/ en Fri, 25 Apr 2025 16:25:17 -0500 Tue, 15 Apr 25 14:47:55 -0500 /news/headline/2025-04-15-cms-update-spa-template-medication-assisted-treatment-benefit <p>The Centers for Medicare & Medicaid Services today released a <a href="https://www.federalregister.gov/public-inspection/2025-06400/agency-information-collection-activities-proposals-submissions-and-approvals-medicaid-and-childrens" title="CMS notice">notice</a> seeking public comment on the collection of information request regarding the State Plan Amendment template for medication-assisted treatment. SPA templates are provided by CMS to assist states with Medicaid application submissions as well as reducing administrative burden and increasing efficiency. States are required to cover MATs for opioid use disorder under their state Medicaid programs. CMS said it is planning to update the SPA template for MAT to align with statutory updates. The comment period will be open for 14 days following publication in the April 16 Federal Register.</p> Tue, 15 Apr 2025 14:47:55 -0500 Regulatory Relief <div class="container"><div class="row"><div class="col-md-8"><p>The Trump administration April 9 released a series of executive orders (EOs) and took other administrative actions aimed at reducing regulatory burden.</p><p>The Office of Management and Budget April 9 issued a <a href="https://www.federalregister.gov/public-inspection/2025-06316/request-for-information-deregulation" target="_blank" title="Federal Register: Request for Information: Deregulation">request for information (RFI)</a> seeking public comment on regulations that should be rescinded as unnecessary, unlawful, unduly burdensome or unsound. According to the RFI, recommendations should focus on regulations that are inconsistent with statutory text or the Constitution, entail costs that exceed benefits, are outdated or unnecessary, or are otherwise burdening businesses in unforeseen ways. Comments are due within 30 days of publication in the Federal Register.</p><p>Relatedly, the White House issued two EOs, <a href="https://www.whitehouse.gov/presidential-actions/2025/04/directing-the-repeal-of-unlawful-regulations/" target="_blank" title="The White House: Directing the Repeal of Unlawful Regulations">“Directing the Repeal of Unlawful Regulations”</a> and <a href="https://www.whitehouse.gov/presidential-actions/2025/04/reducing-anti-competitive-regulatory-barriers/" target="_blank" title="The White House: Reducing Anti-competitive Regulatory Barriers">“Reducing Anti-Competitive Regulatory Barriers.”</a></p><h2>Directing the Repeal of Unlawful Regulations</h2><p>This EO is linked to the Feb. 25 EO 14219, <a href="https://www.federalregister.gov/documents/2025/02/25/2025-03138/ensuring-lawful-governance-and-implementing-the-presidents-department-of-government-efficiency" target="_blank" title="Federal Register: Ensuring Lawful Governance and Implementing the President's " department of government deregulatory>“Ensuring Lawful Governance and Implementing the President’s ‘Department of Government Efficiency’ Deregulatory Initiative.”</a> EO 14219 directed agencies to identify, within 60 days (approximately April 20), categories of unlawful and potentially unlawful regulations to be repealed. The related April 9 EO tasks agencies with immediately taking steps to repeal regulations after the 60-day period has ended, prioritizing those regulations that implicate several Supreme Court rulings. Additionally, it requires agencies to provide justification within 30 days for any regulations that were identified as unlawful but have not been targeted for repeal, explaining the basis for the decision not to repeal.</p><h2>Reducing Anti-Competitive Regulatory Barriers</h2><p>This EO directs federal agencies to review all regulations subject to their rulemaking authority and identify those regulations that create de facto or de jure monopolies, create barriers to entry for new market participants, create or facilitate licensure or accreditation requirements that unduly limit competition, or otherwise impose anti-competitive restraints or distortions in the market. Agencies must submit recommendations to the Federal Trade Commission (FTC) and the Attorney General on whether anti-competitive regulations should be rescinded or modified within 70 days of the order (approximately June 18). Additionally, the EO directs the FTC to issue, within 10 days of the order, an RFI seeking public comment on anti-competitive regulations.</p><p>Additional information will be forthcoming as agencies provide supporting guidance or notices.</p><h2>Additional Information on Executive Actions</h2><p>The Trump administration has issued many executive orders and taken other administrative actions. The AHA has compiled a <a href="/system/files/media/file/2025/01/2025-New-Executive-Orders-20250127.pdf">tracker of the actions the administration has taken</a> that may be of interest to hospitals and health systems. The tracker will be updated regularly as new actions are taken.</p><h2>Further Questions</h2><p>If you have further questions, please contact the AHA at <a href="tel:1-800-424-4301">800-424-4301</a>.</p></div><div class="col-md-4"><p><a href="/system/files/media/file/2025/04/Member-Advisory-Trump-Administration-Issues-Additional-Deregulation-Orders-and-Notices.pdf" target="_blank" title="Click here to download the Member Advisory: Trump Administration Issues Additional Deregulation Orders and Notices PDF."><img src="/sites/default/files/inline-images/Page-1-Member-Advisory-Trump-Administration-Issues-Additional-Deregulation-Orders-and-Notices.png" data-entity-uuid="31a05d9f-f2f8-46cb-9473-74ff7873b661" data-entity-type="file" alt="Member Advisory: Trump Administration Issues Additional Deregulation Orders and Notices page 1." width="695" height="900"></a></p></div></div></div> Thu, 10 Apr 2025 14:32:06 -0500 Regulatory Relief /affordability-advocacy-agenda <div class="container"><div class="row"><div class="col-md-8"><h2><span>Advancing Affordability, Value, and Equity in Health Care Priorities for America’s Hospitals and Health Systems</span></h2><p>By all accounts 2020 was an unprecedented and historic year – one that tested our nation, our economy and our health care system like never before.</p><p>Hospitals, health systems and post-acute care providers – along with our doctors, nurses and other team members – have been on the front lines of the COVID-19 pandemic, working tirelessly to provide the best care for patients, families and communities. They have done this – and continue to do this – while facing daunting challenges. These challenges have persisted well into 2021, with continued surges of cases and hospitalizations.</p><p>At the same time, individuals, employers, and the government continue to seek greater value for their health care dollars. Concerns around the affordability of health care will only grow as overall health care spending continues to rise and, especially with respect to publicly-financed programs like Medicare and Medicaid, demographic trends mean that there are fewer workers to help finance this care. There is also a renewed focus on eliminating disparities in care, closing equity gaps, and enhancing quality and patient safety – all of which are integral to achieving greater value.