MEDICARE FOR 2022 IS FINALIZED AND STATUS QUO - Larry Meikel, MBA December 9, 2021

MEDICARE FOR 2022
 IS FINALIZED AND
    STATUS QUO
  By:
  Larry Meikel, MBA
  Classic Behavioral Healthcare, LLC
  cbh149@cs.com
  December 9, 2021

AGENDA TARGETS

 • CMS-1753-FC
 • Rates for 2022
 • Policy Update
 • CMS Update- Discussion
 • Professional-Hospital OP Visits

CMS-1753-FC

    MEDICARE CONTACT INFORMATION:

_____________________________________________

 CONTACT THE PHP PAYMENT POLICY MAILBOX AT:
        PHPPaymentPolicy@cms.hhs.gov
_____________________________________

CMS-1753-FC
• Released November 3, 2021
• 1394 Pages
• Final Response date 12/2/21 by 5 PM EST
• Proposed Rates to be Effective 1/1/22
              Key Tables for 2022
• CMS 1753-FCC TABLES 2,3,4 REV
      CBSA References
      Under Inpatient
      FY 2021 IPPS/LTCH PPS Final Rule
      Medicare Geographic Classification Review Board
CMS 2022 NFRM Addeneum A 11012021_1

2022 RATE C ALCULATIONS

                         P. 13
Partial Hospitalization Update:
1.   For CY 2022, we (CMS) are using the CMHC and
     hospital-based PHP (HB PHP) geometric mean per
     diem costs, consistent with existing methodology,
     but
2. with a cost floor that will maintain the per
   diem costs finalized in CY 2021.
3.   We are also using the CY 2019 claims and cost
     report data for each provider type, consistent
     with the use of claims and cost report data prior
     to the PHE within the broader CY 2022 OPPS rate
     setting.

2022 FINAL RATES
                         FOR JANUARY 1, 2022

                               FINAL      Final
Service Intervention           CY 2021    CY 2022   %Chg
5853 PHP CMHC 3+ ser.          $139.75    $142.70   +2.07%
5863 PHP Hospital 3+ ser.      $260.49    $265.97   +2.07%

8010 IOP Hospital only         $260.49    $265.97   +2.07%

5823 Brief Individual           $133.63   $136.65   +2.22%
5823 Extend Individual          $133.63   $136.65   +2.22%
5823 Family Psychotherapy       $133.63   $136.65   +2.22%
5822 Group Psychotherapy        $ 74.87   $ 76.42   +2.03%

C ALCULATING YOUR 2022 RATE

       • Ft. Meyers. FL, CBSA 10, Lee County, .9219
                  • See pp. 159 to 162

• 2022 National PHP Rate                       $265.97
• Labor Component Calculation                  x .60
• Labor Component                              $159.582
• Times the Wage Index of .9219                x .9219
• Labor Component Value                        $147.119
• Non-Labor Component .4 x $265.97             $106.388

• Add Labor, Non-Labor Together                $253.507

GEOMETRIC MEAN COSTS FOR 2022-
               POLICY UPDATE

                                    TABLE 44+ p. 569
 CY                         Geometric       Final      Geometric    Geometric      Final
2021           Title       Mean Costs &     Rates      Mean Costs   Mean Floor     Rates
APC                           Floor
                              2019          2021         2020          2022        2022
5853   Partial               $136.14      $139.75       $136.14     $139.75       $142.70
       Hospitalization-
       CMHCs
       (three or more
       services per day)
5863 Partial                $253.76       $260.49      $253.76     $260.49     $265.97
       Hospitalization-
 • FinalHospitals
         Rates are both increased BY 2.65% over the actual means cost of 2019.
       (three or more
       services per day)

         • Final Rates are both increased by 2.07% over the actual mean floors.

CMS-1753-FC QUOTE

• P. 558
• “One National Organization expressed its’ belief that
  ensuring financial stability and sustainability for those
  programs is critical to ensuring access to this level of care
  for some of Medicare’s most vulnerable patients.”

