medicare and Medicaid, which typically pays less than Medicare – are nearly half of total hospital operating revenue.

The pressure to lower costs is constant, and hospitals are doing their part keeping the increase “roughly equivalent to underlying price inflation,” notwithstanding what MedPAC notes are increasing drug and device costs, which together accounted for 26 percent of the 2016 growth in costs per Medicare discharge. 

Yet the actual fixed Medicare (and Medicaid) payment rate is not keeping up with inflation.  And that, along with the $38.3 billion in uncompensated care costs that hospitals provided in 2016, goes a long way towards explaining why hospitals must seek higher payments from private insurers, through arms-length marketplace negotiation, to meet the community mission hospitals commit to, and which our seniors expect and deserve. 

This commonly referred to cost-shift is not some mere “theory,” but a stubborn fact, something policymakers should keep in mind as they contemplate cutting hospital payments even further.

Coalition Asks Congress to Act Now on Vital Health Care Issues

March 19, 2018 | FAH Policy Blog Team

Category: Insurance, Legislation

A coalition of prominent health care and business associations, including the Federation of American Hospitals, sent a letter today to Congressional leaders asking that they take action to lower health care premiums.

The group sent a similar message to Capitol Hill earlier this month, but the message is more urgent now because as they wrote – “Time is running out.”

Congress is working on an omnibus appropriations bill that it must act on by Friday, March 23rd. The coalition is urging leaders to make sure the legislation includes elements that that will reduce premiums, improve affordability, and improve the individual market for 2019 and beyond, such as:

  • Establishing a premium reduction/reinsurance program to help cover the costs of people with significant health care needs.
  • Providing multi-year funding for cost-sharing reduction (CSR) benefits.

The letter highlights recent analysis that shows taking these actions could lower premiums by up to 21% in 2019 and increase enrollment and expand coverage to over 1.5 million Americans.

You can find a complete copy of the letter here.

It was signed by FAH, AHA, America’s Health Insurance Plans, American Academy of Family Physicians, American Benefits Council, American Medical Association, Blue Cross Blue Shield Association, and U.S. Chamber of Commerce.

The letter was sent to Senate Majority Leader Mitch McConnell (R-KY), Senate Minority Leader Chuck Schumer (D-NY), Speaker Paul Ryan (R-WI) and House Minority Leader Nancy Pelosi (D-CA).

FAH Highlights to Congress Effective Ways to Combat Opioid Epidemic

March 16, 2018 | FAH Policy Blog Team

Category: Legislation, Pharmaceuticals

FAH sent a letter today to leaders on the House Ways and Means Committee highlighting policy changes that would help in battling the opioid epidemic.

Reps. Kevin Brady (R-TX), Richard Neal (D-MA), Peter Roskam (R-IL) and Sander Levin (D-MI) recently asked stakeholders to share their thoughts on ways to fight the crisis.

"We appreciate the opportunity to offer our insight on the role hospitals are playing in meeting the challenges of the crisis and on what additional tools and policies are likely to be helpful in both preventing and treating opioid addiction and the acute and long-term medical needs that stem from their misuse," FAH President and CEO Chip Kahn wrote.

The letter begins by pointing out that hospitals are on the frontlines of the crisis - partnering with community groups to address the crisis and also looking for alternative approaches to treating pain.

FAH also draws attention to policy changes that could address the issue, including:

Health Insurance Coverage Fundamental to Addressing Crisis  

Data shows that sustaining and growing the gains in health insurance coverage is essential to connecting those in need with critical services. It is important that the Essential Health Benefits requirements remain in place and cover benefits for addiction treatment. FAH also recommended removing Medicaid restrictions on Institutions for Mental Disease (IMD), which would increase the availability of appropriate care.

Expanded Data Sharing Among Prescription Drug Monitoring Programs (PDMPs) Needed

FAH outlined its reasons for supporting expanding data sharing among PDMPs, including with CMS and other health care entities.

"Consistent, real-time, standardized PDMP's, accessible to health systems in addition to providers or pharmacists, can lead to increased monitoring and reporting that effects changes in opioid-related outcomes such as opioid prescribing behavior, opioid diversion and supply, opioid misuse, and opioid-related morbidity and mortality."

The letter also lays out solutions to the potential barriers to expanded sharing among PDMPs.

Medication Assisted Treatment (MAT) Important

"Broader integration of MAT in the primary care setting in conjunction with increases in the number of SUD treatment facilities expands access to treatment and reduces stigma.  Recent legislation has vastly increased coverage of SUD treatment in primary care, raising the importance of identifying best practices."

Telehealth Offers Pathway to Services

"By breaking down barriers to treatment (e.g., distance), telehealth can assist in connecting patients to qualified providers.  Given the breadth of the crisis, it is important that we use all available pathways to treatment."

Allow Treating Providers to Access Their Patients' Substance Use Disorder Records

Legislators should consider steps needed to "align the 42 CFR Part 2 requirements with the Health Insurance Portability and Accountability Act (HIPAA) requirements to allow the use and disclosure of SUD records from a federally assisted program for "treatment, payment, and health care operations" without prior written authorization... Using the HIPAA requirements would improve patient care by enabling providers with a patient relationship to access their patient's entire medical record."

The letter concludes by expressing FAH's desire to work with Members of Congress on ways to address the opioid epidemic.

You can find the complete letter here.

LifePoint Health Receives Prestigious John M. Eisenberg Award for Innovation in Patient Safety

March 14, 2018 | FAH Policy Blog Team

Category: FAH News, Quality

LifePoint Health received the John M. Eisenberg Award for Innovation in Patient Safety at the Local Level on Tuesday at the National Quality Forum (NQF) Annual Conference in Washington, DC.

The company received the honor for its National Quality Program, which was created in partnership with Duke University Health System. The program has led to significant enhancements across the LifePoint network, including a more than 60 percent improvement in aggregate patient safety.

LifePoint Health, a member of the Federation of American Hospitals (FAH), is the first investor-owned health system to earn an Eisenberg Award.

“Receiving the John M. Eisenberg Award is an honor and one of the proudest moments of our company,” said Bill Carpenter, chairman and chief executive officer of LifePoint Health. “Since our company was founded, we committed ourselves to always putting quality and patient safety first. We, along with our partners at Duke, created the LifePoint National Quality Program as a way to institutionalize and ensure this undisputed top priority and way of life across our system. This recognition is a testament to the hard work and commitment of our dedicated employees, physicians and leaders across the nation.”

“I want to applaud Bill Carpenter and the team at LifePoint Health for earning this honor and being leaders in area of patient safety. The National Quality Program they created is proof of what can happen when a company brings its resources to bear to focus on what matters most – quality, patient-centered care,” said Chip Kahn, President and CEO of the Federation of American Hospitals.

The LifePoint National Quality Program is a data-driven program implemented in LifePoint’s facilities across the nation. Rooted in patient-centeredness, the program is focused on leadership that empowers people, proven systems of performance improvement, and a culture of safety. This initiative has helped create a highly reliable culture of safety and drive enhancements across the LifePoint system, including a 62 percent improvement in aggregate patient safety compared to the company’s 2010 baseline and 12 months of zero central-line infections at 73 percent of its hospitals. Additionally, from 2010 to 2017, hospital-acquired infections at LifePoint hospitals’ decreased by 78 percent for urinary tract infections, 58 percent for sepsis infection, and 73 percent for pneumonia.

“The LifePoint National Quality Program has established at the hospital and system level an ongoing, measurable approach to driving sustainable improvements in patient safety, quality and patient experience,” said Rusty Holman, MD, chief medical officer for LifePoint Health. “Because of the diverse hospitals within the LifePoint system, this program offers many lessons for how healthcare facilities of all types and sizes serving a variety of patient populations can operationalize quality, create a national learning laboratory, and engineer a sustainable culture of safety.” 

The Eisenberg Awards, launched in 2002, honor the late John M. Eisenberg, MD, MBA, former administrator of the Agency for Healthcare Research and Quality (AHRQ). An impassioned advocate for healthcare quality improvement, Eisenberg was a member of NQF’s founding board of directors, chaired the federal government’s Quality Interagency Coordination Task Force and personally led AHRQ’s grant program to support patient safety research. Each year, Eisenberg Awards honor those making strides in innovating patient safety and quality at the individual level, local level and national level.

For more information, including reaction to LifePoint’s honor from other leaders in the medical community, please click here.

Coalition Asks Congress to Pass Market Stabilization Legislation

March 12, 2018 | FAH Policy Blog Team

Category: Insurance, Legislation

FAH joined a coalition in asking Congress to pass bipartisan market stabilization legislation. The group is made up of organizations that either provide health care or coverage to hundreds of millions of Americans

“We are writing to urge you to move forward with bipartisan legislation to reduce premiums, improve affordability, and improve the individual health insurance market. We ask that you include this legislation in the omnibus appropriations bill that Congress needs to act upon by March 23.”

The letter points out that Americans would most benefit from two critical elements:

• Establishing a premium reduction/reinsurance program to help cover the costs of people with significant health care needs.

• Providing multi-year funding for cost-sharing reduction (CSR) benefits.

The letter, which can be found here, was signed by FAH, AHA, America’s Health Insurance Plans, American Academy of Family Physicians, American Benefits Council, American Medical Association, Blue Cross Blue Shield Association, and U.S. Chamber of Commerce.

FAH Comments on CMS 2019 MA Draft Call Letter

March 12, 2018 | FAH Policy Blog Team

Category: Media, Medicare

FAH recently submitted a comment letter to CMS on the 2019 Medicare Advantage (MA) and Part D Advance Notice and Draft Call Letter. FAH urged CMS to use caution when allowing MA organizations (MAOs) greater flexibility regarding cost-sharing and benefit design (e.g., tiered cost-sharing, increased cost-sharing to manage utilization, and new interpretation of the uniformity requirements), as these changes could limit transparency and increase beneficiary costs and confusion.

 

The letter also expressed continued concern that MAOs inappropriately reclassify inpatient hospital stays as outpatient "observation" stays, as well as disappointment that CMS has not addressed network adequacy deficiencies, particularly with regard to sub-networks and post-acute care. Additionally, the letter urges CMS to: continue enforcement actions against MAOs for inaccurate provider directories; require MAOs to honor prior authorizations at the time of payment; require MA plans to inform providers about an enrollee's participation in the Qualified Medicare Beneficiary (QMB) Program; and undertake updates to the Star Ratings Program.


You can read the letter here.

Hospital Groups Call on Anthem to Rescind ED and Imaging Coverage Changes

March 09, 2018 | FAH Policy Blog Team

Category: Health Care Delivery, Insurance, Quality

FAH, together with other hospital groups, wrote to Anthem to express serious concerns about the insurer's coverage policies for outpatient imaging and emergency care services.

The letter highlights that Anthem's emergency services policy lacks transparency for patients and providers, essentially requires patients to know their diagnosis before seeking care, and could lead to patients delaying life-saving medical treatment. The outpatient imaging policy also lacks transparency, is confusing to patients and providers, and will result in some patients failing to receive diagnostic testing.

FAH continues to encourage Anthem to retract these polices and work with our organizations to ensure Anthem members have access to high-quality, timely care.

You can find the complete letter here.

FAH, AHA Urge Congress to Oppose Physician-Owned Hospital Bill

March 09, 2018 | FAH Policy Blog Team

Category: Health Care Delivery, Legislation

FAH and AHA sent a letter to members of Congress Monday urging them to oppose H.R. 1156/S. 1133, the ‘‘Patient Access to Higher Quality Health Care Act of 2017,” legislation that would repeal current law limiting self-referral to physician-owned hospitals.

The letter uses new data to highlight the harmful impact self-referral has on the hospital industry.

“The empirical record is clear that these conflict-of-interest arrangements of hospital ownership and self-referral by physicians result in cherry-picking of the healthiest and wealthiest patients, excessive utilization of care, and patient safety concerns,” wrote FAH and AHA.

You can read the entire letter here.

FAH Presents Annual Corris Boyd Leadership Award to Ed Hardin

March 07, 2018 | FAH Policy Blog Team

Category: FAH News

This week the Federation of American Hospitals presented Edmond Hardin, Senior Vice President for Supply Chain Management at Beaumont Health, with the 12th annual Corris Boyd Leadership Award.  Hardin was honored March 5th during the FAH Annual Meeting in Washington, DC.

Presenter Jerry McKinney, Chairman of the FAH Exposition Advisory Committee, was joined on stage by a special guest – Corris Boyd’s wife, Vanessa.

“This award is given annually in memory of our late friend. Corris Boyd was an exceptional person and an outstanding leader in workplace diversity. This award is our way of keeping his legacy of excellence going and we are so happy to have Vanessa here to take part,” McKinney said.

It has become a tradition to surprise the winner and this year was no different. Mr. Hardin was unaware of the honor until his name was called.

Nominators used words like supportive, leader, mentor and someone committed to excellence to describe Mr. Hardin. As one wrote, “The culture and leadership style he exhibits filters down to his direct supply chain leaders creating a more cohesive Supply Chain business unit.”

But if you talk to those who know Mr. Hardin best they will highlight not only his professional accolades, but his personal attributes. Nominators cited his passion, his desire to see those around him succeed and his dedication to diversity as reasons he deserved to be honored.

He has worked in the health care provider industry for nearly 20 years – specializing in supply chain performance improvement and management solutions. Before taking on his current position at Beaumont Health, Mr. Hardin worked for other influential companies, including CHRISTUS Health, Resource Optimization & Innovation of Mercy Health System, Alvarez & Marsal, Ernst & Young, and Deloitte Consulting.

Mr. Hardin is an amazing example of what our industry strives to achieve.

The Corris Boyd Leadership Award honors an individual or company that has made an outstanding contribution in fostering leadership in the health care industry.   The FAH established the Corris Boyd Leadership in 2007 to honor the late Corris Boyd, who spent his career working with hospital management companies and group purchasing organizations.  Corris Boyd committed his life to diversity and excellence in health care. He believed that leadership development is crucial to success and was devoted to the success of minority- and women-owned business enterprises.

FAH is honored to present Ed Hardin as the 2018 Corris Boyd Award winner, and extends its thanks for his outstanding work which embodies the ideals the award represents.

 

FAH Leader Comments on Secretary Azar’s Remarks at FAH Annual Meeting

March 06, 2018 | Chip Kahn

Category: FAH News, Media

“We were pleased that Sec. Azar chose our meeting for one of his first major public addresses. It was an opportunity for all of us to hear his agenda first hand.  We are excited for the opportunity to partner with HHS as the Secretary’s agenda develops, which is so important to all Americans.”

You can watch Sec. Azar’s Speech here.

FAH Comments on Association Health Plans

March 06, 2018 | FAH Policy Blog Team

Category: Insurance

Today, the Federation of American Hospitals (FAH) submitted comments to the Department of Labor (DOL) on the Proposed Rule amending current regulation making it easier for small employers and sole proprietors to band together as part of an association with the expressed purpose of offering health insurance to the employees of the association's employer members (Association Health Plans).  In most cases, the health insurance offered by the association would be treated as an employer-sponsored plan regulated as large group coverage rather than individual or small group coverage.  

The Proposed Rule would make it easier for AHPs to form by:

  • Allowing AHPs to form with the expressed purpose of offering health insurance;
  • Allowing AHPs to organize as employers in the same trade, industry, line of business, or profession, or (allowing AHPs to organize across state lines under this principle);
  • Allowing AHPs to organize as employers that have a principal place of business within a region that does not exceed the boundaries of the same State or the same metropolitan area (AHPs could also organize in smaller geographic areas);
  • Allowing sole proprietors or working-owners of small businesses to join an AHP regardless of whether the business has employees other than the sole proprietor or working-owner.

In its comments, the FAH noted that the Proposed Rule, if implemented, would likely undermine the stability and availability of meaningful coverage, with coverage likely to lack important consumer protections including minimum benefit standards, annual and lifetime limits on cost sharing, rules that limit underwriting of premiums, single risk pool requirements, and participation in risk adjustment.  In addition to the lack of these important minimum benefits, given the history of fraud and abuse in the association health plan market, the FAH raised concern with the lack of oversight the DOL is proposing to undertake should these plans be authorized.  Given these concerns, the Federation requested that DOL not finalize the proposal.

You can find the FAH’s full comments here.  

FAH Announces Speakers for 2018 Annual Public Policy Conference & Business Exposition

February 28, 2018 | FAH Policy Blog Team

Category: FAH News, Media

WHAT:              The annual public policy conference of the Federation of American Hospitals (FAH)

WHEN:              Monday, March 5, 2018

WHERE:            Marriott Wardman Park Hotel, Main Ballroom, 2660 Woodley Road, N.W., Washington, DC

 

FEATURED SPEAKERS:   

  • Health And Human Services Secretary Alex Azar
  • Rep. Peter Roskam (R-IL), Member, House Ways and Means Committee; Chairman, Subcommittee on Health
  • Sen. Todd Young (R-IN), Member, Committee on Health, Education, Labor & Pensions and  Committee on Commerce, Science and Transportation
  • Sen. Tim Kaine (D-VA), Member, Committee on Health, Education, Labor & Pensions and Budget Committee
  • Rep. Kyrsten Sinema (D-AZ), Member, Committee on Financial Services
  • Andrew Bremberg, Assistant to the President and Director, Domestic Policy Council

 

PLENARY SCHEDULES:  

FAH Plenary Session #1 (Opening Session)
Monday, March 5, 2017
11am – Noon

Speakers:

  • Wayne Smith, Chairman of the Board and CEO, Community Health Systems (FAH 2018 Chairman)
  • Health And Human Services Secretary Alex Azar         

FAH Plenary Session #2
1:30pm – 3:45 pm

Speakers:

  • Chairman Peter Roskam (R-IL)
  • Sen. Todd Young (R-IN)
  • Sen. Tim Kaine (D-VA)
  • Rep. Kyrsten Sinema (D-AZ)
  • Andrew Bremberg

 

MPORTANT NOTE: These are the only sessions open to the media. RSVP to Sean Brown (sbrown@fah.org) for credentials.