</p><p>Our shared focus with Congress and Administration is on providing relief from the pandemic, ensuring a smooth recovery, and rebuilding a better health care system for the future. The ���������� Association continues to incorporate principles that promote improved affordability, value, and equity into our policy and advocacy activities. Below are some of our key priorities in these areas.</p><h3><span>Making Health Care More Affordable</span></h3><p>In recent years, health care spending growth has largely been driven by increased use and intensity of services. In other words, more people are getting care – and more care – and the care they are getting is more involved than in the past. Much of this is the result of substantial expansions in health care coverage, improved efforts to connect people to needed care, advances in medicine and technology, and growth in the prevalence of chronic disease. In some cases, prices have also risen, such as for prescription drugs. This can impact not only what individuals may pay at the pharmacy counter but also the cost of care provided by hospitals, physicians, and other providers that relies on critical drug therapies. Another substantial cost driver that has dramatically escalated in the past several years is the utilization management processes that health plans have erected and which require significant investments in technology and personnel to manage.</p><p>Hospital care requires a range of inputs such as wages for clinical and other personnel, prescription drugs, administrative software and other technology, food, medical devices, utilities and professional insurance. Steep increases in the prices for certain inputs, like drugs and administrative processes mandated by health plans, can undermine hospitals’ efforts to reduce the cost of care.</p><p>To address the underlying cost drivers in the health care system, we urge Congress and the Administration to:</p><ul><li>Rein in the rising cost of drugs, including by taking steps to increase competition among drug manufacturers; improve transparency in drug pricing; and advance value-based payment models for drugs.</li><li>In the same vein, protect the 340B drug savings program to ensure structurally marginalized communities have access to more affordable drug therapies by reversing harmful policies and holding drug manufacturers accountable to the rules of the program, especially as it relates to community pharmacy arrangements.</li><li>Reduce administrative waste by streamlining prior authorization requirements and processes for hospitals and post-acute care providers, so that clinicians can spend more of their time and resources on direct patient care, not pushing paper and arguing with insurance companies over administrative delays and coverage denials.</li><li>Promote greater efficiency and safeguards against unnecessary burden in HIPAA administrative standards and other rules related to billing and ensure an achievable roadmap toward greater adoption of standard transactions.</li><li>Reduce unnecessary costs in the system by passing comprehensive medical liability reform, including caps on non-economic damages and allowing courts to limit attorneys’ contingency fees.</li></ul><h3><span>Improving the Affordability of Coverage</span></h3><p>In addition, we urge Congress and the Administration to take additional steps to make health care coverage more affordable and easier to use for patients. The entire point of insurance is to share large and unanticipated costs across a pool of people. Coverage is essential for making health care affordable for individuals and families in the same way car insurance enables individual drivers to weather the bad fortune of an unexpected crash. While we have made substantial gains in health coverage over the past decade, we are just beginning to fully understand the crisis of under-insurance that is primarily being driven by high deductible health plans.</p><p>The AHA supports bolstering our current public/private framework for coverage to close the remaining coverage gaps and taking immediate steps to ensure that patients do not face financial barriers to using their coverage. We encourage policymakers to preserve and build on the strong foundation of employer-sponsored coverage and further strengthen the individual market while ensuring that Medicare and Medicaid are available to those who rely on these programs. Specifically, we encourage Congress and the Administration to:</p><ul><li>Take additional steps to close coverage gaps, including by building on the existing incentives to encourage all states to expand Medicaid, making permanent the recent expansions in eligibility and the level of subsidies for coverage on the Health Insurance Marketplaces, and expanding existing outreach and enrollment efforts to ensure that every U.S. resident knows their options for coverage.</li><li>End the sale of products purporting to be health plans but that do not meet all of the consumer protections established in federal law, such as health sharing ministries and short-term limited duration coverage products which can leave patients with high and unexpected medical bills as a result of gaps in coverage.</li><li>Restrict the sale of high deductible health plans to consumers who can afford the associated cost-sharing obligations.</li><li>Ensure patients can rely on their coverage by disallowing health plans from inappropriately delaying and denying care, including by making mid-year coverage changes.</li><li>Protect patients from surprise medical bills and ensure that the implementing regulations do not unintentionally distort health care markets and reduce patient access to care.</li><li>Support price transparency efforts by ensuring patients have access to the information they seek when preparing for care, including cost estimates when appropriate, and creating alignment of federal price transparency requirements to avoid patient confusion and overly burdensome duplication of efforts.</li></ul><h2><span>Advancing Value through Health System Transformation and Enhancements in Quality</span></h2><h3><span>Health System Transformation</span></h3><p>In addition to making the health care system more affordable, hospitals and health systems are committed to ensuring that each dollar brings value. We will achieve this by continuously striving to deliver the highest quality care most efficiently, and that will require rethinking how and where we deliver care. We will also look for opportunities for providers to collaborate with payers and employers to ensure aligned incentives to achieve value, including identifying effective models of risk where appropriate.</p><p>The last decade brought significant changes in the health care landscape, but nothing has accelerated changes in the delivery of health care like the COVID-19 pandemic. During the public health emergency, hospitals and health systems were able to innovate at a pace and scale previously unseen as a result not only of the realities of containing a pandemic but also the regulatory flexibility provided by states and the federal government.