PROFESSIONAL SERVICES POLICY
           UPDATES

• In the CY 2014 OPPS/ASC final rule with comment period
  (78 FR 75036 through 75043),
• 1. Finalized a policy that created alphanumeric HCPCS
  code G0463 (Hosp OP clinic visit for assessment and
  management of a patient), representing any and all clinic
  visits under the OPPS. HCPCS code G0463 was assigned to
  APC 0634 (Hospital Clinic Visits).
• 2. Finalized a policy to use CY 2012 claims data to develop
  the CY 2014 OPPS payment rates for HCPCS code G0463
  based on total geometric mean cost of the levels one
  through five previously recognized under the OPPS (CPT
  codes 99201 through 99205 and 99211 through 99215).
• 3. Finalized a policy to no longer recognize a distinction
  between new and established patient clinic visits.

CMS-1753-FC
        IMPACT ON PROVIDERS
Table 84      p. 1329   All Changes
Hospitals     377       +1.6%
CMHCs         39        +1.1%

              CMHCs
   2011 204   2015 57   2019 39
   2012 159   2016 49   2020 39
   2013 100   2017 44
   2014 72    2018 41

CMS BONUS DISCUSSIONS

  • Telehealth Status

  • 20 Hour Rule

  • Individual Therapy

  • Quality Measures

TELEHEALTH STATUS
• Effective as of March 1, 2020 and for the duration of the
  COVID-19 Public Health Emergency (PHE).

• Interim final rule (85 FR 27566), released on April 30, 2020.

• Hospital and CMHC staff are permitted to furnish certain
  outpatient therapy, counseling, and educational services
  (including certain PHP services), incident to a physician’s
  services, to beneficiaries in temporary expansion locations,
  including the beneficiary’s home, so long as the location meets all
  conditions of participation to the extent no waived.

TELEHEALTH STATUS
• A hospital or CMHC can furnish such services using
  telecommunications technology to a beneficiary in a temporary
  expansion location if that beneficiary is registered as an
  outpatient.

• These provisions apply for the duration of the COVID-19 PHE.

• CMS will continue to evaluate policy options for strengthening
  the PHP/HOPS benefit and increasing access to these services.

FOCUS ON INDIVIDUAL THERAPY

CMS is concerned by this decrease in the provision of individual therapy and
will continue to monitor this trend. As we stated in the CY 2017, 2018, and
2019 final rules with comment period (81 FR 79684 through 79685), the PHP
is intensive in nature, and we believe that appropriate treatment for PHP
patients includes individual therapy.

CMS QUALITY MEASURES

CMS has considered Quality Measures as an influence on Payment
Rates/Program Reviews for PHP:

        1. 30 Day Readmission Rate
        2. Group Therapy
        3. No Individual Therapy
        4. Services Per Day
        5. Services Per Week (non admit/discharge)
                 82 FR 52572 Thru 52573

RECENT LISTSERVE ISSUES

• 1. Physician Supervision – Must complete a Psychiatric
  Evaluation, Certification statement (Medicare Patients),
  Treatment Plan, Attend Treatment Team meetings in
  person, Sign off on the Tx Plan and Updates, complete and
  document Physician-Patient Encounters.
• 2. Patient admitted to PHP but only attends 1 or 2 services
  for a day. Can just the groups be billed as OP and
  reimbursed since PHP services are not reimbursable for
  the day?

LISTSERVE ISSUES (CONT)

• 3. One note is written for a 2-hour group but billed as 2
  separate groups.

• 4. Professional billing for PHP/IOP groups and/or facility
  charges for the groups?

PHP NON-ACCEPTABLE LOCATIONS

      1. Individual Home
      2. Inpatient Setting
      3. Residential Setting

THANK YOU FOR ATTENDING
   THIS PRESENTATION