ABOUT THE CONFERENCE:  The FAH’s Annual Public Policy Conference provides an overview, updates and insights about topical and salient health policy issues of interest to FAH members, hospital leaders, private investor-owned hospitals, suppliers, buyers, sponsors and stakeholders. 

The FAH is the national representative of more than 1,000 investor-owned or managed hospitals and health systems. Our members include general community and teaching hospitals in urban and rural areas as well as rehabilitation, long-term acute care, cancer, and psychiatric hospitals.

MEDIA REGISTRATION:  Members of the media are welcome to attend the plenary sessions of the conference.  We request attending media to register in advance by e-mail (sbrown@fah.org).  

FAH Urges OIS to Develop a New Safe Harbor for APM Incentive Payments

February 27, 2018 | FAH Policy Blog Team

Category: Medicare

Today, the FAH submitted comments to the Office of Inspector General (OIG) of the Department of Health and Human Services in response to the OIG’s annual solicitation of new safe harbors under the Medicare anti-kickback statute.  The FAH urged the OIG to create a new safe harbor for incentive payments between hospitals and other providers when operating within the confines of a qualified alternative payment model (APM), as designated by CMS.

The FAH noted that APMs often emphasize bundled payments and/or value-based payments, with a focus on alignment strategies among hospitals, physicians, and other providers to achieve higher quality and lower total expenditures for Medicare beneficiaries.  Yet, APMs are materially hindered by the existing Medicare anti-kickback statute, which is designed to require strict financial separation between providers who are in a position to refer to one another.  The FAH therefore urged the OIG to develop a new safe harbor for APM incentive payments that would provide hospitals, physicians, and other providers the confidence necessary to move forward with meaningful economic and clinical alignment strategies that further quality, reduce waste, and improve patient outcomes. 

The complete letter can be found here.

FAH Comments on Medicare’s Extreme & Uncontrollable Circumstances Policies

February 20, 2018 | FAH Policy Blog Team

Category: Health Care Delivery, Medicare

FAH sent a letter today to CMS Administrator Seema Verma outlining ways that the Medicare Shared Savings Program’s Extreme and Uncontrollable Circumstances Policies interim final rule could be improved.

The letter expressed appreciation for CMS’ recognition of the need for such a policy and relief it provides to Accountable Care Organizations (ACOs) affected by this year’s disasters, including the devastating hurricanes.

However, FAH points out that there is room for improvement:

“We believe the policy could be improved if CMS would incorporate a process for further mitigating shared losses for ACOs participating in a performance-based risk track beyond the mitigation proposed in the interim final rule. Specifically, we believe that losses should be waived, or a modifier used to adjust, for ACOs suffering losses beyond those recognized in the proposed methodology.”

You can read the letter here.

FAH Submits Comments on ONC’s Draft Trusted Exchange Framework

February 20, 2018 | FAH Policy Blog Team

Category: HIT

Federation of American Hospitals recently submitted comments to the Office of the National Coordinator for Health Information Technology (ONC) regarding the Draft Trusted Exchange Framework and Common Agreement (Draft TEFCA). FAH expressed support for ONC's efforts to advance interoperability, while providing suggestions for improvements and requesting a number of clarifications to the TEFCA. Some key comments include:

Scope of the Draft TEFCA

  • The scope of the Draft TEFCA, which focuses on information exchange between health information networks (HINs), is too narrow. FAH recommended that ONC look beyond the current parameters of the Draft TEFCA to align with private-sector-led efforts to advance comprehensive interoperability, including plug-and-play interoperability among devices and systems.

Draft TEFCA Timeline

  • The Draft TEFCA raises a number of important questions that should be answered before being finalized. FAH recommended that ONC release a second version of the Draft TEFCA on which stakeholders would again have the opportunity to comment.

Recognized Coordinating Entity (RCE)

  • The RCE will be the linchpin for the success or failure of implementation of the TEFCA. FAH recommended that the RCE should be a sector-neutral (not an HIT developer or developer-affiliated group) entity that is able to represent the end-users of health information - primarily providers and patients.

Voluntary Participation

  • Participation in the Draft TEFCA is voluntary, which raises questions about how the RCE will enforce compliance with the TEFCA among Qualified HINs. FAH also urged ONC to ensure that hospitals and other health providers cannot be deemed "information blockers" if they decide not to participate under the TEFCA.

TEFCA-Associated Fees

  • The Draft TEFCA allows for Qualified HINs to charge fees for exchanging information among other Qualified HINs and participating hospitals and providers. FAH expressed support for the requirement that Qualified HINs make their fees public and encouraged ONC to require that fees and any fee increases be reasonable and consistent across Qualified HINs.

Patient Access to Data / HIPAA Protections

  • The information sharing and privacy requirements in the Draft TEFCA differ from those with which covered entities must comply under HIPAA, which FAH noted could lead to confusion and increased burden. FAH also strongly recommended that providing a patient with access to information that is not directly maintained by a health care provider should be the responsibility of the Qualified HIN.

You can read the entire comment letter here.

FAH Leader Comments on Release of Administration’s Budget

February 12, 2018 | Chip Kahn

Category: FAH News, Financing, Media

According to MedPAC, hospitals are already experiencing the lowest Medicare margins in history, while the CBO says nearly half of all hospitals will be facing negative margins by 2025.

The White House’s FY19 budget proposal would more than double the $160+ billion in cuts imposed on hospitals since 2010.

Among the flawed proposals are massive reductions in Medicare bad debt payments and cutbacks in funding for hospital care for millions of uninsured Americans, plus those in post-acute facilities. It also dramatically reduces resources for Medicaid and the training of needed new doctors.

Enough is enough. These unsustainable cuts would directly impact hospitals’ ability to serve patients. 

FAH Comments on FCC Rural Health Care Program

February 02, 2018 | FAH Policy Blog Team

Category: HIT, Rural

FAH recently commented on the FCC’s proposed changes for the Rural Health Care (RHC) Program, which provides funding to health care providers for broadband and telecommunications services. FAH urges the FCC to permit all qualified hospitals to participate in the RHC Program, regardless of ownership status. The letter emphasizes that many rural communities are served only by an investor-owned hospital and that segregating the RHC Program based on ownership status unfairly punishes the individuals and communities served by those facilities.  

You can read the complete letter here.

FAH Welcomes Jonathan Jagoda, New Vice President of Legislation

February 01, 2018 | Chip Kahn

Category: FAH News

The Federation of American Hospitals is pleased to announce the addition of Jonathan Jagoda to our team. Jonathan will be joining FAH as Vice President, Legislation on February 26th.

I am excited to have Jonathan join our advocacy team. He has been working in the health care policy world for more than a decade and his knowledge of health care issues and the legislative process will add tremendous value to our membership. Jonathan has spent the past several years as the Director of Federal Government Relations with the Federation of State Medical Boards (FSMB). He joined the organization shortly after the opening of its DC office and has since helped establish the FSMB as the leading voice for state medical boards with the U.S. Congress, Executive Branch, and key health care stakeholders.

Prior to that he served as an advisor and legislative aide for political campaigns and corporate organizations, including several other major health care trade associations.

Jonathan graduated with a Master of Public Policy degree from the University of Southern California and earned a BA in Political Science from University of Illinois.

FAH Suggests Improvements to Extreme and Uncontrollable Circumstances Policy

January 30, 2018 | FAH Policy Blog Team

Category: Medicare, Rehabilitation Care

In a letter sent today to CMS Administrator Seem Verma, FAH expressed appreciation for the new Extreme and Uncontrollable Circumstances policy for the Comprehensive Care for Joint Replacement (CJR) Model, which provides relief to the hospitals affected by this year’s disasters.

However, FAH explained how the new rule could be improved if CMS treated fracture and non-fracture episodes the same. The letter states:

“Specifically, we believe episode payments should be capped for non-fracture episodes with an anchor hospitalization that is on or within 30 days before or after the date that the emergency period begins. Such a change is warranted based on the actual experience of our hospitals in the impacted areas..”

FAH also suggested that CMS consider applying a similar policy to the voluntary Bundled Payments for Care Improvement (BPCI) model.

You can find the letter here.

FAH Comments on Choice and Competition in the Health Care Marketplace

January 25, 2018 | FAH Policy Blog Team

Category: Medicaid, Medicare

Today, the Federation of American Hospitals responded to a Department of Health and Human Services Request for Information (RFI) on how to promote choice and competition in the health care marketplace.  The RFI was issued in response to the President’s Executive Order issued in October 2017, requiring the Secretary of HHS to provide a report to the President detailing the extent to which current law, regulations and policies fail to promote choice and competition. 

The FAH thanked the Department for taking an expansive look at all the factors that both encourage and discourage choice and competition in the health care market, noting that state and federal laws, regulations, guidance, requirements and policies are often at the core of what limits the full potential of a competitive marketplace.  In addition to current regulatory and policy barriers outlined in the letter, the FAH noted that in order to increase choice and competition, policymakers must address persistent Medicare and Medicaid payment shortfalls. 

The FAH’s full comments can be viewed here.

Hospital Groups Urge Congress to Include Vital Programs in Spending Bill

January 18, 2018 | FAH Policy Blog Team

Category: Medicaid, Medicare

Hospital groups sent a letter to Members of the House and Senate Wednesday urging that they include in the short term funding bill “a two year delay of Medicaid disproportionate share hospital (DSH) cuts, as well as straight 5-year extensions of the Medicare-dependent hospital (MDH) and enhanced low-volume adjustment (LVA) programs.”

The groups explained to legislators the importance of each of the programs and highlighted their effects on our nation’s most vulnerable patients. 

The letter was signed by FAH, America’s Essential Hospitals, the AHA, Association of American Medical Colleges, Catholic Health Association of the United States, Premier Health Alliance and Vizient, Inc.

 You can find a copy of the letter here

FAH Submits Comments on Proposed Changes to MA Program

January 16, 2018 | FAH Policy Blog Team

Category: Medicare

Today, the FAH submitted a comment letter to the Centers for Medicare & Medicaid Services (CMS) on that Agency’s proposed changes to the Medicare Advantage program.

FAH offered strong support for CMS’s proposal to eliminate the mandatory use of CMS-developed compliance training, which will improve employee training while reducing confusion and unnecessary burden.

FAH also expressed concern regarding some proposed policies that could shift burden and costs onto beneficiaries and health care providers, such as increased flexibility for Medicare Advantage Organizations (MAOs) to vary benefit design and cost-sharing limits, elimination of the “meaningful difference” requirement, elimination of the annual evaluation of MAO enrollment levels, and the reduction of MAOs’ minimum medical loss ratio requirements.

The letter also notes the importance of requiring adequate stop-loss insurance coverage for physician groups that bear risk, the need for greater transparency in MAO medical record requests, and the importance of provider communications with their MA patients regarding cost-sharing responsibilities.

Lastly, the FAH letter encourages CMS to maintain the requirement that MA providers enroll in traditional Medicare and suggests improvements to the MA Star Ratings System.

FAH Leader Congratulates New Health Subcommittee Chair

January 10, 2018 | Chip Kahn

Category: FAH News, Media

Congratulations to Rep. Peter Roskam on his selection as Chairman of the House Ways and Means Subcommittee on Health. Chairman Roskam is a thoughtful, pragmatic legislator, with a proven understanding of health care. FAH looks forward to his leadership and is ready to work with him in his new role. 

FAH Encourages Senate Confirmation of HHS Secretary Nominee

January 08, 2018 | Chip Kahn

Category: FAH News, Hearings, Media

This week Members of the Finance Committee will learn what many of us already know – Alex Azar is uniquely suited to serve as HHS Secretary and ready to confront the health care challenges and opportunities facing this nation’s patients, families and caregivers.

Mr. Azar’s years of experience in both the private and public sectors equips him well to effectively lead this complex agency.

We encourage the US Senate to confirm Mr. Azar quickly.  We look forward to working with him on further improving American health care delivery and financing.

Passing the Gavel: Wayne Smith Succeeds Milton Johnson as FAH Chair

January 04, 2018 | Chip Kahn

Category: FAH News, General

This week, Wayne Smith, Chairman of the Board and CEO of Community Health Systems (CHS), assumed the position Chairman of the Board of the Federation of American Hospitals.

Wayne is one of the country’s preeminent hospital industry executives. He has been at the helm of CHS for more than 20 years, and during that time his influence and leadership has been well recognized.

The health care field is constantly evolving and having Wayne’s deep appreciation and understanding of the intersection of industry concerns and health policy will only enhance our organization’s effectiveness in meeting the many challenges we face in Washington. 

As Federation Board Chair, Wayne succeeds Milton Johnson, Chairman and CEO of HCA. On behalf of the Federation, I want to thank Milton for his outstanding dedication to our hospitals and patients. His steady hand of leadership kept us successfully focused during this unpredictable year for health care policy development.

Federation Members Honored as Heroes by Modern Healthcare

December 21, 2017 | FAH Policy Blog Team

Category: FAH News, General

Modern Healthcare’s most recent edition recognized health care workers who answered the call to serve during unprecedented disasters and tragedies in 2017 – including those who work at several FAH affiliated hospitals.

In a special section entitled – “Responding to disaster: How healthcare rose to the challenge in 2017” – the magazine highlights acts of dedication from around the country.

Two of the stories center on the tragic shooting at a country music festive in Las Vegas.

Robert Weiss, physician assistant, clinician and an ER provider at HCA’s Sunrise Hospital and Medical Center, was at the concert. After making sure his wife was safe, he made his way to the medical tent on site and started treating the wounded. In the middle of chaos, he said he also saw acts of kindness and a “resurgence of humanity.”

You can read his story here.

The Emergency Department at Sunrise ended up seeing more than 200 patients that night - Dr. Scott A. Scherr is the Chairman of emergency services and led the lifesaving efforts.

He credits the hard work of the hospital’s team with saving hundreds of people.

“Sunrise Hospital is a very busy place to work anyway. We've always stressed a team approach and the next-man-up type of mentality. That certainly was displayed that night,” Dr. Scherr told Modern Healthcare. “To think that at 10 at night our providers answered the call and came in without question, that was the reason why we saved so many lives that night. If we did not have that response from our team, a lot more lives would have been lost.”

You can read his story here.

When Hurricane Harvey dumped more than 50 inches of rain on the Houston area, massive flooding put a strain on hospitals across the area. Caregivers were dutifully treating patients, while in many cases their homes were under water.

That is when nurses from across the HCA system jumped into action. More than 300 of them travelling to Texas to give nurses from Houston a chance to take a break and go home so they could check on their families.

Kelli Nations, Chief nursing executive of the HCA Gulf Coast Division, helped organize the volunteer effort.

“The visiting nurses were fresh and revived and excited about being there. A lot of nurses and staff members lost their home or lost their home and their vehicles,” Nations told Modern Healthcare. “You can imagine, when they came home from work and had to deal with a home that was flooded, they needed some time off. Many of those volunteer nurses stayed with us for two weeks, even four weeks, to allow our nurses to take some needed time off to care for their families and get back on track.”

The HCA Hope Fund assisted families of 1,700 employees affected by the storm. You can read more here.

FAH salutes the hard work and dedication of all the medical professionals who served their communities during these difficult situations. 

FAH Welcomes Claudia Salzberg as New Vice President, Quality

December 12, 2017 | Chip Kahn

Category: FAH News

The Federation of American Hospitals is pleased to announce the addition of Claudia Salzberg, Ph.D.,MSE, as Vice President, Quality. We are excited to have her join our team.

Dr. Salzberg brings a new dimension to the Federation with extensive experience in clinical quality and performance research. She clearly strengthens the team of experts we have already assembled.

She is an accomplished, dynamic researcher with a keen understanding of quality and performance measurement having worked positions at several prestigious academic medical centers.               

Among her areas of expertise are electronic health records and health information technology, patient-and-family-centered healthcare, and the emerging opportunities associated with managing “big data” to improve health outcomes and operational efficiency. 

Dr. Salzberg was most recently a Research Scientist at the Children’s Hospital of Philadelphia. Prior to that she filled a variety of roles at organizations such as Johns Hopkins Bloomberg School of Public Health, Brigham and Women’s Hospital, and Partner’s Healthcare. Claudia also worked in the tech world with IBM.

Dr. Salzberg earned her Ph.D. in Health Policy and Management from Johns Hopkins, an MSE in Computer Science from the University of Pennsylvania, and a BS from Brown University. 

FAH Submits Comments to the 2019 Exchange Rule

November 27, 2017 | FAH Policy Blog Team

Category: Affordable Care Act, Insurance

Late today, FAH submitted comments to CMS Administrator Seema Verma on the Notice of Benefit and Payment Parameters for 2019 Proposed Rule (2019 Exchange Rule).  The rule proposes modifications to the regulations governing the Exchange created by the Affordable Care Act.