</p><p>The AHA is eager to continue these advances and supports policies that:</p><ul><li>Expand use of telehealth, broadband and digital technologies by providing Medicare and Federal Communications Commission funding, coverage, and reimbursement for such services, technology and workforce training.</li><li>Implement policies to better integrate and coordinate behavioral health services with physical health services.</li><li>Build on the progress in modernizing the Stark Law and Anti-kickback Statute regulations that better protect arrangements that promote value-based care.</li><li>Allow providers to determine how best to utilize electronic health records (EHRs) and other technologies while promoting interoperability and access to health information for clinical care and patient engagement.</li><li>Provide robust support to ensure electronic communication between acute care hospitals and psychiatric hospitals and providers, and to encourage psychiatric hospitals and mental health providers to optimally use EHRs.</li><li>Advance use of innovative technologies and software (e.g., clinical decision support algorithms) without increasing regulatory burden by supporting policies that enable clinicians to have the data they need to treat patients and improve health outcomes.</li><li>Invest in health care infrastructure by expanding access to virtual care technologies and high-speed internet, strengthening the capacity and capability for emergency preparedness and response, assisting hospitals in “right-sizing” to meet the needs of their communities, and ensuring adequate financing mechanisms are in place for hospitals and health systems, including for training the workforce.</li><li>Address the impact that social determinants of health have on patient outcomes by improving care coordination and expanding the tools hospitals can use to meet these needs.</li><li>Advance rural health care alternatives to ensure sustainable care delivery and financing including: exploring rural pre-payment models; supporting additional inpatient/outpatient transformation strategies; promoting virtual care strategies; allowing innovative partnerships; and refining existing models that support hospitals serving historically marginalized communities.</li><li>Explore a new payment mechanism for metropolitan anchor institutions that treat a disproportionate number of government-funded or uninsured patients.</li></ul><h3><span>Enhancing Quality and Patient Safety</span></h3><p>America’s hospitals and health systems are world-renowned for the quality of care they provide and are always striving to do even better. Clinicians at U.S. hospitals set the global standard in COVID-19 care, such as by optimizing the use of ventilators for those patients who would most benefit from them. – knowledge that was then shared around the world.</p><p>There is no limit to hospitals’ and health systems’ commitment to quality. However, policy changes are needed to facilitate the identification and adoption of best clinical practices, including addressing challenges with public quality reporting and incentive programs. The AHA encourages policymakers to:</p><ul><li>Continue to streamline and coordinate quality measures in national programs to focus on the “measures that matter” most to improving health and outcomes while reducing burden on providers. These measures should be based on evidence that demonstrates meaningful improvements in patient outcomes are achievable by improving adherence to the measures.</li><li>Advocate for modernized conditions of participation, interpretative guidance and Joint Commission standards that hold hospitals accountable for taking actions that lead to higher-quality and safer care.</li><li>Enhance the effectiveness of the physician quality payment program by advocating for more accurate and meaningful cost measures and data-driven implementation of new program approaches.</li><li>Promote advanced illness management to better honor patients’ wishes at the end-of-life and remove barriers to expanding access to palliative care services.</li><li>Enhance care coordination and improve patient safety by implementing through rulemaking Sec. 3221 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, which revises and better aligns the outdated 42 CFR Part 2 regulations with HIPAA, allowing the responsible sharing of substance use disorder treatment records for the purposes of treatment, payment and health care operations.</li></ul><h3><span>Advancing Health Equity, Eliminating Health Care Disparities, and Increasing Diversity and Inclusion</span></h3><p>The COVID-19 outbreak in the U.S. has shown the country what all hospital and health systems leaders have known for years: serious gaps exist in access, cost and quality for patients based on race, ethnicity, gender and gender identity, age, sexual orientation or other demographic and socio-economic factors. Hospitals and health systems are committed to doing the work to address health equity issues. The AHA and its Institute for Diversity and Health Equity (IFDHE) are also committed to advancing health equity, eliminating health care disparities and increasing diversity and inclusion. The AHA supports policies that:</p><ul><li>Pursue strategies and support public policies aimed at improving maternal and child health outcomes with a particular focus on eliminating racial and ethnic disparities.</li><li>Promote health equity by encouraging cultural humility training in medical residency programs and in-service training for health care professionals.</li><li>Promote inclusion of adjustment for sociodemographic factors in quality measurement programs where appropriate to ensure performance measurement and payment adjustments support the efforts to make meaningful improvements.</li><li>Support coordinated collection of race and ethnicity data across federal agencies to elevate understanding of health care needs in Black and Latino Americans, Native Americans and other communities of color.</li><li>Increase funding for the health equity infrastructure in the Department of Health and Human Services, including the National Institute on Minority Health and Health Disparities, to better research and address the needs of communities of color.</li><li>Support efforts to increase diversity in the health care workforce, including through federal grants to minority-serving institutions for scholarships.</li><li>Repeal the June 2020 final rule that narrowed the scope of non-discrimination protections under Section 1557 of the Affordable Care Act.</li></ul></div><div class="col-md-4"><p><a href="/system/files/media/file/2019/09/report-affordability-agenda-0919.pdf" target="_blank" title="Click here to download the AHA Affordability Advocacy Agenda 2021 PDF."><img src="/sites/default/files/inline-images/Page-1-Affordability-Advocacy-Agenda-2021-10-15.jpg" data-entity-uuid="f0cf703c-d05d-4774-9ecd-c00015b522d3" data-entity-type="file" alt="Page one of the AHA Affordability Advocacy Agenda 2021." width="2550" height="3311"></a></p><div class="external-link spacer"><a class="btn btn-wide btn-primary" href="/system/files/media/file/2019/09/report-affordability-agenda-0919.pdf" target="_blank" title="Click here to download the AHA Affordability Advocacy Agenda 2021 PDF.">Download PDF</a></div><p><a href="/costsofcaring" target="_blank" title="Click here for more information."