This week in Medicare updates—8/9/2023

Biden-Harris Administration Announces Medicare Dementia Care Model

On July 31, CMS published a Press Release regarding a new Innovation Center model called the Guiding an Improved Dementia Experience (GUIDE) Model. This voluntary nationwide model will utilize a package of care coordination and care management, caregiver education and support, and respite services to aim to improve the quality of life for people living with dementia, reduce strain on their unpaid caregivers, and enable people living with dementia to remain in their homes and communities. It combines care from an interdisciplinary team with training and support for the beneficiary’s unpaid caregivers.  

Providers who may participate in this model must be Part B-enrolled providers/suppliers who are eligible to bill for Physician Fee Schedule services and agree to meet the care delivery requirements of the model either alone or with partner organizations. The model will include three types of payments: infrastructure payment via a one-time, lump sum payment; per-beneficiary per-month payments for care management, coordination, caregiver education, and support services; and respite care payment up to an annual respite cap amount. 

CMS published additional information about the model via a GUIDE model fact sheet and on the Innovation Center website. CMS will release the application to participate in the fall, and interested organizations are encouraged to submit letters of intent by September 15. The model will run for eight years and will begin on July 1, 2024.

Alternative Payment Model (APM) Incentive Payment Advisory for Clinicians - Request for Current Billing Information for Qualifying APM Participants

On July 31, CMS published a Payment Advisory in the Federal Register to notify clinicians who are qualifying APM participants that CMS does not have the current billing information needed to disburse payment. The advisory provides information to clinicians on how to update their billing information. 

Updated billing information must be received no later than September 1.

FY 2024 Skilled Nursing Facility (SNF) PPS Final Rule

On July 31, CMS published a draft copy of the FY 2024 SNF PPS Final Rule, which is scheduled to be published in the Federal Register on August 7. CMS estimates a 4.0% increase to the SNF payment rate for 2024. This number incorporates the 2.3% reduction that will finish the two-year phase-in of the PDPM parity adjustment. 

CMS also finalized a change to administrative procedures for civil monetary penalties where, if a facility fails to submit a timely request for a hearing, CMS will consider that facility to have waived its right to a hearing. The accompanying 35% penalty reduction would remain unchanged. This revision is intended to reduce the burden involved with tracking and managing written waiver requests. The rule also includes changes to PDPM ICD-10 code mappings, the exclusion of marriage and family therapists and mental health counselor services from SNF consolidated billing, several quality reporting changes, and SNF value-based purchasing program changes.

CMS published a Fact Sheet to accompany the rule. The rule is effective October 1.

FY 2024 Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital (LTCH) PPS Final Rule 

On August 1, CMS published a draft copy of the FY 2024 IPPS Final Rule, which is scheduled to be published in the Federal Register on August 28. CMS projects an increase in operating payment rates by 3.1% based on a projected hospital market basket update of 3.3% reduced by a 0.2% productivity adjustment. Despite this administration’s emphasis on health equity, CMS projects that disproportionate share hospital (DSH) payments will decrease by approximately $957 million, far more than the estimated $115 million decrease suggested in the proposed rule. CMS said it based that cut on the Office of the Actuary’s estimation that the rate of the uninsured will decline from 9.2% in FY 2023 to 8.3% in 2024 despite acknowledging an estimated 11% decrease in Medicaid enrollees in FY 2024 due to the end of PHE provisions enabling greater enrollment in Medicaid. 

Other policies finalized in the rule include: 

• For the New Technology Add-on Payment (NTAP) program, CMS is moving the FDA approval deadline from July 1 to May 1 beginning with applications for FY 2025. CMS will also require applicants for technologies that are not already market authorized to have a complete and active FDA market authorization request at the time of NTAP application submission beginning with payment applications for FY 2025. 
• CMS will limit the inclusion of patient days for patients who are regarded as eligible for Medicaid benefits under a Section 1115 demonstration project for purposes of the Medicare DSH calculation.
• CMS is changing graduate medical education payments for rural emergency hospitals to better support graduate medical training in rural areas

The rule also contains a variety of quality reporting program changes and changes, continues the temporary low-wage index hospital policies from the FY 2020 final rule, revises regulations regarding physician-owned hospitals, and more. 

CMS published a Press Release and Fact Sheet to accompany the rule. CMS published some of the IPPS data files and tables to the IPPS webpage. The rule is effective October 1.