FAH believes that an important goal of the ACA - and implemented through the Exchange - is to provide a consumer-friendly opportunity to shop for and compare health insurance products that offer meaningful coverage at an affordable price.

Unfortunately, many of the changes proposed in the 2019 Exchange Rule go against those principles and could lead to higher cost, lower value and reduced benefit adequacy.

Key provisions in the proposed rule of particular interest to hospitals are unfavorable changes to how Essential Health Benefits (EHBs) are determined, further weakening of the current network adequacy standards, reduction of the MLR and rate review requirements and the adoption of policies that make the Marketplaces less consumer-friendly.

In comments, the FAH echoes previous positions, including the support for comprehensive EHBs, the need for CMS to strengthen the Exchange’s network adequacy provisions in order to ensure access to provider services, and support for a robust MLR and rate review policy.  

You can read the comment letter here.

FAH Comments on Administration’s New Vision for CMMI

November 21, 2017 | FAH Policy Blog Team

Category: Medicaid, Medicare

The Federation of American Hospitals sent a letter to CMS today answering the agency's Request for Information on a new direction for the Center for Medicare and Medicaid Innovation (CMMI).

The FAH wrote that at its core, the new direction for CMMI should be about "improving quality, retaining and improving access, and addressing cost for patients...."

As in previous letters to the Agency, the Federation reiterated its belief that CMMI models should be tested on a voluntary basis and that "CMS does not have the authority to implement permanent or mandatory changes to Medicare stemming from results of a CMMI model without Congressional approval."

Other areas addressed include the need for greater stakeholder engagement in transparent model design and the use of appropriate quality measurement in the models.

Per the Agency's request, the FAH commented on potential models in the outlined areas:

  • Medicare Advantage Innovation Models
  • Prescription Drug Models
  • Mental and Behavioral Health Models

The letter also laid out other areas where FAH recommends CMS should consider voluntary models, including:

  • Post-Acute Care
  • Population-Based Payment
  • Telemedicine
  • Rural Hospital Outpatient-Only Model

You can view the entire letter here.

FAH Joins Coalition Urging Congress to Keep Individual Mandate

November 14, 2017 | FAH Policy Blog Team

Category: Affordable Care Act, Insurance

A broad coalition of health care groups, including FAH, sent a letter to leaders of the House and Senate Tuesday urging Congress to “maintain” the Affordable Care Act’s individual insurance mandate.

The House and Senate have discussed including a repeal of the mandate in tax reform legislation. However, a CBO report released last week noted that eliminating the requirement that most American have health insurance would result in 13 million people losing coverage over the next decade.

“As providers of healthcare and coverage to hundreds of millions of Americans, we are committed to assuring everyone has access to a range of high quality, affordable coverage options so they can access the care they need, regardless of pre-existing conditions,” the letter states. “To achieve this critical goal, we are urging you to maintain the individual mandate unless and until Congress can enact a package of reforms to adequately assure a balanced risk pool and prevent extraordinary premium increases.”

In the letter, which was addressed to Senate Majority Leader Mitch McConnell (R-KY), Senate Minority Leader Charles Schumer (D-NY), Speaker Paul Ryan (R-WI) and Minority Leader Nancy Pelosi (D-CA), the groups said they stand ready to work with Congress on a solution that maintains access to affordable coverage and care.

“We join together to urge Congress to maintain the individual mandate. There will be serious consequences if Congress simply repeals the mandate while leaving the insurance reforms in place: millions more will be uninsured or face higher premiums, challenging their ability to access the care they need. Let’s work together on solutions that deliver the access, care, and coverage that the American people deserve.”

The letter was signed by The Federation of American Hospitals, America’s Health Insurance Plans, American Academy of Family Physicians, American Hospital Association, American Medical Association and Blue Cross Blue Shield Association.

You can find a copy of the letter here.

FAH Congratulates Alex Azar on HHS Secretary Nomination

November 13, 2017 | Chip Kahn

Category: Affordable Care Act, FAH News

 “We welcome and support the nomination of Alex Azar for HHS Secretary.  His years of experience in government service and the health care sector makes him uniquely qualified to confront the challenges facing patients, families, and caregivers.

“I have worked with Mr. Azar in the past and think he is the perfect pick for the times. His steady hand of leadership will be critically important as the deliberations over health reform and the many health care quality and cost issues proceed.

“We encourage the US Senate to confirm Mr. Azar quickly.  We look forward to working with him constructively on the future of American health care delivery and financing.”

Serving our Country, Caring for our Community

November 09, 2017 | FAH Policy Blog Team

Category: FAH News, General

This weekend, we honor veterans for their dedicated service to our country. The FAH appreciates the great sacrifices made by our retired service members and their families to protect America at home and abroad.

Hospitals have partnered with the Veterans Administration for many years to ensure all of our veterans have access to quality health care close to home. We are proud to work with the VA to provide support for our nation’s heroes.

Several FAH member companies have also dedicated themselves to hiring veterans so their time of service doesn’t end with their discharge. The values instilled by the military – commitment, diversity, leadership and the ability to perform under pressure – translate perfectly into health care. Each year thousands of veterans transition from serving our nation to caring for our communities. Hospitals are proud to hire heroes from all branches of the military because we know what a difference they can make in every aspect of patient care.

To all veterans across America, we thank you for your service.  Happy Veterans Day!

FAH Leader Applauds House Vote to Repeal IPAB

November 02, 2017 | Chip Kahn

Category: Affordable Care Act, Medicare

“Today’s House vote to repeal the Independent Payment Advisory Board (IPAB) will ensure that Medicare beneficiaries and their caregivers are not subject to arbitrary cuts in the program orchestrated by an appointed board of bureaucrats. It leaves in Congress’ hands the important decisions about Medicare health care services, where the decisions that affect so many Americans should be made.

“We applaud Rep. Roe and Rep. Ruiz for their leadership and appreciate the strong bipartisan support for this legislation.”

FAH Supports House CHIP Reauthorization Bill

October 31, 2017 | FAH Policy Blog Team

Category: Health Care Delivery, Legislation, Medicaid

The Federation of American Hospitals sent a letter to House Energy and Commerce Chairman Greg Walden (R-OR) on Tuesday expressing support for HR 3922, legislation that reauthorizes funding for the Children’s Health Insurance Program (CHIP).

FAH President and CEO Chip Kahn wrote that this bill “will provide certainty to families that depend on this program, the states that are attempting to manage the program and providers that are eager to administer care.  We appreciate that there is bipartisan commitment in both the House and Senate to the extension of CHIP and believe that passage of this legislation is an important and necessary step that moves us closer to a final agreement.”

The legislation also eliminates reductions to the Medicaid DSH program for fiscal years 2018 and 2019, restoring vital funding so that hospitals can better care for patients.

“DSH hospital payments, which help defray losses hospitals incur in treating low-income and uninsured Americans, play a critical role in allowing hospitals to fulfill our mission to provide care in our communities.  If allowed to go into effect, DSH reductions will pose a serious challenge to our hospitals to meet that mission,” Kahn wrote.

FAH urges the House to swiftly pass HR 3922.

FAH Releases Coalition Statement Urging Congress to Fund Vital Insurance Program

October 20, 2017 | FAH Policy Blog Team

Category: Affordable Care Act, Insurance

Today, a broad coalition of health care and business groups, including FAH, released a statement regarding the market stabilization legislation proposed by Sens. Lamar Alexander and Patty Murray. Last week the Administration announced it was ending CSR payments. The coalition has been working for months to make sure this vital program continues.

The statement reads:

“Sens. Alexander and Murray, thank you for your leadership.

Consumers and patients benefit from more affordable care and additional choices in a stable individual health insurance market.

Funding the critical consumer cost-sharing reduction (CSR) benefit will help:

• lower-income patients afford to see their doctor; and

• consumers access more affordable insurance options.

Beyond advancing these important policy priorities, federal spending will be lower if CSR benefits are continuously funded. In contrast, terminating CSR funding will increase our nation’s budget deficit by almost $200 billion over 10 years.

We join together again to urge Congress to take action to enact legislation that includes continued funding for CSR benefits for the rest of 2017 and for at least the next two years (2018-2019).

Health care is a bipartisan priority on which all of us can work together to deliver real solutions and real results.”

The statement was authored by FAH, America’s Health Insurance Plans, American Academy of Family Physicians, American Benefits Council, American Hospital Association, American Medical Association, Blue Cross Blue Shield Association, and U.S. Chamber of Commerce.

FAH Leader Reacts to Bipartisan Deal on Vital Insurance Program

October 18, 2017 | Chip Kahn

Category: Affordable Care Act, Insurance

“We applaud Senators Alexander and Murray for their leadership in crafting a bipartisan plan that will help millions of working American families keep access to the care they need.

“Ensuring that federal funds remain available to pay for the subsidization of the cost sharing is vital to keeping premiums in check and coverage available to so many people that depend on this critical program.

“We encourage both the House and Senate to act swiftly on this important legislation since enrollment begins in a matter of days.”

FAH Comments on EPM Cancellation Proposed Rule

October 16, 2017 | FAH Policy Blog Team

Category: Health Care Delivery, Medicare

FAH sent comments to CMS today supporting the agency’s decision to cancel the Episode Payment Models (EPM), and encouraging the Agency to make additional changes to the Comprehensive Care for Joint Replacement Model (CJR).

CMS’s reasoning for cancelling the EPMs falls largely in line with FAH’s comments when the models were originally proposed. The Federation and other stakeholders pointed out that the “models contain many design flaws that undermine their success.”

Also in the letter, the Federation expressed appreciation for CMS’s proposed scaling back of the CJR mandatory participation areas and encouraged the agency to make it and other CMMI models voluntary.

Ultimately, FAH does not believe that the law authorizes CMS to “mandate mandatory participation in any CMMI models.”

The letter also contains more detail on additional areas where FAH believes CMS could improve CJR.

You can find the complete letter here.

FAH Joins Coalition Urging Congress to Fund Vital Insurance Program

October 16, 2017 | FAH Policy Blog Team

Category: Affordable Care Act, Insurance

A broad coalition of health care and business groups, including FAH, sent a letter to leaders of the House and Senate Saturday asking Congress to restore funding for cost-sharing reduction (CSR) benefits.

Earlier this week the Administration announced it was ending CSR payments. The coalition has been working for months to make sure this vital program continues.

“We have come together with one voice to call for much-needed legislation to fund CSR benefits. With the Administration’s decision to terminate this funding, Congress must take action immediately.”

“The CSR program directly benefits nearly 6 million low- and modest-income Americans. By reducing their out-of-pocket expenses—such as deductibles and co-payments—CSR benefits help people afford their medical expenses and get the care they need.”

The letter was addressed to Senate Majority Leader Mitch McConnell (R-KY), Senate Minority Leader Charles Schumer (D-NY), Speaker Paul Ryan (R-WI) and Minority Leader Nancy Pelosi (D-CA).

The groups highlighted what the non-partisan Congressional Budget Office (CBO) says will happen if CSR benefits aren’t restored. Consequences include:

• Rising premiums, increasing average premiums for benchmark silver plans (the most popular plans on the exchanges) by 20 percent in 2018 and by 25 percent in 2020.

• Denying choices for consumers and greatly increases the risk that some places will have no coverage options at all.

• Increasing the federal budget deficit by $194 billion over the next ten years (2017-2026).

”We join together again to urge Congress to take swift action to ensure continued funding for CSR benefits for 2017 and for at least the next two years (2018-2019) as part of a targeted, bipartisan solution to strengthen and stabilize the individual health insurance market. We agree that this approach is the best way to move forward without jeopardizing access to care for millions of Americans.”

The letter was signed by FAH, America’s Health Insurance Plans, American Academy of Family Physicians, American Benefits Council, American Hospital Association, American Medical Association, Blue Cross Blue Shield Association, and U.S. Chamber of Commerce.

FAH Leader Comments on Elimination of Federal Cost-Sharing Payments

October 13, 2017 | Chip Kahn

Category: Affordable Care Act, Financing

Federation of American Hospitals President and CEO Chip Kahn released the following statement on announcement that Federal cost-sharing payments will be eliminated:

"Millions of working Americans families depend on the subsidization of their cost sharing to ensure them access to the health care they need. Unfortunately, a decision has been made to stop Federal payments for the cost sharing. This action will jeopardize the health care coverage on which so many Americans depend. It is critically important that the Congress act with dispatch to ensure the Federal funds remain available to pay for the cost sharing for those working American families."

FAH Leader Comments on Efforts to Repeal IPAB

October 04, 2017 | Chip Kahn

Category: Affordable Care Act, Medicare

“Congress should be making the important decisions on Medicare that so critically affects the lives of 58 million seniors and disabled Americans. The Independent Payment Advisory Board (IPAB), included in the ACA to set Medicare payment and delivery policy, was a bad idea from the beginning.

“It is time to repeal the IPAB. We support the efforts in the House Ways and Means and Energy and Commerce Committees to eliminate the IPAB. We congratulate the committees on this endeavor and thank them for their leadership. We look forward to working with policymakers as this legislation proceeds.”

FAH Member Company, Hospitals Named to Best Places to Work List

October 03, 2017 | FAH Policy Blog Team

Category: FAH News, Health Care Delivery

One of FAH’s member companies and several hospitals were named the 2017 Modern Healthcare Best Places to Work list.

This is the tenth year that the magazine has put out the list, which includes HealthSouth and 16 FAH affiliated hospitals.

“Our award winners can be proud of the role they play in elevating the standard for workplace excellence. These five-star organizations not only see higher employee retention, but also increased patient engagement and satisfaction and healthier bottom lines,” wrote Modern Healthcare’s Vice President and Publisher Fawn Lopez.

FAH affiliated hospitals on the list included:

#7 – Doctors Hospital of Sarasota, HCA, Sarasota, Florida

#8 – Southern Tennessee Regional Health System Pulaski, LifePoint Health, Pulaski, Tennessee

#10 - Texas Orthopedic Hospital, HCA, Houston, Texas

#16 - Methodist Ambulatory Surgery Hospital, HCA, San Antonio, Texas

#27 - Methodist Texsan Hospital, HCA, San Antonio, Texas

#28 - West Valley Medical Center, HCA, Caldwell, Idaho

#36 - South Baldwin Regional Medical Center, Community Health Systems, Foley, Alabama

#37 - Lovelace Women's Hospital, Ardent Health Services, Albuquerque, New Mexico

#40 - Lee's Summit Medical Center, HCA, Lee's Summit, Missouri

#43 - Englewood Community Hospital, HCA, Englewood, Florida

#55 - HealthSouth Corp., Birmingham, Alabama

#59 - Hillcrest Hospital Cushing, Ardent Health Services, Cushing, Oklahoma

#62 - Bailey Medical Center, Ardent Health Services, Owasso, Oklahoma

#65 - Lovelace Medical Center, Ardent Health Services, Albuquerque, New Mexico

#67 - Metropolitan Methodist Hospital, HCA, San Antonio, Texas

#68 - BSA Health System, Ardent Health Systems, Amarillo, Texas

Click here to view the entire 2017 Modern Healthcare Best Places to Work list.

We congratulate all the facilities and companies honored this year.

FAH to CMS: Hospital Star Ratings New Methodology Needs Improvement

September 28, 2017 | FAH Policy Blog Team

Category: General, Quality

The Federation of American Hospitals this week commented on the CMS proposed methodology changes for the Medicare Hospital Star Rating program.

“It is vitally important to hospitals, patients, their families, and the overall national work on quality improvement and public reporting that any changes to the display data by star categories accurately reflect the quality of care provided by hospitals to their patients,” FAH wrote in the letter.

FAH has indicated to CMS several times that the Star Ratings were “not ready for primetime” because they didn’t accurately reflect – in an easily discernable way – the true quality of care being provided by the facilities.

“FAH strongly suggests that CMS further test its methodologies and hold focus groups with hospitals, physicians, patients, families and caregivers to understand how well the statistical information and displays are understood and determined to be useful by all stakeholders.”

In the letter, which can be found here, FAH proposes several improvements to the Star Ratings methodology and asks CMS to suspend release of the ratings until changes are made.

FAH Comments on Proposed Home Health Payment and Methodology Changes

September 25, 2017 | FAH Policy Blog Team

Category: Financing, Health Care Delivery, Medicare

The Federation of American Hospitals sent comments to CMS today on proposed changes to the 2018 home health prospective payment system (HH PPS) rate and proposed refinements to the case-mix adjustment methodology that would begin in 2019.

CMS’s proposed home health grouping model (HHGM) would group patients into payment categories using primarily clinical characteristics and other patient information as a replacement for the five current categories, which are based on the number of therapy services provided and the episode’s timing in a sequence of episodes.

FAH expressed concern that the changes described in the proposed rule are not ready for implementation in 2019 and urged CMS not to finalize the proposed adoption of the HHGM. FAH’s letter notes that: “The proposed new case mix system represents a major departure from how home health agencies are currently paid by Medicare. It is untested, its details are not transparent, and if implemented as proposed, the new HHGM could result in unintended consequences for Medicare beneficiaries, the Medicare program, and home health service providers, as well as hospitals and the broader health care system…”

FAH supports continued work on a HHGM-based case-mix adjustment, but asked that CMS continue to work with all stakeholders to develop a system that is “clinically coherent and transparent, results in appropriate payment for services rendered, and ensures continued access to needed home health services.”