><img src="/sites/default/files/2022-08/costs-of-caring-report-cover_Page_1.png" data-entity-uuid data-entity-type="file" alt="Costs of Caring 2022 Cover." width="1159" height="1500"></a></p><div class="external-link spacer"><a class="btn btn-primary btn-wide" href="/system/files/media/file/2022/04/2022-Hospital-Expenses-Increase-Report-Final-Final.pdf" target="_blank">Download PDF</a></div><div class="panel module-typeC"><div class="panel-heading"><h3 class="panel-title">Affordability Resources</h3></div><div class="panel-body group2"><p><a href="/issue-brief/2019-09-18-real-affordability-solutions-front-lines-caring" target="_blank" title="Click here to go to the Real Affordability Solutions from the Front Lines of Caring landing page.">Real Affordability Solutions from the Front Lines of Caring</a></p><p><a href="/costsofcaring" target="_blank" title="Click here to view the Cost of Caring report.">Cost of Caring</a></p><p><a href="/standardsguidelines/2021-10-08-partnerships-mergers-and-acquisitions-can-provide-benefits-certain" target="_blank">Partnerships, Mergers, and Acquisitions Can Provide Benefits to Certain Hospitals and Communities</a></p><p><a href="/guidesreports/2021-09-21-financial-effects-covid-19-hospital-outlook-remainder-2021" target="_blank">Financial Effects of COVID-19: Hospital Outlook for the Remainder of 2021</a></p><p><a href="/guidesreports/2021-09-09-results-2018-tax-exempt-hospitals-schedule-h-community-benefit-reports" target="_blank">Results from 2018 Tax-Exempt Hospitals’ Schedule H Community Benefit Reports</a></p><p><a href="/news/perspective/2021-10-08-perspective-confronting-commercial-insurers-practices-threaten-patient" target="_blank">Perspective: Confronting Commercial Insurers’ Practices that Threaten Patient Care</a></p><p><a href="/news/blog/2021-07-12-lown-institute-report-hospital-community-benefits-falls-short" target="_blank">Lown Institute Report on Hospital Community Benefits Falls Short</a></p><p><a href="/news/headline/2021-09-28-study-health-insurance-market-becoming-more-concentrated">Study: Health insurance market becoming more concentrated</a></p><p><a href="https://www.ama-assn.org/delivering-care/patient-support-advocacy/competition-health-insurance-research">Report: American Medical Association Report on Competition in the Health Insurance</a></p></div></div></div></div></div> Tue, 13 Aug 2024 10:00:00 -0500 Regulatory Relief /testimony/2024-05-08-aha-statement-senate-budget-committee-alleviating-administrative-burden-health-care <p class="text-align-center"><strong>Statement</strong><br><strong>of the</strong><br><strong>���������� Association</strong><br><strong>for the</strong><br><strong>Committee on the Budget</strong><br><strong>of the</strong><br><strong>U.S. Senate</strong></p><p class="text-align-center"><strong>Reducing Paperwork, Cutting Costs: Alleviating Administrative Burdens in Health Care</strong></p><p class="text-align-center"><strong>May 8, 2024</strong></p><p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the ���������� Association (AHA) appreciates the opportunity to provide comments on ways to reduce administrative burden and costs in the health care system.</p><h2>PRIOR AUTHORIZATION</h2><p>Inappropriate denials for prior authorization and coverage of medically necessary services are a pervasive problem among certain plans in the Medicare Advantage (MA) program. This results in delays in care, wasteful and potentially dangerous utilization of fail-first requirements for imaging and therapies, and other direct patient harms. These practices also add financial burden and strain to the health care system through inappropriate payment denials and increased staffing and technology costs to comply with plan requirements. Additionally, plan prior authorization requirements are a major burden to the health care workforce and contribute to provider burnout. In fact, Surgeon General Vivek Murthy, M.D., issued a recent <a href="https://www.hhs.gov/sites/default/files/health-worker-wellbeing-advisory.pdf">advisory</a> that notes that burdensome documentation requirements, including the volume of and requirements for prior authorization, are drivers of health care worker burnout.</p><p>Many of the harms associated with inappropriate care delays and denials are evidenced by the <a href="https://oig.hhs.gov/oei/reports/OEI-09-18-00260.pdf">striking report</a> issued in April 2022 by the Department of Health and Human Services Office of Inspector General (HHS OIG). MA plans are denying medically necessary, covered services that met Medicare criteria at an alarming rate. The report found that 13% of prior authorization denials and 18% of payment denials actually met Medicare coverage rules and therefore were inappropriate. In a program the size of MA, improper denials at this rate are unacceptable.</p><p>Streamlining the prior authorization process is vital to MA reform. Plans vary widely on accepted methods of prior authorization requests and supporting documentation submission. The most common methods of prior authorization requests are fax machines and call centers. Additionally, plans that offer electronic submission methods most commonly use proprietary plan portals, which require significant time spent logging into a system, extracting data and completing idiosyncratic plan requirements. For each plan, providers and their staff must ensure they are following the correct rules and processes, which vary substantially between plans and by service, and are often unilaterally changed in the middle of a contact year.</p><p>This heavily burdensome process contributes to patient uncertainty regarding their care plan and creates harmful delays in care. According to a 2022 American Medical Association <a href="https://www.ama-assn.org/system/files/prior-authorization-survey.pdf">survey</a>, 94% of physicians reported care delays associated with prior authorizations, while 80% indicated that prior authorization hassles led to patient abandonment of treatment.</p><p>We greatly appreciate the new regulations issued by the Centers for Medicare & Medicaid Services, which will significantly reduce the burden associated with the prior authorization process. However, greater oversight of MA plans is needed to ensure appropriate access to care. The AHA specifically urges Congress to:</p><p><strong>Establish Controls for MA Plan Usage of Prior Authorization.</strong> The AHA supports The Improving Seniors’ Timely Access to Care Act, which would codify many of the reforms in the Interoperability and Prior Authorization Final Rule to streamline prior authorization requirements under MA plans by making them simpler and more uniform and eliminating the wide variation in prior authorization methods that frustrate both patients and providers. Additionally, we recommend that MA plans be required to deliver prior authorization responses within 72 hours for standard, non-urgent services and 24 hours for urgent services.</p><p><strong>Conduct More Frequent and Targeted Plan Audits.