FAH believes that in order to successfully design and implement a HHGM, CMS should:

•         Defer implementation of the proposed 2019 HHGM, and establish a process for continued dialogue with stakeholders in anticipation of a re-proposal of an HHGM in the future

•         Make all data used in preparing the proposed rule groupings and impact analysis available to stakeholders to further understanding and replication of the proposed system

•         Propose any subsequent HHGM with a multi-year transition in order to minimize disruptions

•         Make conversion to the HHGM budget neutral, which FAH believes is statutorily required.

You can read the entire comment letter by clicking here.

FAH Leader Comments on the Graham-Cassidy Proposal

September 20, 2017 | Chip Kahn

Category: Affordable Care Act, Insurance, Medicaid

The Graham-Cassidy proposal could disrupt access to health care for millions of the more than 70 million Americans who depend on Medicaid and the marketplaces for their health coverage.

It is time to move on to secure the health coverage for those who have it, and find solutions for those who don’t.

We urge the Senate to reject legislation that fails to move us forward in assuring Americans access to affordable health care and coverage.

Campaign for Sustainable Rx Pricing Urges House to Pass CREATES Act

September 19, 2017 | FAH Policy Blog Team

Category: Legislation, Pharmaceuticals

The Campaign for Sustainable Rx Pricing, which is made up of groups from across the health care spectrum – including FAH, sent a letter to House leaders this week urging them to consider the Creating and Restoring Equal Access to Equivalent Samples (CREATES) Act.

The legislation is a targeted, market-based, bipartisan solution to this longstanding problem that affects both access to and affordability of prescription medications.

The 36 organizations and companies that signed the letter laid out the reasons why the CREATES Act is needed.

“For too long, brand-name pharmaceutical manufacturers have exploited patient safety tools in order to stifle generic competition and attendant lower prescription drug prices…

“This “gaming” by brand-name pharmaceutical companies denies generic manufacturers access to the samples that they require in order to conduct necessary equivalence testing to ensure the quality, efficacy, and safety of a generic drug. As a result of this pattern of anticompetitive practices, brand-name manufacturers are able to stifle generic competition, inflating prescription drug prices by artificially extending their monopoly pricing power far beyond the exclusivity period intended by Congress.”

The letter was sent to House Speaker Paul Ryan and Minority Leader Nancy Pelosi. You can read it in its entirety and see who signed on by clicking here.

Legislative Lifeline: Bipartisan Bill Can Cure Funding Issue for Rural Hospitals

September 18, 2017 | FAH Policy Blog Team

Category: FAH News, Medicare, Rural

Rural hospitals provide a vital lifeline to nearly 60 million Americans. Whether you are taking you child for a check-up at Mad River Community Hospital in Arcata, California or need emergency care at Desoto Memorial in Arcadia, Florida, facilities from coast to coast keep small communities healthy physically and fiscally.

Now rural hospitals need Congress’ help.

Having a hospital in a rural community can literally save lives. When seconds matter most, having essential health care minutes away, instead of hours, can mean the difference between life and death.

But these facilities are also the center of people’s livelihoods. Around 14% of total employment in small communities is attributed to the health care sector and hospitals are often the largest or the second largest employer in most rural communities. The economic impact radiates far beyond the four walls of the hospital. From the dry cleaner who takes care of workers uniforms and the restaurant where the staff go to lunch to realtors, car dealers and day cares, you would be hard pressed to find a business not touched in some way by those who work for or get treatment at one of these facilities.

However, their locations create unique challenges, like limited workforce options, physician shortages, difficult patient mix and razor tight budgets. This can often make it tough for rural hospitals to keep their doors open.  We saw this reality play out in the 1980’s, when hundreds closed.

Congress stepped in to revive many rural hospitals with payment modifications, which included the Medicare Dependent Hospital (MDH) and the Low Volume Hospital (LVH) programs.

MDHs are hospitals that meet specific criteria that care for a larger portion of Medicare recipients (more than 60%) than their urban counterparts.  Because the rural Medicare patient populations in these areas are older, suffer from higher rates of chronic illness, and have lower incomes, these rural hospitals struggle to stay financially stable under the Medicare fee schedule.  In 1987, Congress recognized these challenges, by providing MDH designated hospitals payments based on their historical costs of providing care rather than the prospective payment schedule based on how other hospitals preform.

The LVH program recognizes that certain hospitals are more isolated and simply do not have the patients volume for economies of scales.  The sliding-scale payment adjustment created by the LVH program helps compensate for such a competitive disadvantage.   

Both programs expire at the end of this month and if Congress doesn’t act patients could suffer. Hospitals might be forced to cut back on services and staff and in worst cases scenarios shut down completely.

The good news – it doesn’t have to get to that point. There is bipartisan legislation that would make these programs permanent. The Rural Hospital Access Act of 2017 (H.R. 1955/S.872), which was introduced by Congressman Tom Reed (R-NY) and Peter Welch (D-VT) and Senators Chuck Grassley (R-IA) and Chuck Schumer (D-NY), gives certainty to rural hospitals and the patients and communities they serve.

With the deadline approaching, FAH President and CEO Chip Kahn has been highlighting the importance of these programs for community hospitals during a radio tour. He has conducted interviews with hosts in local markets from Tennessee, Ohio, Pennsylvania, New York and North Carolina. He also spoke with Tim Farley on Sirius/XM Radio’s POTUS channel.

Kahn’s message is simple – there is a vaccination that can treat this problem before it starts. FAH is asking Congress to package the Rural Hospital Access Act with other must-pass health care legislation, like the Children’s Health Insurance Program (CHIP) reauthorization, and pass it this month.

It is time for lawmakers to stand up for the rural hospitals that so many Americans depend on.

You can listen to Chip’s Sirius XM interview here and find his interview on Pennsylvania Public News Service here.

Health Care Coalition Asks Congress to Delay Medicaid DSH Cuts

September 18, 2017 | FAH Policy Blog Team

Category: Affordable Care Act, Medicaid

A coalition made up of groups from across the spectrum of health care, including the Federation of American Hospitals, sent a letter to members of the House and Senate on Monday asking for a delay in the start of Medicaid disproportionate share hospital (DSH) cuts.

The Medicaid DSH program assists hospitals serving high numbers of Medicaid and uninsured patients. Currently, about half of all hospitals in the United States receive DSH payments to address Medicaid underpayment and uncompensated care, which allow them to provide critical community services such as trauma and burn care, high-risk neonatal care and disaster preparedness resources.

The letter outlines why the cuts need to be delayed:

“The Affordable Care Act (ACA) reduced payments to the Medicaid DSH program under the assumption that uncompensated care costs would decrease as health care coverage increased. The reductions are now scheduled to begin on Oct. 1, 2017 at $2 billion.

“Unfortunately, the coverage rates envisioned under the ACA have not been fully realized, and tens of millions of Americans remain uninsured. In addition, Medicaid underpayment continues to pose ongoing financial challenges for hospitals treating our nation’s most vulnerable citizens. Congress recognized the need for the Medicaid DSH program to continue to be fully funded by delaying the start of the cuts over the past four years.”

Joining FAH in signing the letter was America’s Essential Hospitals, American Hospital Association, Association of American Medical Colleges, Catholic Health Association of the United States, Children’s Hospital Association, National Association of Psychiatric Health Systems, Premier Healthcare Alliance and Vizient, Inc.

You can view copies of the letter here.

Hospitals Offer Free Virtual Care to Storm Victims

September 14, 2017 | FAH Policy Blog Team

Category: FAH News

Several hospitals in Florida are offering free non-emergency telehealth care via electronic devices to Hurricane Irma survivors.

The facilities, which are affiliated with FAH member Community Health Systems, are working with Virtual Health Connect to help patients suffering from minor health concerns like sinus problems, fever, ear infections, cold and flu symptoms, allergies, migraines, stomach pain, and much more.

Hospitals leaders who came up with the idea understand that in the wake of the storm getting to the doctor’s office can be difficult – if it is even open.

As several local hospitals CEO’s have said, “Making it more convenient to talk with a clinician about your or your loved ones’ medical needs is one way we can lend a hand to those who’ve been impacted by the storm.”

People can log on to http://VirtualHealthIrma.com on any mobile device, computer or tablet, then enter coupon code IRMA to have their visit free of charge. They will then be connected directly to a physician who will evaluate and diagnose the patient, and if feasible and appropriate, send prescriptions to the pharmacy—just like an in-office doctor’s appointment.

It is important to note that is someone is experiencing a life-threatening medical emergency they need to dial 9-1-1 immediately.

Several local news outlets have covered the hospitals’ efforts you can read more by clicking on the headlines below:

The Ledger: 2 Polk Hospitals Providing Free Telehealth Care

Hernando Sun: Medical Visits 24/7 Free of Charge for Hernando County Hurricane Irma Victims

Ocala Star Banner – MRMC Offers Free Telehealth Visits

Experts Stress Importance of Telehealth to Congressional Staff

September 13, 2017 | FAH Policy Blog Team

Category: Health Care Delivery, Rural

The importance of telehealth to rural communities and the challenges it faces were the topic of a special briefing on Capitol Hill today.

A wide range of stakeholders, including a representative from LifePoint Health, briefed congressional staffers on the unique obstacles in health care coverage and access for non-urban areas - including provider shortages, limited insurance, and increased distance to quality care.

One thing that can literally help bridge the gap is telehealth.

“Telehealth offers rural communities, in particular, the extraordinary ability to access specialized, highly trained physicians in remote and sparsely populated locations while maintaining the highest standards of quality and saving costs,” said Melissa Waddey, President of Ambulatory and Operations Services of LifePoint health.

She added that one of the biggest roadblocks is making sure providers get paid fairly for their services, whether they are delivered in person on remotely.

“Reimbursement for telehealth services is variable by state and by payor,” Waddey added. The lack of parity compounds complexity of providing services across the country in rural markets and is a barrier for rural hospitals.”

Waddey was joined on the panel by representatives from the National Rural Health Association and TeleQuality Communications.

They also briefed staffers on how legislation like the HEART Act (H.R. 2291) can affect access among the occupying populations.

Just click here to watch today’s briefing.

FAH Comments on 2018 Proposed OPPS and PFS Rules

September 11, 2017 | FAH Policy Blog Team

Category: Financing, Medicare

Today, the Federation of American Hospitals (FAH) filed comment letters in response to CMS’s proposed rules governing Medicare hospital outpatient payments and physician fee schedule payments in 2018.

Some of the issues addressed by FAH in the letters include:

340B Drug Discount Program

The letter states that if CMS finalizes its proposed payment reduction for separately payable drugs acquired under the 340B program, it must “implement this payment reduction in a budget neutral manner within OPPS.”

Total knee replacement

FAH strongly recommends that the total knee replacement procedures remain on the CMS Inpatient only (IPO) list. The letter notes that these procedures place patients at risk for several complications including but not limited to deep vein thrombosis, pulmonary embolism and infections among other issues. This is especially true for a Medicare population that is more elderly and typically more frail than a commercial population.

Outpatient payment for new hospital off-campus provider based departments (PBD)

FAH strongly opposes CMS’s proposal to reduce payment from the current 50% of the outpatient rate to 25%. Instead, the FAH letter recommends a rate of 60% and presents empirical data and analysis supporting its position.

Direct supervision enforcement in rural hospitals

While the FAH letter acknowledges and appreciates CMS’s proposal for a two year enforcement moratorium, we urge CMS to extend it permanently.

You can read the entire OPPS letter here and find the PFS letter here.

Keeping Kids Safe: Congress Needs to Act on CHIP Program

September 07, 2017 | Chip Kahn

Category: FAH News, Hearings, Medicaid

Parents have a lot on their minds this time of year. First days of school, after-school activities, drop off and pick up are just some of the things keeping parents on their toes this Fall. Luckily, for the millions of parents whose children are insured by the Children’s Health Insurance Program (CHIP), Congress is eager to make sure, “find new health insurance,” isn’t added to the to-do list. 

Thursday’s Finance Committee hearing is a welcome step in Congress’ work to extend CHIP. Our patients, the kids covered by CHIP and their parents, depend on the peace of mind that insurance coverage provides. Hospitals will be ready to take care of those kids when the inevitable playground spills or sports injuries occur and we don’t want their parents to think twice about seeking treatment. We know Congress wants the same.

While Congress’ Fall agenda is crowded, there is no doubt that keeping kids insured and making sure America’s hospitals can serve them is an important priority. We appreciate Congress’ work to extend CHIP and encourage both chambers to also focus on delaying the scheduled Medicaid DSH cuts and extending the important Low-Volume Hospital and Medicare Dependent Hospital programs. By taking these actions, Congress can help hospitals fulfill our commitment to delivering the best care to kids in all parts of our nation while allowing their parents to sleep a little more restfully at night.

FAH Leader Calls CHIP Hearing a “Welcome Step”

September 06, 2017 | Chip Kahn

Category: FAH News, Hearings, Medicaid

More than eight million American kids depend on the CHIP program for their health care. We treat many of these young patients in our hospitals. These children and their families depend on the security of the CHIP program, we should not let them down. Today’s Finance Committee hearing is a welcome step in Congress’ work to extend CHIP and keep those kids secure.

While Congress has a crowded agenda this fall, that should not be an obstacle to keeping children covered and we are hopeful that CHIP will be extended.

At the same time, the CHIP bill, as it did a few years ago, provides an opportunity for Congress to help Americans most in need by delaying the scheduled Medicaid DSH cuts and extending the critically important Low-Volume Hospital and Medicare Dependent Hospital programs.

Coalition Urges Two Year Extension of CSR Funding

September 06, 2017 | FAH Policy Blog Team

Category: Affordable Care Act, FAH News, Insurance

A broad coalition of health care and business groups, including FAH, sent a letter to leaders of the Senate HELP Committee on Tuesday asking for cost-sharing reduction (CSR) benefits to be continuously funded for 2018-2019. The committee is holding two hearings on the issue this week.

“We urge the Committee to include continuous funding for CSR benefits for at least the next two years  as part of bipartisan legislation to stabilize the individual market. Without two years of CSR funding, uncertainty will persist and the Congress will need to address these same issues early next year,” the letter states. “By committing to CSR funding for two years, it would go a long way to bring much needed stability to the individual market and promote access to more affordable coverage and choices for millions of Americans.”

The letter, which was addressed to Sens. Lamar Alexander (R-TN) and Patty Murray (D-WA) – Chairman and Ranking Member of the Senate HELP Committee respectively, outlined the importance of CSRs.

“CSR benefits help those who need it most: low- and moderate-income Americans with incomes under 250 percent of the federal poverty level. Nearly 60 percent of exchange-plan enrollees rely on CSR benefits, which translates into comprehensive coverage and access for nearly 6 million individuals and families. The CSR program makes it more affordable for patients to receive needed medical care and services by reducing deductibles, copayments, and out-of-pocket maximums. As a result, providers can better serve the needs of their communities and employers do not needlessly face higher costs to provide coverage to their employees.”

The letter, which you can find here, was signed by FAH, America’s Health Insurance Plans, American Academy of Family Physicians, American Benefits Council, American Hospital Association, American Medical Association, Blue Cross Blue Shield Association, and U.S. Chamber of Commerce.

FAH to CMS: Delay and Rescind Medicaid DSH Cuts

August 28, 2017 | FAH Policy Blog Team

Category: Affordable Care Act, Medicaid

In comments to CMS today to the Medicaid Disproportionate Share Hospital (DSH) Reduction Proposed Rule, FAH urged the Agency to delay the implementation of the reductions and to work with Congress to rescind them. 

Cumulative reductions set to be imposed between FY 2018 and FY 2025 now reach $43 billion. 

As FAH points to in its letter, Medicaid DSH cuts of this magnitude pose a significant risk to the hospital safety net at a time when demands on the program are growing and the responsibilities of hospitals to care for the uninsured have not abated.  As such, FAH urges the Administration to work with Congress to delay this year’s proposed DSH cuts and ultimately, rescind these harmful cuts to hospitals.  Additionally, citing the need to address deficiencies with its data sources, including the transparency and timeliness of the data and outstanding legal questions impacting the data, FAH urges CMS to delay the implementation of the rule in order to address the data issues identified in the letter. FAH notes that if not addressed prior to implementation, these issues will have a material impact on the distribution of the reductions across states.

Finally, FAH outlines its support for CMS’s decision not to use Medicare uncompensated care cost data from Worksheet S-10 for purposes of imposing the Medicaid DSH reductions.  Specifically, due to a wide range of structural defects, including unclear and ambiguous instructions, the form does not yet yield fair, accurate, uniform, and audited data, and is not ready to be deployed.  Most importantly, FAH points out, Worksheet S-10 does not define uncompensated care consistent with a policy designed to capture the actual cost of uninsured patients or consistent with Medicaid’s policy of capturing these costs. 

FAH’s comments can be found here

FAH Submits Ideas to Congress to Relieve Statutory & Regulatory Burdens

August 25, 2017 | FAH Policy Blog Team

Category: Health Care Delivery, Medicare

Today, FAH submitted ideas to Chairman Tiberi on how the Ways & Means Health Subcommittee can reduce legislative and regulatory burdens on health care providers and improve care for Medicare beneficiaries. This is the first stage of a three part initiative which includes - requesting feedback from stakeholders; roundtables with stakeholders; and Congressional action. FAH appreciates the opportunity to share our comments with the Chairman, and we look forward to working with the Subcommittee and participating in the upcoming roundtables.