</strong> We urge additional CMS audits be conducted and targeted to specific service types of MA plans that have a history of inappropriate denials or delayed prior authorization response timeframes.</p><p><strong>Establish Provider Complaint Process.</strong> Health care providers, including hospitals and health systems, act on behalf of their patients when working with insurers to obtain approval and coverage for medically necessary care. We encourage Congress to establish a process for health care providers to submit complaints to CMS for suspected violation of federal rules by MA plans.</p><p><strong>Enforce Penalties for Non-Compliance.</strong> Congress should ensure that CMS exercise its authority to enforce penalties for MA plans that fail to comply with federal rules, including the provisions regarding plan reporting and adherence to medical necessity criteria that are not more restrictive than Traditional Medicare. In the recent contract year 2024 Medicare Advantage Rule, CMS noted that a number of the established regulations were already requirements under the health plan terms of participation in the MA program. Given MAOs historic lack of adherence to these rules, Congress should establish stronger programs to hold plans accountable for non-adherence. Additional requirements are insufficient without enforcement action and penalties to support compliance.</p><p><strong>Provide Clarity on the Role of States in MA Oversight.</strong> One of the challenges in regulating MA plans is the split responsibility of insurance oversight between the federal and state governments. To ensure that CMS and states exercise their authorities as needed, we encourage Congress to delineate and strengthen the specific oversight and enforcement responsibilities of state and federal authorities.</p><h2>PROMPT PAYMENT</h2><p>In addition to challenges with inappropriate denials of care, hospitals and health systems are increasingly reporting significant financial impacts from insurers’ failure to pay promptly. An AHA <a href="/infographics/2022-11-01-survey-commercial-health-insurance-practices-delay-care-increase-costs-infographic">member survey</a> found that 50% of hospitals and health systems reported having more than $100 million in unpaid claims that were more than six months old. Among the 772 hospitals surveyed, these delays amounted to more than $6.4 billion in delayed or denied claims that are more than six months old.</p><p>These delays add unnecessary cost and burden to the health care system, as combatting inappropriate delays and denials cost valuable time and resources, including resources needed to comply with insurer requests for additional documentation, physician peer-to-peer consultations and onerous appeal processes — and these processes may still be subject to other types of insurer audits or post-pay reviews that recoup payment to start the process all over again.</p><p>To address these concerns, the AHA urges Congress to add statutory prompt payment requirements for MA plans when services are furnished by in-network providers to enrollees of the MA plans and to subject the MA plans to interest penalties on the amounts owed if they fail to make timely payments.</p><h2>GOLD CARDING</h2><h2><u></u></h2><p>Gold carding programs substantially reduce administrative burdens and costs by streamlining access to care for Medicare beneficiaries. These programs help eliminate unnecessary delays in care by enabling providers who have demonstrated consistent adherence to evidence-based guidelines to be granted exemptions for prior authorization requirements.</p><p>The AHA supports the GOLD Card Act of 2023 (H.R. 4968), which would exempt providers from requiring prior authorization for a MA plan year if the provider had at least 90% of prior authorization requests approved the preceding year.</p><h2>CLAIMS ATTACHMENTS STANDARDIZATION</h2><p><u></u></p><p>Health care providers are currently forced to use burdensome manual processes including mail, fax and online portals when they respond to documentation requests from health plans. The lack of standardization in the claims attachment process has created a significant source of administrative complexity and burden for hospitals and other providers. Standardization of the transmission of clinical data to support claims would greatly reduce the burden created by these inefficient manual processes and eliminate unnecessary claims processing delays.</p><p>The AHA supports CMS’s proposed rule to standardize claims attachments under HIPAA. Requiring the use of a standard would improve the timeliness of patient billing and provider cash flow by reducing processing times between when a claim is submitted and when a health insurer issues payment. This would increase efficiency and help alleviate some of the financial strain facing many hospitals and health systems due to delays in payment. If CMS does not finalize a claims attachment standard rule, we urge Congress to explore ways to leverage its authority to address this issue.</p><h2>CONCLUSION</h2><p>Thank you again for your interest in increasing access to care while reducing unnecessary burdens and costs in the health care system. We look forward to working with you to support and advance these important issues.</p> Wed, 08 May 2024 09:57:42 -0500 Regulatory Relief <p>March 26, 2024 <br><br>Ms. Anne Docimo, M.D.<br>Chief Medical Officer<br>UnitedHealth Care<br>P.O. Box 1459<br>Minneapolis, MN 55440-1459 <br><br>Dear Dr. Docimo:</p><p>On behalf of the ���������� Association’s (AHA) nearly 5,000 member hospitals, health systems and other health care organizations, I write to address UnitedHealthcare’s (UHC) implementation of its Molecular Pathology Reimbursement Policy on April 1, 2024. Due to the substantial administrative burden and potential reimbursement disruption that the policy would create for providers, particularly at a time in which revenue cycle resources are alarmingly strained due to the Change Healthcare cyberattack, we urge UHC to reconsider implementation of this policy, and at a minimum to postpone the effective date until later in the year.</p><p>This policy will require the submission of a DEX Z-Code obtained from the DEX® Diagnostics Exchange Registry for claims to be considered for reimbursement. This code would be <strong><u>in addition to</u></strong> the applicable CPT code, which is the statutorily recognized coding set for reporting medical services for reimbursement. As a result, the policy would create additional UHC-specific coding outside of the standard CPT process, resulting in potential reimbursement denials for claims that meet all HIPAA-mandated CPT and claim formatting requirements. The AHA believes that the CPT process, rather than plan-specific auxiliary reporting requirements, should be the basis of reporting a clinical service on claims. Anything beyond this will require idiosyncratic UHC claims processes that will create enormous administrative burden and lead to unnecessary claim denials for medically necessary and appropriate lab services. In addition, the UHC policy does not specifically justify the need or underlying rationale for this new reporting process, which is a glaring omission considering the substantial disruption that this new requirement could have on provider operations and claims payment.  However, to the extent that the current CPT codes are insufficient or that UHC believes that additional codes are required, UHC should work with the CPT Advisory Panel to update their guides.</p><p>The AHA also has significant concerns about the burdensome registration process associated with this policy. On February 1, 2024, UHC <a href="https://www.uhcprovider.com/en/resource-library/news/2024/ensure-molecular-tests-have-z-code.html">alerted</a> providers that, “Beginning April 1, 2024, UnitedHealthcare commercial plans will require DEX Z-Codes® for certain molecular diagnostic test services on facility and professional claims for the claims to be considered for reimbursement.” To comply with these policies, providers must complete a substantial registration process involving the submission of a lab code, assignment of a Z-code, and UHC issuing a corresponding “recommended CPT code” for the lab – a process that UHC estimates takes approximately 60 days. In other words, hospitals would need to have initiated the registration process on nearly the same date UHC announced the change in policy. It is a wholly inappropriate expectation for a complex organization like a hospital to be able to understand and assess the new policy, make an organizational determination regarding participation, and initiate the registration process. Further complicating the timeline are the tremendous administrative resources required to apply for a specific code for each applicable lab test, particularly if UHC determines that they require additional documentation based on their review of test complexity.</p><p>This policy also would undermine UHC’s efforts “[t]o help reduce the administrative burden on health care professionals and their staff.” Specifically, in August 2023, UHC <a href="https://www.uhcprovider.com/en/resource-library/news/2023/medical-prior-auth-code-reduction-august.html#:~:text=Prior%20authorization%20reduction%20equals%20nearly%2020%20percent%20of%20overall%20volume,-email&text=To%20help%20reduce%20the%20administrative,requirement%20for%20many%20procedure%20codes.">announced</a> its intention to reduce prior authorization requirements by 20%and <a href="https://www.uhcprovider.com/content/dam/provider/docs/public/resources/news/2023/codes/PP-prior-auth-reductions-Commercial.pdf">identified</a> a set of CPT codes for which they would no longer require prior authorization. This list included a large number of molecular and genetic testing codes. Unfortunately, this soon-to-be effective policy to require Z-codes erodes any potential time or cost savings that could have been realized from the removal of prior authorization for molecular pathology codes, simply shifting the burden from prior authorization to other points in the process.</p><p>Furthermore, the implementation of this policy could not come at a worse time for providers throughout the country. Hospital and health system revenue cycle teams have been overwhelmed responding to the impact of the Change Healthcare cyberattack, which has upended many of the electronic transactions on which providers rely resulting in both substantial cashflow and patient care disruptions. Navigating this unprecedented attack has diverted resources away from other billing activities, which would include any registration, systematic implementation, and workflow updates needed to operationalize this policy. Implementing an unnecessary and burdensome policy that could further restrict provider revenue for patient care services – and would require extensive administrative processes to prepare and implement – as the health care system continues reeling from the wake of unprecedented cyber crisis would be irresponsible.</p><p>For these reasons, <strong>the AHA urges UHC to reconsider implementation of the revised Molecular Pathology Reimbursement Policy until further notice.</strong> Please contact me if you have questions, or feel free to have a member of your team contact Terrence Cunningham, AHA Director of Administrative Simplification Policy, at <a href="mailto:tcunningham@aha.org">tcunningham@aha.org</a>.</p><p>Sincerely,</p><p>/s/</p><p>Molly Smith<br>Group Vice President, Public Policy</p> Tue, 26 Mar 2024 14:47:51 -0500 Regulatory Relief <div class="container"><div class="row"><div class="col-md-8"><p>Rural hospitals and health systems are committed to ensuring local access to high-quality, affordable health care. However, these hospitals continue to experience ongoing challenges that jeopardize their ability to provide local access to care and essential services. These include severe underpayments by Medicare and Medicaid, which threaten the financial stability of the health care system; challenges imposed by commercial and Medicare Advantage plans; and a heavy regulatory burden.</p><div class="raw-html-embed"> <div class="col-md-12 cc_tabs"> /* reset */ .cc_tabs ul.a-container { margin: 0; padding: 0; list-style: none; } .cc_tabs input[type=checkbox] { display: none; } /* style */ .cc_tabs .a-container { width: 100%; margin: 20px auto; } .cc_tabs .a-container label { display: block; position: relative; cursor: pointer; font-size: 18px; font-weight: bold; padding: 10px 20px; color: #63666a; background-color: #eee; border-bottom: 1px solid #ddd; -webkit-transition: all .2s ease; -moz-transition: all .2s ease; -ms-transition: all .2s ease; -o-transition: all .2s ease; transition: all .2s ease; margin-bottom:15px } .cc_tabs .a-container label:after { content: ""; width: 0; height: 0; border-top: 8px solid #aaa; border-right: 6px solid transparent; border-bottom: 8px solid transparent; border-left: 6px solid transparent; position: absolute; right: 10px; top: 16px; } .cc_tabs .a-container input:checked + label, .cc_tabs .a-container label:hover { background-color: #003087; color: #fff; } .cc_tabs .a-container input:checked + label:after { border-top: 8px solid transparent; border-right: 6px solid transparent; border-bottom: 8px solid #fff; border-left: 6px solid transparent; top: 6px; } .cc_tabs .a-content { padding: 0 20px 20px; display: none; height:auto; max-height: 40vh; overflow: auto } .cc_tabs .a-container input:checked ~ .a-content { display: block; } /* Style the tab */ .cc_tabs .tab { background-color: #fff; width: auto; height: auto; overflow: auto; } /* Style the buttons inside the tab */ .cc_tabs .tab button { display: block; background-color: lightgray; color: #003087; padding: 10px 16px 10px 20px; width: calc(50% - 30px); border: solid 1px lightgray; outline: none; text-align: center; cursor: pointer; transition: 0.3s; font-size: 20px; float: left; overflow: auto; margin: 0px 15px; -webkit-border-top-left-radius: 15px; -webkit-border-top-right-radius: 15px; -moz-border-radius-topleft: 15px; -moz-border-radius-topright: 15px; border-top-left-radius: 15px; border-top-right-radius: 15px; font-weight: 700; } @media (max-width:452px){ .cc_tabs .tab button{ padding: 10px 5px 10px 5px; width: calc(50% - 4px); font-size: 17px; margin: 0px 2px; } } /* Change background color of buttons on hover */ .cc_tabs .tab button:hover { background-color: #003087; color:#fff } /* Create an active/current "tab button" class */ .cc_tabs .tab button.active { background-color: #003087; color: #ffffff } /* Style the tab content */ .cc_tabs .tab .tabcontent { float: left; padding: 15px 12px; border: 1px solid #ccc; width: 100%; height: auto; } .cc_tabs .tablinks:after { content: '\2610'; color: #777; font-weight: bold; float: right; margin-left: 5px; } .cc_tabs .tablinks.active:after { content: "\2611"; } Get CertifiedRecertify </div> --> <div class="tabcontent" id="General"> <a id="patienttools"> </a> <a id="patienttools"></a> <ul class="a-container"> <li class="a-items"> SUPPORT FLEXIBLE PAYMENT MODELS <div class="a-content"> <p> As the health care field continues to change at a rapid pace, flexible approaches and multiple options for reimbursing and delivering care are more critical than ever to sustain access to services in rural areas. </p> <p> <span><strong>Medicare-dependent Hospital (MDH) and Low-volume Adjustment (LVA).