You can read FAH’s comments here.

Modern Healthcare “100 Most Influential” Honors FAH’s Chip Kahn, Several FAH Member Leaders

August 21, 2017 | FAH Policy Blog Team

Category: FAH News

FAH and the leadership of its member companies are strongly represented in Modern Healthcare magazine’s just released 2017 list of the “100 Most Influential People In Healthcare.” This annual ranking uses input from Modern Healthcare readers and the magazine’s senior editors to honor health policy and health care leaders nationwide. Modern Healthcare selected nine FAH leaders for the 2017 list:

  •     #10 Milton Johnson, Chairman and CEO, HCA, Nashville, TN
  •     #17 Trevor Fetter, President and CEO, Tenet Healthcare Corp., Dallas, TX
  •     #28 Chip Kahn, President and CEO, Federation of American Hospitals, Washington, DC
  •     #46 Wayne Smith, President and CEO, Community Health Systems, Franklin, TN
  •     #61 Ben Breier, President and CEO, Kindred Healthcare, Louisville, KY
  •     #73 William Carpenter, Chairman and CEO, LifePoint Health, Brentwood, TN
  •     #77 Jonathan Perlin, President of Clinical Services and Chief Medical Officer, HCA, Nashville, TN
  •     #83 Alan Miller, Chairman and CEO, Universal Health Services, King of Prussia, PA
  •     #98 Mark Tarr, President and CEO, HealthSouth Corp., Birmingham, AL

Mr. Smith, Mr. Fetter and Mr. Kahn are among a group of five individuals who have appeared in the top 100 every single year since the list’s inception 16 years ago.

You can find the complete 2017 list here.

Congratulations to all of the leaders honored this year.

FAH Submits Comments on MACRA 2018 Proposal

August 21, 2017 | FAH Policy Blog Team

Category: Financing, Health Care Delivery

Friday, the Federation of American Hospitals submitted comments to CMS on proposals to update the Medicare Quality Payment Program (QPP) for calendar year 2018. The QPP was created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) and establishes a new framework for physician payment focused on value. FAH letter provides comments on both components of the QPP: the Merit-Based Incentive Payment System (MIPS) and the Alternative Payment Model (APM) Incentive program.

Regarding the MIPS, FAH generally supports the balance CMS strikes in advancing value-based care while providing a glide path for clinician participation. For example, FAH expresses support for the increase in the low-volume threshold, the flexibility for hospital-based clinicians to utilize hospital quality measures, and bonus points for small providers’ complex patients. FAH also recommends improvements in these and other proposals, including allowing clinicians/groups that would be excluded due to the low-volume threshold to opt-in to MIPS participation on annual basis, to allow the use of facility-based measurement as an option rather than a requirement, and to also provide a bonus for rural providers. Additionally, while FAH appreciates CMS’s proposed flexibility regarding the continued use of 2014 Edition or 2015 Edition Certified Electronic Health Record Technology (CEHRT) and the 90-day performance period for the Advancing Care Information (ACI) category, FAH also encourages CMS to further align the ACI category for clinicians with the EHR Incentive Program for hospitals.      

Regarding APMS, FAH reiterates several previous comments, including the need for: more available Advanced APMs; CMS to count providers’ upfront APM infrastructure costs as “risk”; the development and testing of a voluntary bundling program to includes inpatient rehabilitation facilities (IRFs); and a single, overarching waiver for the CMS-led bundled payment programs applicable to the Stark physician self-referral law, the anti-kickback statute, and relevant civil monetary penalties. The comments also urge CMS to proceed cautiously in considering whether to provide a pathway for clinicians to count their participation in Medicare Advantage toward participation in an Advanced APM.

You can read the FAH letter here.

FAH Leader Welcomes CMS Proposal on Bundled Payments

August 16, 2017 | Chip Kahn

Category: Financing, Health Care Delivery

FAH President and CEO Chip Kahn issued the following statement after CMS proposed cancelling the mandatory Episode Payment Model (EPM) and reducing the number of hospitals required to participate in the Comprehensive Care for Joint Replacement (CJR) Payment Model:

“FAH very much welcomes Secretary Price’s thoughtful efforts to reduce the regulatory burden on providers while at the same time advancing innovations in patient care delivery through voluntary demonstration programs under CMMI.  Today’s proposed rule is an important step in the right direction, and we look forward to providing CMS with our comments.”

FAH Leader Looks to the Future of Value-Based Payment in New Health Affairs Blog

August 11, 2017 | Chip Kahn

Category:

Today, Health Affairs published a new blog authored by Federation of American Hospitals’ President and CEO Chip Kahn entitled The Future of Value-Based Payment – Time to Reexamine and Refocus Our Efforts. It looks critically at current hospital payment programs and outlines the challenges that should be addressed to ensure the continued advancement of better and more efficient care across the health care delivery system.

“If we strictly adhere to the current path, Medicare performance measurement could become an exercise in mandated compliance rather than actual performance improvement. Now is the time for stakeholders across the health care sector – from patients to providers to payers to regulators – to pause, reexamine, and refocus our efforts. The refocus begins with targeting measurement to capture what matters most, minimizing burden, and adapting to a transforming delivery system that strives to clinically integrate care,” Kahn wrote.

In the blog, he outlined three areas of focus - measures that matter, return on investment (ROI), and meaningful reporting.

“Taking our experience with measurement, reporting, and pay-for-value programs thus far, we need to engage in the hard work of determining which elements of these programs move us closer to our quality and cost goals and improve our ROI. Only those elements that move us in the right direction should remain and then be aligned to the extent possible across payers and providers.”

Kahn added, “The logical next step in this effort is to acknowledge the need for collaboration across the continuum – payers, patients, providers, regulators – and to develop a platform for moving forward.”

You can read the entire blog by clicking here.

FAH Joins Other Health Care and Business Groups in Support of CSR Payments for Health Care Consumers

August 03, 2017 | FAH Policy Blog Team

Category: Affordable Care Act, FAH News, Insurance

The Federation of American Hospitals joined America’s Health Insurance Plans, American Academy of Family Physicians, American Benefits Council, American Hospital Association, American Medical Association, Blue Cross Blue Shield Association, and U.S. Chamber of Commerce to issue the following statement in response to recent remarks made by the Administration on the funding of cost-sharing reduction (CSR) benefits, which directly benefit health care consumers.

“Cost-sharing reductions are used to help those who need it most—low- and moderate-income consumers. These funds, which are built into their benefits, reduce their out-of-pocket costs such as copayments and deductibles when they receive care. Without these funds, consumers’ access to care is jeopardized, their premiums will increase dramatically, and they will be left with even fewer coverage options.

“These benefits are essential to making coverage and care affordable for American families who receive them. Clarity and commitment to this funding is needed to eliminate confusion and anxiety for consumers.

“As medical professionals, insurers providing health care services and coverage to hundreds of millions of Americans, and business leaders concerned with maintaining a stable health insurance marketplace for consumers, we believe it is imperative that the Administration fund the cost-sharing reduction program.

FAH Members Honored by Modern Healthcare

July 24, 2017 | FAH Policy Blog Team

Category: FAH News, Media

Three people serving in leadership roles at FAH member companies were selected to Modern Healthcare’s “Top 25 Women in Healthcare” and “Women to Watch” lists.

The magazine complies the list every other year and says the “program honors female executives from all sectors of the healthcare system. These high achievers are developing policy, leading change and guiding healthcare delivery improvement across the country. The biennial program recognizes women in a variety of leadership roles, spotlighting their administrative and professional accomplishments.”

Dr. Lynn Simon, who serves as the President of Clinical Services/Chief Quality Officer for Community Health Systems, was named to the “Top 25 Women in Healthcare 2017” list. She was also honored by the magazine in 2015.

Sally Hurt-Deitch, Market CEO of the Hospitals of Providence in El Paso, and Dr. Suzanne White, Executive VP and CMO of Detroit Medical Center, were both named as “Women to Watch.” Each leads Tenet Health facilities.

You can view the complete list here.

Congratulations to all of the leaders honored this year.

FAH Members Selected for Prestigious List by Modern Healthcare

June 29, 2017 | FAH Hospital Policy Blog

Category: FAH News

Three people serving in leadership roles at FAH member companies were selected to Modern Healthcare’s “50 Most Influential Physician Executives and Leaders” list. 

The magazine describes those on the list as, “physicians working in all sectors of the healthcare industry who are steering their organizations and the healthcare delivery system through dynamic, challenging times. These physicians stand out for the scope of their executive responsibilities, personal achievements, innovation and commitment to their communities.”

Representatives from FAH companies include:

  • Ralph de la Torre, Founder, chairman and CEO, Steward Health Care
  • Jonathan Perlin, President of clinical services and chief medical officer, HCA
  • Lynn Simon, President of clinical operations and chief medical officer, Community Health Systems

Modern Healthcare reports that nearly 65,000 people voted in this year’s program.

You can view the complete list here.

Congratulations to all of the leaders honored this year.

FAH Comments on FY2018 Proposed IRF PPS Rule

June 27, 2017 | FAH Policy Blog Team

Category: General, Health Care Delivery

The Federation sent a letter to CMS on Monday commenting on several areas of the agency’s FY2018 proposed Inpatient Rehabilitation Facility (IRF) Prospective Payment System.

Among the things included in the letter is a recommendation that the IRF 60 Percent Rule should be eliminated. FAH notes that the rule is not patient-centered and no longer needed in light of new emerging paradigms of health care.

In addition, FAH commented on proposed code modifications for presumptive testing of compliance with the 60 Percent Rule.

FAH also recommended in the letter that CMS test IRF measures before deploying them in quality programs, accounting for social risk factors, such as sociodemographic status adjustment. The letter also asks that CMS develop a robust and fully transparent methodology for proposed changes and updating the Proposed Collection of Standardized Patient Assessment Data under the IRF QRP.

Finally, in response to CMS’s request for information on program flexibilities and efficiencies, FAH recommended that the agency adopt alternative payment models to allow IRFs to carry more risk, while offering relief from certain regulations, such as the three hour therapy rule.

You can read the entire letter here.

FAH Leader Reacts to Better Care Reconciliation Act Discussion Draft

June 22, 2017 | Chip Kahn

Category: Affordable Care Act, Financing, Medicaid

Most providers and clinicians, including FAH, are deeply concerned by the Better Care Reconciliation Act (BCRA) discussion draft released today.  The opportunity is still there for the Senate to make critical revisions to keep the promise of accessible, affordable health care coverage and ensure Medicaid remains a viable program because it is essential to our most vulnerable neighbors. 

FAH has been explicit about our health reform core principles: maintain coverage levels, reasonable Medicaid structural reforms, sustain affordable, high quality individual coverage, protect employer-sponsored insurance and roll back untenable cuts to hospital reimbursement.  At this time, the BCRA draft does not sufficiently meet those principles which are so important to those Americans our community hospitals serve and our employees who care for those patients every day. Now is the time for the Senate to hit reset and make key improvements to this legislation. 

14 FAH Leaders Nominated for Modern Healthcare’s “100 Most Influential” List – Vote Now!

May 31, 2017 | FAH Policy Blog Team

Category: FAH News

Every year, Modern Healthcare magazine honors industry leaders in its “100 Most Influential People In Healthcare” list.  This annual ranking is based upon input from Modern Healthcare readers and the magazine’s senior editors.

This year, the FAH is proud to announce that Modern Healthcare’s list of 300 nominees includes 13 leaders from our membership, as well as FAH President & CEO Chip Kahn.  Voting is underway and will continue through June 23rd.  We encourage everyone to place their vote and acknowledge the great work of our industry’s leaders.

FAH leaders nominated for the 2017 “100 Most Influential People In Healthcare” list are:

  • Ben Breier, President and CEO, Kindred Healthcare, Louisville, KY
  • William (Bill) Carpenter, Chairman and CEO LifePoint Health, Brentwood, TN
  • Dr. Ralph de la Torre, Chairman and CEO, Steward Health Care System, Boston, MA
  • Trevor Fetter, President and CEO, Tenet Healthcare Corporation, Dallas, TX
  • Sally Hurt-Deitch - Market CEO, Hospitals of Providence, El Paso, TX
  • R. Milton Johnson, Chairman and CEO, HCA, Nashville, TN
  • Chip Kahn, President and CEO, Federation of American Hospitals, Washington, DC
  • Alan Miller, Chairman and CEO, Universal Health Services, King of Prussia, PA
  • Tom Miller, CEO, Quorum Health Corporation, Brentwood, TN
  • Dr. Jonathan Perlin, President of Clinical Services and Chief Medical Officer, HCA, Nashville, TN
  • Wayne Smith, Chairman and CEO, Community Health Systems, Franklin, TN
  • Mark Tarr, Chairman and CEO, HealthSouth Corporation, Birmingham, AL
  • Tony Tedeschi - CEO, Detroit Medical Center, Detroit, MI
  • W. Carl Whitmer, President and CEO, IASIS Healthcare, Franklin, TN

You can learn more about Modern Healthcare’s awards on its recognition page.  Voters are required to vote for exactly five nominees.  Don’t forget to vote now!

FAH Sends Chairman Hatch Letter Outlining Health Reform Principles

May 23, 2017 | FAH Policy Blog Team

Category: Affordable Care Act, Insurance, Medicaid, Medicare

The Federation of American Hospitals submitted a letter to Chairman Orrin Hatch (R-UT) and the Senate Finance Committee Tuesday outlining core principles for lawmakers to consider during the health care reform debate.

Chairman Hatch recently asked key stakeholders to share their ideas about what should be included in the Senate's reform legislation.

FAH President and CEO Chip Kahn wrote:

“We hope you will focus your attention on sustaining the protections people have today, including coverage gains in the individual market and Medicaid, while you explore opportunities to expand coverage to those Americans who continue to lack it.

“Along those lines, the FAH has adopted a set of core principles on Medicaid, financial assistance in the individual market, coverage, Medicare hospital payment and employer sponsored coverage – principles which we hope the Senate will follow, and which will guide our consideration of proposed legislation.”

More details about FAH’s principles can be found in the letter.

Kahn also reiterated the Federation’s desire to work with policy makers to craft a patient-centered health reform bill.

FAH Leader Reacts to Release of Administration’s Budget

May 23, 2017 | Chip Kahn

Category: Health Care Delivery, Medicaid

The hospitals that Americans depend on need sufficient resources to ensure care.  The Administration’s budget proposal released today would make it harder for hospitals to meet the needs and expectations of patients.  Proposed cuts to Medicaid and the social safety net of this magnitude are not reform.  We hope the Congress will take a different direction as it progresses through the budgeting process.  

Standing up for Rural Hospitals

May 19, 2017 | Chip Kahn

Category: FAH News, Quality, Rural

Temperatures are heating up, classes are winding down and the Memorial Day Weekend is almost here – all sure signs that summer is almost here. The auto club AAA estimates that over the next few days nearly 40 million people will get away to the beach, the lake or the mountains looking to cool off and relax!

You may be miles away from the city, but you can rest easy knowing quality care is still nearby. Rural hospitals are there to take care of visitors and locals – 24/7/365.

We at the Federation of American Hospitals think this is the perfect time to celebrate Rural Hospitals Week. From May 22nd to May 26th we will be highlighting the positive impact these facilities have – not just for the patients they care for, but also the communities they serve.

When you hear rural community you think small town, but add up the population of these areas across the country and it equals nearly 60 million people, or one in five Americans.

At the heart of many of those communities is the local hospital.

The most obvious benefit they provide is also the most vital: timely, quality care. Whether you need emergency treatment or have a scheduled routine procedure, the presence of a hospital in these community saves lives. When seconds matter most, having essential health care minutes away, instead of hours, can mean the difference between life and death.

But the impact to a community extends far beyond medical capabilities. In many rural areas the hospital is the largest or second largest employer in the area. It also contributes to job creation throughout a community. A recent study by the American Medical Association said that “each physician supports almost 14 jobs and adds more than $2 million in economic input, on average.” Those aren’t just jobs in the hospital or doctor’s office, they include restaurants, dry cleaners and day cares. I bet you would be hard pressed to find a business in a rural area that isn’t touched in some way by those who work for or get treatment at one of these facilities.

Rural hospitals are vital to keeping a community healthy – physically and fiscally. The goal of Rural Hospital Week to raise awareness of their impact nationwide. Spreading the word from Main Street to the halls of Congress. You can help by joining the conversation on social media. Follow the Federation on Facebook, Twitter and Instagram to see stories of success and discover what these facilities mean to a community.  Please check out our new infographic here.  Hospitals in rural areas have a big impact on our nation’s health care system so join us this week as we #StandUp4RuralHospitals.

Medicare Hearing: An Important First Step in Protecting Patient Care

May 18, 2017 | FAH Policy Blog Team

Category: Medicare, Rural, Sequester

FAH appreciates the leadership of the House Ways and Means Health Subcommittee, specifically Chairman Tiberi and Ranking Member Levin, for holding a hearing about the importance of the Medicare program – present and future. Now more than ever, hospitals need policymakers to stand up for our patients and ensure hospitals will be there for our communities.

Our mission is to care for anyone that walks through the door, day or night, but these uncertain times are forcing difficult decisions on scaling back staff and services – ultimately hurting the people and places we serve.