</strong></span> MDHs are small, rural hospitals where at least 60% of admissions or patient days are from Medicare patients. MDHs receive the inpatient prospective payment system (IPPS) rate plus 75% of the difference between the IPPS rate and their inflation-adjusted costs from one of three base years. <span><strong>AHA supports making the MDH program permanent and adding an additional base year that hospitals may choose for calculating payments.</strong></span> The LVA provides increased payments to isolated, rural hospitals with a low number of discharges. <span><strong>AHA also supports making the LVA permanent.</strong></span> The MDH designation and LVA protect the financial viability of these hospitals to ensure they can continue providing access to care. </p> <p> <span><strong>Necessary Provider Designation for Critical Access Hospitals (CAHs).</strong></span> The CAH designation allows small rural hospitals to receive cost-based Medicare reimbursement, which can help sustain services in the community. Hospitals must meet several criteria, including a mileage requirement, to be eligible.  A hospital can be exempt from the mileage requirement if the state certifies the hospital as a necessary provider, but only hospitals designated before Jan. 1, 2006 are eligible. <span><strong>AHA urges Congress to reopen the necessary provider CAH program to further support local access to care in rural areas.</strong></span> </p> <p> <span><strong>Rural Emergency Hospital (REH) Model.</strong></span> REHs are a Medicare provider type that small rural and critical access hospitals can convert to in order to provide emergency and outpatient services without needing to provide inpatient care. REHs are paid a monthly facility payment and the outpatient prospective payment system (OPPS) rate plus 5%. <span><strong>AHA continues to support strengthening and refining the REH model to ensure sustainable care delivery and financing.</strong></span> </p> <p> <span><strong>Rebasing for Sole Community Hospitals (SCHs).</strong></span><strong> </strong>SCHs must show they are the sole source of inpatient hospital services reasonably available in a certain geographic area to be eligible. They receive increased payments based on their cost per discharge in a base year. <span><strong>AHA supports adding an additional base year that SCHs may choose for calculating their payments.</strong></span> </p> </div> </li> <li class="a-items"> ENSURE FAIR REIMBURSEMENT, ACCESS TO CAPITAL & REGULATORY RELIEF <div class="a-content"> <p> Medicare and Medicaid pay only 82 cents for every dollar spent caring for patients, according to the latest AHA data. <strong>Given the challenges of providing care in rural areas, reimbursement rates across payers need to be updated to cover the cost of care.</strong> </p> <p> <span><strong>Telehealth.</strong></span><strong> </strong>Telehealth services are a crucial access point for many patients. AHA supports legislation to make permanent coverage of certain telehealth services made possible during the pandemic, including lifting geographic and originating site restrictions, allowing Rural Health Clinics and Federally Qualified Health Centers to serve as distant sites, expanding practitioners who can provide telehealth and allowing hospital outpatient billing for virtual services, among others. </p> <p> <span><strong>Infrastructure Financing for Rural Hospitals.</strong></span> Many rural hospitals were constructed following the passage of the Hill-Burton Act of 1947, which provided grants and loans for the construction and modernization of hospitals. Currently, many rural hospitals need to update their facilities and services to continue meeting the needs of their community. Yet, narrow financial margins limit rural hospitals’ ability to retain earnings and secure access to capital or qualify for U.S. Department of Agriculture or U.S. Department of Housing and Urban Development mortgage guarantees. Without those resources, rural hospitals are sometimes unable to update facilities. <span><strong>The AHA urges Congress to help ensure that vulnerable communities are able to preserve access to essential health care services by providing infrastructure funding for hospitals that restructure their facilities and services to meet community needs.</strong></span> </p> <p> <span><strong>Reverse Rural Health Clinic (RHC) Payment Cuts.</strong></span> RHCs provide access to primary care and other important services in rural, underserved areas.<strong> </strong><span><strong>AHA urges Congress to repeal payment caps on  provider-based RHCs</strong></span> that limit access to care. </p> <p> <span><strong>Maternal and Obstetric Care.</strong></span><strong> </strong>Maternal health is a top priority for AHA and its rural members. We urge Congress to continue to fund programs that improve or maintain access to maternal and obstetric care in rural areas, including supporting the maternal workforce, promoting best practices and educating health care professionals. </p> <p> <span><strong>Wage Index Floor.</strong></span> AHA supports legislation that would place a floor on the area wage index, effectively raising the area wage index for hospitals below that threshold with new money. </p> <p> <span><strong>96-hour Rule</strong></span>. <span><strong>We urge Congress to pass legislation to permanently remove the 96-hour physician certification requirement for CAHs.</strong></span><strong> </strong>These hospitals still would be required to satisfy the condition of participation requiring a 96-hour annual average length of stay, but removing the physician certification requirement would allow CAHs to serve patients needing critical medical services that have standard lengths of stay greater than 96 hours. </p> <p> <span><strong>Ambulance Add-on Payment.</strong></span> Rural ambulance service providers ensure timely access to emergency medical care but face higher costs than other areas due to lower patient volume. <span><strong>We support permanently extending the existing rural and “super rural” ambulance add-on payments to protect access to these essential services.</strong></span> </p> <p> <span><strong>Regulatory Burden</strong></span><strong>.