The long list of financial threats facing hospitals includes MedPAC’s estimate that overall Medicare margins will hit an all-time low once again this year – bottoming out at negative ten percent.

The commission has noted the challenges created by the Medicare sequester. In a recent report to Congress MedPAC argues against the Medicare sequester saying, “it reduces payments across all sectors by 2 percent without regard to payment adequacy.”

Lawmakers also need to address the so-called ‘rural extenders.’ This unique payment structure helps facilities in less populated areas keep their doors open. Without that support – millions of Americans could have their access to care reduced.

Current events only compound past actions. Estimates show that past Congressional and Executive Branch moves have led to cuts that total $148 billion from 2010 to 2026.

This confluence of financial factors led to Congressional Budget Office to say in a recent report that by 2025 between 40% and 50% of hospitals could have negative margins.

Enough is enough – if hospitals are pushed past the brink financially it hurts patients, employees and entire communities.

Today’s hearing was an important first step. FAH looks forward to working with lawmakers as we work to make Medicare provides patients the care they need and deserve.

You can watch the hearing by clicking here.

FAH Leader Applauds Administration’s Regulatory Reform Efforts, Submits Recommendations

May 17, 2017 | Chip Kahn

Category: Financing, General, Medicaid, Medicare

 “When regulations start hindering care instead of helping people - we have a problem.

“Caregiver focus should be on the patient, not outdated or ineffective bureaucratic mandates.

"The letter we are sending today highlights action that HHS could take to implement regulatory reform across a variety of areas, including alternative payment models, Medicaid, hospital and post-acute payment policies, and quality measurement and reporting.  For example, HHS should ensure that the Center for Medicare & Medicaid Innovation (CMMI) acts only within its designated authority to voluntarily test alternative payment models, not make permanent or mandatory changes to the Medicare program. HHS also should indefinitely suspend the troubled Hospital Star Ratings system while the Agency collaborates with stakeholders on appropriate risk adjustment. Additionally, HHS should provide hospitals with flexibility to relocate their provider-based departments to meet community needs and still retain hospital outpatient payments."

"FAH members believe a comprehensive review and repeal or revision of regulations that are obsolete, ineffective, or otherwise overly onerous will further our shared goals of improving health outcomes and efficiencies in care delivery.”

“We appreciate the Trump Administration asking for our input and the leadership of the President, Secretary Price and Administrator Verma on this issue. This executive order is has started a critically important dialogue that we hope will ultimately improve the quality of care for patients.”

You can click here to read the letter.

Connecting Care to You

May 14, 2017 | Chip Kahn

Category:

It is a dynamic time in Washington. A new Administration and new Congress means a fresh look at health care and especially how it’s delivered.  The perfect time to more fully embrace the benefits of telehealth.

Telehealth isn’t new, it’s just, unfortunately, underutilized – primarily due to health law and regulations that have bottled up its potential.  But, thanks to constantly improving and increasingly familiar and accessible technology – the scope of how it can improve lives is expanding faster than ever before.

Assessment, consultation, treatment management and education between provider and patients are all now possible without the two being in the same room or even the same state.

Hospitals in both rural and urban settings are investing in telehealth technologies because they appreciate the benefit to patients, ultimately helping to address inequities in access to care, containment of health care cost growth, and enhancement of quality.   Clearly, telehealth is a critical catalyst to innovation in health care that will improve patient lives and lower costs.

However, as referenced earlier, legislation and regulation have historically lagged behind. The good news is there are committed policymakers striving toward improvement.

The recently introduced CONNECT for Health Act is the perfect example. This bipartisan, bicameral bill is designed to expand the use of technology and remote patient monitoring in the Medicare program.  The CONNECT for Health Act is one of the first major pieces of legislation that would thoughtfully expand the use of telemedicine and remote patient monitoring services in the Medicare program, which is essential to the expansion of services provided in hospitals.  For example, helping diabetes patients monitor their chronic condition or making it more likely that patients with pacemakers recover after surgery and thrive long afterward are important clinical improvements made easier to achieve with passage of this legislation.    

As policymakers consider opportunities to improve the delivery of services via telehealth, the Federation of American Hospitals is releasing a new infographic and the following principles we hope will guide future legislative and regulatory activity:

  • Medical and behavioral health services that can be appropriately delivered via telehealth technology should be reimbursed by Medicare, Medicaid, private insurance, and other payers at the same level as when those services are delivered in person
  • Support efforts for providers to participate in multi-state telehealth programs
  • Originating site restrictions should be updated continually as new technologies develop with the goal of eliminating originating site restrictions in order to make telehealth services available to patients where most convenient for them
  • Access for telehealth services should not be restricted by geography, and all patients, whether in rural, suburban or urban areas, should be able to avail themselves of medical and behavioral health services via telehealth
  • Reimbursement should not discriminate based on the technology used and should encourage the use of real-time secure bi-directional audio and video, home health monitoring technologies, store-and-forward technologies, and other synchronous, asynchronous, and remote monitoring technologies
  • The federal government should take steps to remove Medicare’s restrictions and expand reimbursement of telehealth services, and ensure they conform to the above principles
  • The federal government, through its role in oversight of the Medicaid program, should encourage states to broadly adopt telehealth services in state Medicaid programs
  • Health care providers and practitioners engaged in the delivery of services via telehealth should continually strengthen safeguards that ensure the privacy and security of patient data 

The FAH and its more than 1,100 investor-owned or managed hospitals and health systems throughout the United States will continue to work with lawmakers and federal agencies to expand the use of and access to telemedicine for patients and providers.

FAH Celebrates 2017 National Hospital Week

May 08, 2017 | FAH Policy Blog Team

Category: FAH News, General, Media

Hospitals across the country and their millions of employees work diligently to provide quality care to patients 24/7/365.

Much of the time their hard works goes unnoticed, but not this week. National Hospital Week is a chance for us all to say thanks! This year’s celebration runs from May 7th to the 13th and the theme is “The Healing Heart of Healthcare.”

The FAH and its member hospitals are proud to join other health care industry leaders to acknowledge the critical work hospitals perform caring for patients. We take this week each year to show our appreciation to the dedicated physicians, nurses, therapists, clinicians, engineers, custodial workers, food service workers, volunteers, and administrators who keep hospitals operating all day, every day to care for anyone who walks through their doors.

As the theme for this week suggests, the hospital is more than just a building – it is the “heart” of the community. It is the commitment of the people working inside that make it all possible.

Hospitals also are a strong economic pillar and provide jobs to numerous people in their communities.

The FAH extends its gratitude to the dedicated and compassionate professionals who care for millions of patients each day.

 Please share this graphic on social media and join us in showing support using the #HospitalWeek.

FAH Leader Reacts to House Passage of AHCA

May 04, 2017 | Chip Kahn

Category: Affordable Care Act, FAH News, Health Care Delivery

"Republicans have set their sights on repealing and replacing the ACA so today’s vote is disappointing, but not surprising.  As passed by the House of Representatives, the AHCA fails to protect the health coverage and access to care for so many Americans. It also makes it more difficult for hospitals to deliver the care we all rely on. With these concerns top of mind, FAH could not support the House legislation today.

"We are committed to engaging in a forward looking dialogue with policy makers as the process moves to the Senate.

"As caregivers our policy goals are simple: to ensure that the health care delivery and financing legislation improves access to health coverage for Americans with individual insurance; protects and strengthens the Medicaid program for the most vulnerable – especially in rural areas where more people depend on the program; and restores needed Medicare funding so community hospitals have sufficient resources to continue to deliver high quality care to seniors, the disabled, and the uninsured among us."

Millions of Low Income Americans Depend on Marketplace CSRs

May 02, 2017 | Chip Kahn

Category: Affordable Care Act, Financing, Insurance

Summer is right around the corner.  June 21st, to be exact.  Many Americans probably don’t pay much attention to that date, other than waiting for those warm summer days.  But it should be circled on our calendars this year because it is the day on which health insurers must decide whether to participate in Obamacare Exchanges for 2018.

That decision hinges in no small part on the availability of the Affordable Care Act’s (ACA) Cost Sharing Reduction (CSR) payments that help lower income Americans afford their health insurance.  For those not following this closely, the availability of those payments both in the short and long term has been called into question.  

The Trump Administration has signaled the availability of those payments in the short-term – recently announcing that it will continue funding the CSRs temporarily. That’s a good first step. But insurers – and their customers – need greater certainty. They need to know that the CSRs are going to be at least available for the remainder of 2017 and through 2018.  The consequences for people who buy insurance in the Exchanges cannot be understated.  CSRs provide critical help for those who need it most by reducing out-of-pocket costs like deductibles and co-payments. Without them, consumers face two possible outcomes – insurers will either leave the marketplace or be forced to raise their rates. Both options short change low and middle income folks, leaving them with either fewer choices or higher costs.

Need proof? A recent study by Covered California estimates that premiums in that state could go up as much as 11 percent if CSRs disappear. And it won’t just hurt those who depend on the funding. Researchers at the Kaiser Family Foundation say eliminating CSRs could cost the government $2.3 billion more next year than just paying for them.  In other words, taxpayers would needlessly be paying more for the same product and that just doesn’t make fiscal sense.

No matter what happens this week with the American Health Care Act, without some certainty on CSRs, the availability and cost of health coverage will become unpredictable in the months and years ahead.  The consumers in the insurance marketplace need the injection of stability that guaranteeing this funding provides so they know that month-in-and-month out, the care they count on will be there for them.  In order to protect access to affordable coverage and access to high-quality care provided by hospitals, physicians and nurses, policy makers must fund CSRs through 2018 while they work on a more permanent solution.

FAH Responds to Request for Information in the 2018 Rate Announcement and final Call Letter

April 24, 2017 | FAH Policy Blog Team

Category: Medicare

The Federation of American Hospitals (FAH) submitted comments to the Centers for Medicare & Medicaid Services (CMS) April 24th in response to a Request for Information in the 2018 Rate Announcement and final Call Letter (“Call Letter”) for Medicare Advantage (MA) and Part D Prescription Drug Programs.

The FAH letter underscored the need for robust oversight by CMS over MA program policies and their impact on stakeholders, as well as the need for adequate time to review and comment on policy proposals.

Key comments relate to issues such as enrollee access to quality medical care, including adequate provider networks offered to MAO enrollees. Beneficiaries often face restrictions and confusion when MAOs contract with downstream providers that have a far narrower network than depicted in the MAO provider directory or when MAOs engage in mid-year network changes through provider contract terminations. FAH also encouraged CMS to ensure network adequacy for post-acute care, including inpatient rehabilitation services. 

Other FAH comments discuss the adverse impact of out-of-pocket cost-sharing policies on providers, and urged CMS to monitor and accurately measure Medical Loss Ratio for Part C plans.

Read the entire letter here.

FAH Comments on CMS Rule Proposing Delay of Cardiac Bundling Rule

April 19, 2017 | FAH Policy Blog Team

Category: Medicare

In comments to CMS on April 19th, the FAH argued for delaying the Episode Payment Model (EPM) Bundling Rule to no sooner than January 1, 2018.  In a proposed rule issued in late March, CMS delayed the implementation of the EPM model until October 1, 2017 and requested comments on a further delay to January 1, 2018.  

As CMS noted it would use the delayed implementation to evaluate the model, the FAH took the comment opportunity to reiterate a number of key concerns it has shared with the Agency in the past.  Specifically, the FAH urged CMS to reconsider its use of mandatory models and instead convert those models to voluntary participation.  Additionally, the FAH urged CMS to make necessary data available prior to model implementation, make key changes to episode length, downside risk and quality metrics, and better integrate post-acute care providers, like IRFs, in the model. 

The FAH’s letter can be viewed here.     

Looking to the Future of Value Based Payments

April 18, 2017 | Chip Kahn

Category: Health Care Delivery, Quality, Transparency

Measures that matter, return on investment, and meaningful reporting – these are three things our industry needs to focus on as we look to the future of value based payments.

Today, I joined experts from all sectors of the health care continuum as we discussed “Securing the Future of Value Based Payment” before a crowd of almost 300 at a Health Affairs Forum. In thinking through the future of value based payment, there are two key questions that need to be considered:

First - are we focusing on measures that matter? And second, if we can get the measurement right, can we adopt a platform that deploys those measures across health care settings to inform patient care and improve accountability, while at the same time reducing the current redundancies and inefficiencies?

From my viewpoint, the answer to the first question is not enough.

We do have a few measures that matter. They include the reduction of elective deliveries before 39 weeks and readmissions measures, the latter of which are flawed, but have brought attention to an area where we have achieved great improvement.

The answer to the second question is that our industry still lacks a process that ensures consistent measurement across patient care settings and value based payment programs.

Instead, we have a Balkanized quality measurement and reporting process. Clinicians and providers are currently required to collect similar data elements for reporting on different measures and measure specifications for different value based payment programs and systems in both the public and private sectors. This variation is arbitrary and diverts attention and resources from what is most important – improving patient care by using effective performance data.. 

I believe if we truly focus on measures that matter we can bring a return on investment for patients, caregivers, payors and purchasers.

Of course, return on investment (ROI) is a classic business term, not something usually associated with health care. Rather than thinking of it as a purely financial metric about money earned relative to the costs of an investment, I think its meaning can be stretched to the performance measurement space.

In this context, the investment is the time and resources and resulting improvement efforts.  In other words,– currency and human capital – that those in health care contribute to collecting, reporting, and analyzing the data, as well as the result of improved patient care. 

The return should meet the three measurement purposes that have the most meaningful impacts on all stakeholders – improved care, accountability, and transparent/useable information.

Focusing on ROI also reframes the current measurement discourse around reducing burden.  Burden is an important consideration that we should strive to reduce – and eliminate when there is no ROI – but it is one part of the equation, not the sole focus.

If we can agree on the purposes of measurement and the desire to improve ROI across the system, then what is the best platform to align the needs of various stakeholders in developing, disseminating, and utilizing these measures?

My experience with the National Quality Forum’s (NQF) Measure Applications Partnership (“the MAP”) tells me that it is possible to develop a platform to serve that role. The MAP already includes the key elements for success, including multi-stakeholder involvement and a public/private partnership. To fill the role I’ve laid out here, it would need to expand from federal programs, such as Medicare and Medicaid, to include those in other public and private spheres as well.

This would of course require buy-in from a wide array of stakeholders, including industry-led groups. To achieve success, we would also need broader participation, more formalized rules of the road, and increased transparency.

For this to work, we must also address the variation within the health care system. We need uniform measures to the extent possible, but they must balance the differences among providers with the ability to compare across settings and systems.

Meaningful reporting – aligning the use of measures across payors – is one way to move us toward measures that matter and free up energy and resources that caregivers can use to innovate patient-centered care delivery.

So if we agree on the goals of measurement, the need for tangible ROI, and the process for moving forward, this could create a solid platform for the next step – reassessing current federal payment programs to ensure they align with the overall goals and work that already is being done in many states. 

This forum was a great venue to continue the discussion. It is clear that it is now time to pave the way for more refined, focused, and purposeful value-based programs.

FAH Joins Other Groups in Urging that Health Coverage be Stabilized

April 12, 2017 | FAH Policy Blog Team

Category: Health Care Delivery, Insurance, Media

The Federation of American Hospitals and seven other groups sent a letters to President Trump and Congressional leaders today asking them to protect access to care for millions of Americans by quickly stabilizing the individual insurance market.

The groups all agree that the best way to do this is by funding the cost sharing reductions or CSRs, which help nearly seven million people by reducing deductibles, co-payments, and out-of-pocket costs.

FAH President and CEO Chip Kahn stated:

“Everyone – no matter their financial situation – should have access to affordable, quality health care. Cost sharing reductions can make this a meaningful reality for millions of low income Americans. Without funding of the CSRs by Congress and the Administration, there could be a ripple effect in the individual insurance market raising coverage costs for everyone.”

“The coalition behind this letter shows united support for funding this important lift up for low income Americans. We stand ready to work with policy makers to find a solution and urge the Congress and Administration to take action”

A copy of the letter to President Trump can be found here.

A copy of the letter to Congressional leaders can be found here.

It is signed by the Federation of American Hospitals, America’s Health Insurance Plans, American Academy of Family Physicians, American Hospital Association, American Benefits Council, Blue Cross Blue Shield Association, the American Medical Association and the U.S. Chamber of Commerce.

FAH Leader Praises Reintroduction of Bipartisan, Bicameral Rural Hospital Bill

April 06, 2017 | Chip Kahn

Category: Health Care Delivery, Rural

“This legislation is vital to the health of rural hospitals across America. It provides them critical financial support that allows hospitals in small communities to focus on what matters most – quality patient care.

“Rural hospitals are a lifeline for millions of Americans. These facilities are often the largest employer in a community, and drive the local economy.  Without local community hospitals, rural patients would have to travel long distances, adversely impacting access to essential, timely care. Additionally, local businesses expect there to be hospital care for a community to thrive.  When these hospitals close, the effect radiates.

FAH applauds these members for their leadership and their efforts to protect rural hospitals. We look forward to working with them to ensure this legislation becomes law. It is time for Congress to make a permanent commitment to rural communities.”

FAH Leader Reacts to House Consideration of AHCA

March 24, 2017 | Chip Kahn

Category: Affordable Care Act, FAH News, Legislation

“As the Congress regroups after the consideration of the American Health Care Act, we hope moving forward that policy makers will focus on improving access to affordable health care coverage for Americans, protect and strengthen the Medicaid program for the most vulnerable, and restore needed Medicare funding so community hospitals have sufficient resources to continue to deliver high quality care to seniors and the disabled.

“If the Congress chooses to go back to the drawing board on ACA repeal and replace legislation in the future, it is important that a recrafted plan puts patients first. We stand ready to work with lawmakers on next steps.”

FAH Leader Reacts to Delay of Mandatory Bundles

March 20, 2017 | Chip Kahn

Category: FAH News, Financing, Quality

FAH President and CEO Chip Kahn issued the following statement after HHS announced today that it was delaying and seeking comment on the implementation of the mandatory cardiac bundle program as well as the expansion of the current mandatory joint replacement bundle program:

“We so appreciate Secretary Price’s decision to delay these bundled payment programs and welcome a fresh set of eyes on these policies. Taking the time to get the policy right is what is most important.

“We support efforts to test and evaluate innovations in care delivery and payment. However, the impact of these policies on our patients is paramount and we look forward to working with the new leadership at HHS and CMS as they consider them further.”

FAH Welcomes Erin Richardson, New Vice President and Associate General Counsel

March 15, 2017 | Chip Kahn

Category: FAH News

The Federation of American Hospitals is pleased to announce the addition of Erin Richardson as Vice President and Associate General Counsel. It is gratifying to have Erin join our staff.

I first met her when I was chair of the Winston Health Policy Fellowship Program. We were fortunate enough to have Erin as one of our fellows and after her year in the program, she went on to serve in vital roles both on Capitol Hill and at the White House.

Her variety of experience has given Erin a unique perspective and a deep understanding of the intersection of politics and health policy.

I am confident she will now assume an important role in the work of FAH for its 1,000 hospitals, as well as the patients our members serve.

Before joining the Federation, Erin served at the White House Domestic Policy Council, focusing on Medicare and delivery reform. Prior to that she was health counsel for the Ways and Means Health Subcommittee. Erin also worked for Way and Means during her time as a Winston Health Policy Fellow. She additionally served as Legislative Assistant for Health for Sen. Sherrod Brown of Ohio.

Erin earned a Bachelor of Arts in English from Wellesley College, a Masters of Arts in Bioethics from Case Western Reserve University, and a law degree from Columbia University.

Keith Pitts Receives FAH’s Mike Bromberg Lifetime Achievement Award

March 06, 2017 | Chip Kahn

Category: FAH News

The Federation of American Hospitals was honored to give its newly named Mike Bromberg Lifetime Achievement Award to Tenet Health’s Keith Pitts on Monday morning.

Keith Pitts has worked in the hospital industry for more than 40 years. During that time, he has come to be recognized as one of the most influential figures in our sector.  He devoted his professional career to the nation’s healthcare delivery system and to the patients we serve.  He has represented the investor-owned hospital community with distinction, and is known for finding solutions using his keen business and common sense.  Keith is a three-time Chairman of the Federation and a longtime board member.

He is also a valued member of his community, giving generous amounts of time and support to various charitable causes.

Keith shares many qualities with the man whose name is now on this award. Mike Bromberg passed away in 2016. Mike ran FAH from 1969 to 1994 and remained active with our organization until the time of his passing. He also started his own consulting firm, Capitol Health Group, after leaving FAH. His long history of working in a bipartisan way to expand health care coverage led The Washington Post to once call him “dean of Washington health lobbyists.”

The current Board of Directors voted in October 2016 to name the FAH Lifetime Achievement Award after Mike as a way to honor is contributions to the health care industry.

I sincerely congratulate Keith on receiving this much deserved award. 

FAH Presents Annual Corris Boyd Leadership Award to Marsha Powers

March 06, 2017 | FAH Policy Blog Team

Category: FAH News

Today, the FAH presented Marsh Powers, the CEO, Eastern Region – Coastal Division of Tenet Healthcare, with the 11th annual Corris Boyd Leadership Award.  Powers was honored during the Opening Plenary Session of the FAH Annual Meeting being held in Washington, DC.

Presenter Jerry McKinney, Chairman of the FAH Exposition Advisory Committee, described Powers as, “a unifier who encourages employees at all levels to contribute to enhancing patient care and the patient experience.”

Powers is the CEO of Tenet Health’s Eastern Region – Coastal Division, which encompasses 10 hospital providers spanning South Florida from Miami-Dade to Palm Beach counties. And just this year – her area of responsibility expanded to hospitals in South Carolina and Massachusetts.

Her dedication to patient care is a big reason why her hospitals have won more than 250 quality awards.

Powers is also active in her community back home and in our industry – serving on the University of Florida board of trustees and the Federation’s Board of Governors.

She is an amazing example of what our industry strives to achieve.

The Corris Boyd Leadership Award honors an individual or company that has made an outstanding contribution in fostering leadership in the health care industry.   The FAH established the Corris Boyd Leadership in 2007 to honor the late Corris Boyd, who spent his career working with hospital management companies and group purchasing organizations.  Corris Boyd committed his life to diversity and excellence in health care. He believed that leadership development is crucial to success and was devoted to the success of minority- and women-owned business enterprises.

The FAH is honored to present Marsh Powers as the 2016 Corris Boyd Award winner, and extends its thanks for her outstanding work which embodies the ideals the award represents.

FAH Comments on 2018 Medicare Advantage Call Letter

March 03, 2017 | FAH Policy Blog Team

Category: Medicaid, Medicare

The Federation of American Hospitals (FAH) submitted comments to the Centers for Medicare and Medicaid Services (CMS) today regarding the Advance Notice of Methodological Changes for Calendar Year (CY) 2018 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2018 Call Letter ("Call Letter").

FAH is pleased that the agency is proposing to increase MA Organizations’ (MAOs) baseline payments, but has several issues with other proposals laid out in the Call Letter.  Adoption of adequate payment policies is critical for ensuring enrollees’ access to quality health care services.

The comment letter outlined the expansive growth of the MA program, which now covers almost 34 percent of the eligible Medicare population, and noted that this growth gives MA program policies a far-reaching effect on patients and providers, and thus a need for robust oversight by CMS over MA program policies and their impact on stakeholders.

FAH made numerous recommendations regarding key provisions in the Call Letter that we believe will promote enrollee access to quality medical care, including adequate provider networks offered to MAO enrollees. 

Key comments relate to issues such as MAOs’ excessive use of observation status and inappropriate denials of hospital inpatient admissions, in conflict with policies in traditional Medicare.  These practices affect beneficiary access to care and out-of-pocket cost-sharing.

Other key issues addressed by FAH include MAO readmissions policies that result in double penalties for hospitals, and restrictions and related confusion for patients when MAOs contract with downstream providers that have a far narrower network than depicted in the MAO provider directory.

FAH encouraged CMS to use its audit protocols to ensure that these directories accurately describe the provider network, as well as ensuring network adequacy for post-acute care, including inpatient rehabilitation services.  Other FAH comments discuss the adverse impact of out-of-pocket cost-sharing policies on providers, and urged CMS not to incorporate dismissals in a Star Rating System measure regarding the effectiveness of an MAO in resolving beneficiary appeals of MAO determinations. 

The final MAO Rate Announcement and Call Letter for 2018 will be issued by CMS on April 3, 2017.

Seema Verma is the Right Choice at the Right Time

March 01, 2017 | Chip Kahn

Category: FAH News, Health Care Delivery, Medicaid, Medicare

Medicare and Medicaid have seen many changes since the programs were created more than five decades ago – from the people they cover to the way benefits are administered.

However, there has been one constant – smart, savvy leaders in charge with an unwavering commitment to the best interests of the program’s beneficiaries.

It isn’t easy to lead the agency that runs these programs - now known as the Centers for Medicare and Medicaid (CMS). During my 40 years in health care policy, I have known and had the privilege to work closely with each of the CMS Administrators and seen them navigate countless political and policy pitfalls. I believe our nation has been fortunate to always have leaders at the Agency of the highest quality and integrity whose knowledge and abilities seemed to always fit the times.

Seema Verma, the current nominee for CMS Administrator, is no exception. I am confident she has both the background and the temperament that fits these times.

Throughout her career, she has brought people of all political stripes together to solve complicated health care problems. Ms. Verma is a pragmatist who understands the real effects of policymaking on families and patients.

We are clearly heading toward a re-examination of the Medicare and Medicaid programs and our guiding principle should continue to be to assure we maintain access to high quality health care for seniors and low-income Americans. Reform is no simple task. President Trump, Secretary Price and the nation will be well served by an individual with Ms. Verma’s policy expertise and extensive professional experience. I believe she will move us forward fairly and effectively.

During her confirmation hearing before the US Senate Finance Committee, Ms. Verma revealed an understanding of the gravity and importance that the role the CMS Administrator plays in our health care system. In her opening statement she stated: “I humbly accepted President Trump’s call to service because I understand what is at stake. I have never stood on the sidelines of our nation’s health care debate, merely pointing out what is wrong with our health care system. I have spent my entire life helping the most disadvantaged in our society receive the kind of accessible, affordable and competent health care service that our country’s healthcare system is renowned for.”

We are fortunate that someone with Seema Verma’s ability and commitment has agreed to accept this challenge. We need her to be confirmed as CMS Administrator quickly so she can get to work and start doing what she has done her entire career – bring people together to improve health care quality and access for our families and patients.

Hospital Groups to Congress: Maintain Ban on Self-Referral to Physician-Owned Facilities

February 24, 2017 | FAH Policy Blog Team

Category: Affordable Care Act, Medicaid, Medicare

The Federation of American Hospitals (FAH) and the American Hospital Association (AHA) sent a joint letter to each member of the House and Senate on Friday urging them to oppose any legislation that would repeal or modify current law to expand self-referral to physician-owned hospitals.

FAH and AHA specifically called out H.R. 1156, the “Patient Access to High Quality Health Care Act of 2017,” which was recently introduced in the House. Companion legislation is expected soon in the Senate.

Contrary to the name on the House bill, loosening the law on physician-owned hospitals would harm patients, community hospitals and local businesses. FAH and AHA point out that these arrangements lead to over utilization and higher health care costs.

“Conflicts of interest are inherent in these arrangements, whereby physicians refer their patients to hospitals in which they have an ownership interest. Seven years ago, after a decade of studies and congressional hearings showing the adverse impact of these arrangements, Congress acted to protect the Medicare and Medicaid programs and the taxpayers that fund them by imposing a prospective ban on self-referral to new physician-owned hospital,” the letter states.

To prove the point, FAH and AHA highlighted the recent analysis of the health care economics consulting firm Dobson|DaVanvo. The firm compared the performance of non-physician owned full-service community hospitals with physician-owned hospitals identified on the Physician Hospitals of American public facing website.

Among the findings, physician-owned hospitals:

  • cherry-pick patients by avoiding Medicaid and uninsured patients;
  • treat fewer medically complex patients;
  • enjoy all-payer margins nearly three times those of non-physician owned hospitals;
  • provide few emergency services – an important community benefit; and
  • are penalized for unnecessary readmissions at 10 times the rate of non-physician owned hospitals.

“The empirical record is clear that these conflict-of-interest arrangements of hospital ownership and self-referral by physicians result in cherry-picking of the healthiest and wealthiest patients, excessive utilization of care, and patient safety concerns,” wrote FAH and AHA.

The letter to Congress concludes, “The law as it stands protects patients, businesses and taxpayers. It also helps ensure that full-service hospitals can continue to meet their mission to provide quality care to all the patients in their communities. We urge you to oppose any and all attempts to weaken it.”

ICYMI: FAH Leader Addresses Challenges, Advantages of Telehealth in Modern Healthcare Op-Ed

February 22, 2017 | FAH Policy Blog Team

Category: FAH News, Health Care Delivery, Quality

In an op-ed published in this week’s Modern Healthcare, FAH President and CEO Chip Kahn talked about telehealth – from the advantages it provides patients to the challenges it faces legislatively.

The piece, which was entitled “The feds hold the key to telehealth's untapped potential,” highlights real world examples of how telehealth is advancing patient care, including live video consultation and remote monitoring.

But Kahn also discussed the roadblocks to innovation.

“Unfortunately, patients are not able to take advantage of the full range of these technological advances because the federal government hasn't kept pace. Steps taken over the years by Congress and government agencies have cracked the door to innovation, but open it wider and even more can be accomplished,” he wrote.

Adding, “As new HHS Secretary Dr. Tom Price starts his second week on the job, he has the opportunity to help telehealth fully achieve its promise. His department has the power to remove some of the roadblocks to innovation and start us down a path that forever changes the delivery of care.”

Kahn wrapped up the piece urging people to take action,

“The healthcare industry and the federal government cannot afford to miss the opportunities telehealth presents. We owe it to patients to adapt to these new technologies so we can continue to improve care.”

Analysis Highlights Need to Maintain Law Banning Self-Referral to Physician-Owned Hospitals

February 16, 2017 | FAH Policy Blog Team

Category: FAH News

For more than fifteen years, community hospitals, policymakers, the business community and governmental advisory bodies have grappled with overutilization and higher health care costs caused by self-referrals to physician-owned hospitals. Conflicts of interest are inherent in these arrangements, where physicians refer their patients to hospitals in which they have an ownership interest.  More than seven years ago, after a decade of studies and Congressional hearings showing the adverse impact of these arrangements, Congress acted to protect the Medicare and Medicaid programs, and the taxpayers that fund them, by imposing a prospective ban on self-referral to physician-owned hospitals.

Nevertheless, groups like the Physician Hospitals of American (PHA) continue to attempt to unwind the law.  This would harm patients, community hospitals, and local businesses.  Proponents of weakening the law often argue that the underlying data that fueled congressional action is out-of-date and current data no longer supports the earlier findings. 

A recent analysis conducted by the health care economics consulting firm Dobson | DaVanzo refutes that argument and presents new findings that reinforce the reasons why Congress acted.  

What the Data Shows

The Dobson | DaVanzo statistics compares the performance of non-physician owned full service community hospitals with physician-owned hospitals identified on PHA’s public-facing website.  It provides a clear picture that the characteristics of these PHA hospitals virtually mirror the findings and data collected in the early-to-mid 2000’s that drove Congress to enact the law prospectively banning self-referral to these facilities.  Among those findings, physician-owned hospitals:

  • cherry pick patients by avoiding Medicaid and uninsured patients; 
  • treat fewer medically complex patients;
  • enjoy all-payer margins nearly three times non-physician owned hospitals;
  • provide few emergency services, an important community benefit; and
  • experience the maximum readmission penalty at ten times the rate of non-physician owned hospitals .  

Physician-owned hospitals still cherry pick – PHA members largely avoid Medicaid, uninsured, dual-eligible and medically complex patients.

Physician-owner referrals result in the “cherry picking” of patients. Analyses previously conducted by both GAO and MedPAC clearly found that physician owned specialty hospitals avoided lower-income or non-paying patients.  

“Specialty hospitals uniformly denied selecting cases based on payer mix but the specialty hospitals we visited had much lower Medicaid shares and provided less uncompensated care. One physician told us the specialty hospital had used the lack of uninsured patients as a marketing pitch to him.” (MedPAC staff, transcript, pg. 179, September 2004)

“Relative to general hospitals in the same urban areas, specialty hospitals in our HCUP sample tended to treat a lower percentage of Medicaid inpatients among all patients with the same types of conditions.” (GAO-04-167 (October 22, 2003), pg. 20, "Specialty Hospitals: Geographic Location, Services Provided, and Financial Performance.

“…physician-owned specialty hospitals tend to have lower Medicaid shares than both community hospitals in their market and peer hospitals that provide similar services….These findings are consistent with earlier work by the GAO and consistent with what we found on site visits to communities with physician-owned hospitals.” (MedPAC staff, transcript, pg. 174, September 2004)

In the most recent data available, the Dobson | DaVanzo statistics show once again that PHA members have far fewer Medicaid discharges, uncompensated care costs, and care to dual-eligible Medicare-Medicaid patients.

       
   
 
     

 

A key characteristic of cherry picking is avoiding patients that may have higher complexity or comorbidity.  Under the Medicare hospital payment system, CMS has identified those diagnoses whose presence as a secondary diagnosis leads to substantially increased hospital resource use, or, cost. Referred to as complication or comorbidity (CC) or a major complication or comorbidity (MCC), the higher the CC or MCC count, the potential for higher costs borne by the hospital. 

According to the Dobson | DaVanzo analysis, non-physician owned hospitals have nearly twice the number of CC/MCCs per Medicare claim as PHA member hospitals.

 
   

This “cherry picking” – avoiding Medicaid and uninsured patients, and treating low-cost, low complexity patients – creates an unlevel playing field that enables physician-owned hospitals to enjoy all-payer margins that are nearly three times the margin of non-physician-owned community hospitals, according to data from Dobson | DaVanzo.

Emergency Services Are Lacking in Physician-Owned Hospitals

A key measure of whether a hospital is providing a community benefit is the presence of emergency and trauma services.  The lack of emergency services provided in physician-owned hospitals is well documented. 

In 2003, GAO found that "The emergency departments at specialty hospitals treated less than one-tenth the median number of patients treated at the emergency departments of general hospitals.” (GAO-04-167 (October 22, 2003), pg.18, "Specialty Hospitals: Geographic Location, Services Provided, and Financial Performance.) 

And in September 2004, MedPAC staff reported that “many of the specialty hospitals we visited did not have emergency rooms, which increases their control over admissions. But even having an emergency room didn't mean the hospital was ready to treat emergencies. At one hospital we visited, it had to turn on the lights of its emergency room to show us the space.”

Further, in 2008, the U.S. Department of Health and Human Services’ Office of the Inspector General (HHS OIG) issued a report regarding the ability of physician-owned specialty hospitals to respond to and manage medical emergencies. The HHS OIG report found, in part, that “[t]wo-thirds of physician-owned specialty hospitals use 9-1-1 as part of their emergency response procedures,” and “[m]ost notably, 34 percent of [specialty] hospitals use 9-1-1 to obtain medical assistance to stabilize patients, a practice that may violate Medicare requirements.”   

The most recent data from Dobson | DaVanzo reaffirms these findings and strongly indicates that the PHA membership still largely do not provide emergency department services.

 
   

Readmission rates are considered an important barometer of a hospital’s quality of care and in 2010 Congress created a readmissions payment penalty program with a maximum penalty of three percent.  Since that time, there has been a significant drop in the overall readmissions rate among all hospitals.  Yet in 2016, according to Dobson | DaVanzo, ten percent of PHA physician-owned were among the poor performers who experienced the maximum penalty.  This compares to less than one percent – 0.9 percent – of all non- physician-owned hospitals in that category.

 
   

Conclusion:  Data Continues to Strongly Support Need to Maintain Current Law

There is a substantial history of Congressional policy development and underlying research on the impact of self-referral to physician-owned hospitals.  The empirical record is clear that these conflict-of-interest arrangements of hospital ownership and self-referral by physicians results in cherry picking the healthiest and wealthiest patients, excessive utilization of care and patient safety concerns.  This policy development includes 15 years of work by Congress, involving numerous hearings, as well as analyses by the HHS Office of Inspector General (OIG), Government Accountability Office (GAO) and Medicare Payment Advisory Commission (MedPAC).  And now, using the most recent data publicly available, Dobson | DaVanzo has reinforced those findings.  

In short, the dangers of self-referral remain, and the foundation for current law must be fortified, not weakened. Congressional Budget Office scoring of proposals to modify existing law consistently demonstrate that self-referral to physician owned hospitals increases utilization, which increases Medicare costs and health care costs generally.  This is a key reason why the U.S. Chamber of Commerce has long supported the ban on self-referral to physician-owned hospitals. 

The law enacted in 2010 is working exactly as planned to ensure a more level playing field – one that promotes fair competition.  It is a carefully crafted policy with an important safeguard that permits limited expansion of grandfathered hospitals to meet demonstrated community need.  Several physician owned hospitals, in fact, have met the requirements and are currently on the path to expand.  The law works and it must be maintained.

FAH Statement on Confirmation of Dr. Price as HHS Secretary

February 10, 2017 | Chip Kahn

Category: Affordable Care Act, FAH News, Health Care Delivery, Media

The Federation of American Hospitals congratulates Dr. Tom Price on becoming the HHS Secretary.

His experience as a thoughtful detailed-oriented legislator, combined with his decades working in the medical field make him uniquely qualified to confront the challenges facing patients, families and caregivers.

As Congress and the Trump Administration move forward with expected legislative action on the ACA, we stand ready to work with Secretary Price to ensure millions of Americans continue to have access to affordable health insurance. Further, we look forward to working with Secretary Price to make sure hospitals have the resources to provide essential health services in the communities we serve.

Mayors Urge Congress to Restore Hospital Funding in ACA Repeal

February 08, 2017 | FAH Policy Blog Team

Category: Affordable Care Act, Medicare, Rural

The Mayors of five Arizona cities recently penned an op-ed that contained a simple message for those in Washington – ACA repeal must also restore Medicare funding for hospitals.

“Cutting Medicare years ago hurt hospitals. Not restoring that funding now would be disastrous for cities and patients,” the mayors of Scottsdale, Mesa, Yuma, Prescott and Chandler wrote in the Arizona Republic.

The op-ed lays out the importance of hospitals in each of their communities – from the impact on jobs and the economy to the vital care they provide to patients.

“Mayors make difficult decisions that directly affect the lives of their citizens each and every day. As leaders in our own communities, we are calling on our counterparts in Washington to make what we view as an easy decision — restoring Medicare hospital reimbursements, so all Arizonans have access to quality health care, and those who deliver it can keep their jobs,” they wrote.

Their fear is that no action could lead to facilities cutting back on services or closing all together.

The mayors echoed FAH’s message when they urged federal legislators to include in any repeal legislation critically important restoration of hospital Medicare and Medicaid cuts.  

“We respectfully call on our federal delegation to stand up for Arizonans by voting to strengthen Medicare. Cutting Medicare funding was an error made years ago that wreaked havoc on Arizona hospitals. It would be an even bigger mistake for our lawmakers not to act now.”

The piece was co-signed by Mayors Jim Lane (Scottsdale), Doug Nicholls (Yuma), John Giles (Mesa), Harry Oberg (Prescott), and Jay Tibshareny (Chandler).

ICYMI: Arizona Governor Op-Ed Urges Congress to Protect Rural Care in any ACA Repeal by Restoring Hospital Medicare Cuts

January 23, 2017 | FAH Policy Blog Team

Category: Affordable Care Act, Financing, Health Care Delivery, Legislation, Rural

Republican Arizona Governor Doug Ducey recently penned an op-ed that appeared in The Daily Courier in Prescott and the Camp Verde Bugle entitled -  Rural health care a critical component of reform.

In the commentary, he outlines how important rural hospitals are to people in Arizona and nationwide:

“We don’t want to see rural Arizonans lose access to care or have to travel unacceptably long distances to get life-saving medical treatments which would create a serious problem, especially in emergency situations, where seconds and minutes can make the difference between life and death.

“In the last decade or so, Arizona has already lost three rural hospitals. As part of the repeal of Obamacare, there must be a patient-focused, common-sense replacement that also protects the viability of our rural health care providers.”

Gov. Ducey also echoed FAH’s message to Congress when he urged lawmakers to include in any repeal legislation critically important restoration of hospital Medicare and Medicaid cuts.  

“This means that legislation that repeals Obamacare, must also repeal the Medicare and Medicaid hospital reductions embedded in the law to ensure our community hospitals have the resources they need to meet their public health and safety mission on behalf of Arizona citizens. It stands to reason that just as policymakers are likely to rescind the hundreds of billions of dollars in Obamacare taxes imposed for the sole purpose of funding this massive law, they should similarly rescind the “hospital tax”, specifically the hundreds of billions of dollars in scheduled reductions to inflation updates and the Medicare and Medicaid DSH payments that help Arizona’s hospitals care for uninsured, low-income, and disabled Americans.”

Growing Concern for Rural Care if ACA Repeal Doesn’t Restore Medicare Cuts

January 11, 2017 | FAH Policy Blog Team

Category: Affordable Care Act, Financing, Health Care Delivery

The debate over repealing and replacing the Affordable Care Act is reaching a fever pitch in Washington. As lawmakers continue to discuss the timing and contents of future legislation, more voices are rising up to warn that rural care could be devastated if a repeal and replace plan doesn’t also restore Medicare cuts.

Wednesday the President of the National Grange, the nation’s oldest agriculture advocacy group, had a message for lawmakers thinking about the negative effects of ACA repeal on rural patients.

“We ask them to keep in mind that millions of people stand to lose the subsidies that are helping them afford healthcare, which could lead to a tremendous increase in patients coming to hospitals without the means to pay,” National Grange President Betsy Huber said in a statement. “This growth in uncompensated care would adversely affect rural hospitals causing them to potentially limit hours, shutter specialty units, or close their doors entirely.  Any of these results would have a harmful effect on health care in communities across the country as well as on local economies that rely on employers – like hospitals – to bring needed jobs.  Any repeal bill should at the same time reverse the cuts to Medicare – especially those made to hospitals.”

Those concerns were echoed by Thair Philips, who is president and CEO of the grassroots advocacy seniors’ group RetireSafe. He wrote a piece for TheHill.com entitled – Protect seniors and restore Medicare funding - and said:

“These ACA Medicare payment cuts played a significant role in causing more than 70 rural hospitals to close their doors. These hospitals served some of the most vulnerable of America’s seniors. As other health care providers struggle to keep from closing, access to health care for this vulnerable population will become increasingly difficult.”

“Republican leaders would inevitably like to keep their promise they made to American voters to repeal ObamaCare, but they must make sure that in their haste to repeal they don't put seniors’ health at risk — that’s a consequence none of us want. Any repeal bill should also restore the Medicare payments that ACA cut.”

“With the repeal of ObamaCare, there could be millions of Americans who will be uninsured leading to billions of dollars in uncompensated care, further burdening hospitals, especially in rural areas. If Medicare funding isn’t restored, hospitals will likely have an even steeper hill to climb to provide critical care for communities.”

In an opinion piece published Wednesday on RealClearHealth.com entitled - Medicare Cannot Be Used as America's Health Care Piggy Bank, Rich Galen (former spokesperson for Dan Quayle and Newt Gingrich), also raises concern about the future of health care in rural America:

“Doctors, clinics, and hospitals have to operate in the real world.  People have to be hired, equipment has to be purchased and maintained, drugs and consumables have to be at hand, and so on…And smaller hospitals, especially those in rural and medically underserved areas, are facing new Medicare cuts while simultaneously facing new pressures from growing epidemics like opioid overdoses. In the current drive to ‘repeal and replace’ the ACA, designers must be careful not to add to the burden of hospitals and clinics by ignoring the significant cuts to Medicare.”

ICYMI: FAH/AHA Drug Pricing Study Continues to Make Headlines

January 11, 2017 | FAH Policy Blog Team

Category: FAH News, Media, Pharmaceuticals

The website Healthcare Dive recently refocused the spotlight on the FAH/AHA hospital drug pricing study by publishing a feature article entitled, “How hospitals can fight the cost of budget-busting drugs.”

Reporters Ana Mulero and Lisa LaMotta used the FAH/AHA study as a basis to highlight rapidly rising hospital drug costs and what can be done to make sure it doesn’t harm patient care.

As the story states, the report found that, “High increases had either a moderate or severe impact on more than 90% of the budgets of hospitals surveyed.”

FAH CEO Chip Kahn told the reporters the goal was to raise the visibility of the issue and inform policy makers.

"We had been hearing from hospital leaders about the fix they were in regarding generic drugs or pre-FDA drugs," Kahn told Healthcare Dive. "Because of what was happening with the ownership and licensure of those drugs companies like Valeant basically had a monopoly on some of these drugs…In hundreds of cases, there have been thousands of percent increases in drugs — antibiotics and others."

The article also examines what hospitals can do to lessen the impact on their budgets. Steps that include:

  • Look for a generic or branded generic alternative for drugs that have undergone unexpected price increases.
  • Substitute combination drugs, when possible, with their respective components.

Healthcare Dive also looked at how the drug industry is responding to the controversy and what the federal government might do to resolve the problem.

You can read the entire article here.

ICYMI: Politico Highlights ACA Repeal’s “Doomsday Scenario”

January 09, 2017 | FAH Policy Blog Team

Category: Affordable Care Act, Financing, Media

The possible fallout from repealing the Affordable Care Act without a replacement continues to make headlines inside and outside the Beltway.

On Monday morning, Politico published a story entitled: “Obamacare repeal's doomsday scenario,” which highlights “apocalyptic” impact repeal could have on hospitals and the patients they serve.

As the hospital community continues its efforts to educate policymakers about the importance of ensuring patients have access to care, the impact of ACA repeal—and not restoring the hospital Medicare cuts—is becoming clearer.

The story references the recently released Dobson | DaVanzo study - commissioned by the FAH and AHA - which analyzed the financial impact of repealing the ACA without restoring the hospital Medicare cuts.

The reporters write, “Their doomsday scenario: Millions of people could lose their health care coverage, hospitals could hemorrhage cash and shocks to the $3 trillion-a-year health system could send ripple effects through the entire economy.”

Heidi Gartland, vice president for community affairs and government relations at Cleveland-based University Hospitals Health System, described it this way:

“That transition period is going to be like that slow-moving tsunami that we know is coming, and we can watch it and try to prepare for it — but in the aftermath of the tsunami, there’s devastating loss that we never could have planned for.”

The reporters also refer to recent layoffs at The Advisory Board Company as some of the first casualties of the political uncertainty surrounding the future of the health care industry.

William Conway, CEO of Detroit’s 1,300-physician Henry Ford Medical Group, says, “Everybody is going to continue to belt tighten and take action fearing the worst is going to happen.”

The article goes on to highlight the devastating effects of eliminating individual insurance subsidies or getting rid of the individual mandate – both moves that could devastate hospitals financially.

“Without the ACA’s expanded coverage, the cost of uncompensated care to hospitals, doctors and other health providers would surge — by as much as $1.1 trillion over a decade, according to an Urban Institute study. Providers would bear much of the new burden of caring and paying for the newly uninsured, an obligation they warn could collapse the finances of hospitals serving the nation’s neediest regions.”

Gartland points out that ultimately, and most importantly, it ends up hurting the patient, “Health systems only have a few tools to balance our budgets, and those are things like curtailing services and reducing our workforce. It really is going to have a big impact on access to care, whether you’re insured or uninsured.”

You can read the entire article by clicking here.

MedPAC Predicts Lowest Hospital Margins of All-Time

December 16, 2016 | FAH Policy Blog Team

Category: Affordable Care Act, Financing

MedPAC is predicting that hospital overall margins will hit an all-time low in 2017, a fact that only adds to the growing financial pressure being felt by facilities nationwide.

The startling revelation was one of several items to come out of the commission’s recent meeting. MedPAC seems set to recommend to Congress that acute care hospitals receive an FY18 market basket update under current law, which staff estimates will be a net 1.85 percent.

The final recommendation, which will be included in its annual March Report to Congress, will be adopted when the Commission meets in January.  But there was clear consensus about the market basket update, and there is no expectation that it will change.

Among the considerations in supporting this recommendation was the continued decline in the hospital overall margin, which staff projects to be negative ten percent in 2017 – a new all-time low

This is one of several tough economic factors facing hospitals in the near future. Earlier this month, a report released jointly by the FAH and AHA showed the crippling effects of repealing the ACA without replacing the law’s deep cuts to hospitals. The ACA cuts alone could be close to $400 billion, an amount that would damage hospitals ability to provide needed care in communities across the country, especially if ACA’s coverage expansion is rolled back.

New Report Outlines Impact of ACA Repeal on Patients and Hospitals

December 06, 2016 | FAH Policy Blog Team

Category:

The American Hospital Association (AHA) and the Federation of American Hospitals (FAH) sent letters to President-Elect Trump  and Congressional leaders today highlighting a new report that details the severe impact repealing the Affordable Care Act (ACA)’s coverage will have on community hospitals as they strive to care for their communities. The report finds that this would result in the largest ever cut to hospital funding, nearly 100% more than the Balanced Budget Act of 1997.

While expressing the importance for repeal legislation to be accompanied by replace legislation, Chip Kahn, FAH President and CEO, and Rick Pollack, AHA President and CEO, underscored the importance of protecting patients, hospitals and our caregivers if the Congress chooses to only repeal at this time.

      “As you begin reconsideration of the ACA, we want to be a constructive partner in this discussion. We strongly believe that any repeal legislation must be accompanied by provisions that protect the coverage for those currently receiving such    protection. However, if that is not the legislative path to be pursued, then it is vital that such legislation provide a true clean slate and also include repeal of the reductions in payments for hospitals services embedded in the ACA – specifically the substantial reductions to hospitals’ annual inflation updates and the cuts to Medicare and Medicaid DSH payments. If the coverage associated with the ACA disappears, the importance of these payments would be heightened – they are vital in helping defray the costs of treating our most vulnerable patients.

The report, which was commissioned by the AHA and FAH, was put together by the health care economics firm Dobson | DaVanzo.  It estimates the financial impact, from 2018 – 2026, on hospitals of repealing the ACA under H.R. 3762 without any replacement. Dobson | DaVanzo finds that the loss of coverage under H.R. 3762 would have a net negative impact on hospitals of $165.8 billion, after accounting for the restoration of the Medicaid DSH cuts that H.R. 3762 contemplates. Dobson | DaVanzo also finds that hospitals would lose $289.5 billion in inflation updates if the payment cuts in the ACA are not restored. Finally, Dobson | DaVanzo finds that the full restoration of the Medicare and Medicaid DSH payment reductions would amount to $102.9 billion.  

      “Losses of this magnitude cannot be sustained and will adversely impact patients’ access to care, decimate hospitals’ and health systems’ ability to provide services, weaken local economies that hospitals help sustain and grow, and result in massive job losses. As you know, hospitals are often the largest employer in many communities, and more than half of a hospital’s budget is devoted to supporting the salaries and benefits of caregivers who provide 24/7 coverage, which cannot be replaced,” wrote Pollack and Kahn.

The Pollack and Kahn letters also call attention to a second Dobson | DaVanzo analysis that estimates the cumulative federal payment reductions to hospitals that have been imposed subsequent to and independent of ACA.  These cuts total another $148 billion from 2010 to 2026.

Pollack and Kahn concluded the letters by committing to work with the President-Elect and Congress on legislation that achieves the shared goal of improving America’s health care system through patient-centered care, and believe strongly that empowering Americans through health coverage is key to success.