</strong> Reduce regulatory burden by identifying and advocating for the repeal of unnecessary and duplicative Conditions of Participation that increase hospital inefficiency and reduce the time providers can spend caring for their patients. </p> </div> </li> <li class="a-items"> COMMERCIAL INSURER ACCOUNTABILITY <div class="a-content"> <p> Underpayment by commercial insurance plans and systematic and inappropriate payment delays for medically necessary care are putting patient access to care at risk.  </p> <p> <span><strong>Cost-based Reimbursement for Critical Access Hospitals (CAHs) from Medicare Advantage (MA) Plans</strong></span>. Congress created a special statutory payment designation for CAHs in recognition of the unique role they play in preserving access to health care services in rural areas. As certain MA plans in rural communities rapidly grow, there is an erosion of this important financial protection. A greater portion of a CAH’s revenue will be subject to negotiations with MA plans that often result in below-cost payment terms and involve onerous plan requirements that contribute to administrative burden, unnecessary delays and denials in approving and paying for patient care, and additional strains on the health care workforce.<span><strong> We support legislation to ensure CAHs receive cost-based reimbursement for MA patients. </strong></span> </p> <p> <span><strong>Prompt Pay</strong></span>. Ensure prompt payment from insurers for medically necessary, covered health care services delivered to patients. <span><strong>We support policies to increase oversight and accountability of health plans including establishing more stringent standards for timely payment</strong></span> to address certain insurer tactics to delay and deny payment to health care providers.  </p> <p> <span><strong>Prior Authorization</strong></span>. Hold commercial health insurers accountable for ensuring patients have timely access to care, including by reducing the excessive use of prior authorization, ensuring expeditious prior authorization decisions and eliminating inappropriate denials for services that should be covered. <span><strong>We support building on recent regulations and legislation that further streamline and improve prior authorization processes.</strong></span> </p> <div class="a-content"> <a> </a> <p class="MsoNormal"> <span></span> </p> <p> Underpayment by commercial insurance plans and systematic and inappropriate payment delays for<br> medically necessary care are putting patient access to care at risk. </p> <strong> <p> <span><strong>Cost-based Reimbursement for Critical Access Hospitals (CAHs) from Medicare Advantage (MA) Plans.</strong></span><strong> </strong>Congress created a special statutory payment designation for CAHs in recognition of the unique role they play in preserving access to health care services in rural areas. As certain MA plans in rural communities rapidly grow, there is an erosion of this important financial protection. A greater portion of a CAH’s revenue will be subject to negotiations with MA plans that often result in below-cost payment terms and involve onerous plan requirements that contribute to administrative burden, unnecessary delays and denials in approving and paying for patient care, and additional strains on the health care workforce.  <span><strong>We support legislation to ensure CAHs receive cost-based reimbursement for MA patients.</strong></span> </p> <p> <span><strong>Prompt Pay.</strong></span><strong> </strong>Ensure prompt payment from insurers for medically necessary, covered health care services delivered to patients. <span><strong>We support policies to increase oversight and accountability of health plans including establishing more stringent standards for timely payment </strong></span>to address certain insurer tactics to delay and deny payment to health care providers. </p> <p> <span><strong>Prior Authorization.</strong></span> Hold commercial health insurers accountable for ensuring patients have timely access to care, including by reducing the excessive use of prior authorization, ensuring expeditious prior authorization decisions and eliminating inappropriate denials for services that should be covered. <span><strong>We support building on recent regulations and legislation that further streamline and improve prior authorization processes.</strong></span> </p> </strong> </div> <strong> </strong> </div> </li> <li class="a-items"> BOLSTER THE WORKFORCE <div class="a-content"> <p> Recruitment and retention of health care professionals is an ongoing challenge and expense for rural hospitals. Nearly 70% of the primary care health professional shortage areas (HPSAs) are located in rural or partially rural areas. Targeted programs that help address workforce shortages in rural communities should be supported and expanded. Workforce policies and programs also should encourage nurses and other allied professionals to practice at the top of their license.  </p> <p> <span><strong>Graduate Medical Education</strong></span>. We urge Congress to enact legislation that would lift existing caps on the number of Medicare-funded residency slots, which would help alleviate physician shortages in rural and other underserved areas and improve patients’ access to care. We also support robust funding for rural residency track programs, which provide medical residents additional training opportunities in rural areas.  </p> <p> <span><strong>Conrad State 30 Program</strong></span>. We urge Congress to make permanent and expand the Conrad State 30 J-1 visa waiver program, which waives the requirement for physicians holding J-1 visas to return home for a period if they agree to stay in the U.S. for three years and practice in underserved areas.  </p> <p> <span><strong>Loan Repayment Programs</strong></span>. We urge Congress to pass legislation to provide incentives for clinicians to practice in rural HPSAs. We support expanding the National Health Service Corps and the National Nurse Corps, which incentivize health care graduates to provide health care services in underserved areas.  </p> <p> <span><strong>Visa Recapture</strong></span>. We urge Congress to pass legislation to recapture up to 40,000 unused employment visas for foreign-trained workers (25,000 for nurses and 15,000 for physicians). </p> </div> </li> <li class="a-items"> PROTECT THE 340B PROGRAM <div class="a-content"> <p> The 340B Drug Pricing Program helps CAHs, Sole Community Hospitals, Rural Referral Centers and other disproportionate share hospitals serving vulnerable populations stretch scarce resources. Section 340B of the Public Health Service Act requires pharmaceutical companies participating in Medicaid to sell outpatient drugs at discounted prices to organizations that care for many uninsured and low-income patients. </p> <p> Hospitals use 340B savings, for example, to provide free care for uninsured patients, offer free vaccines, provide services in mental health clinics and implement medication management and community health programs. The AHA opposes any efforts to undermine the 340B program and harm the patients and communities it serves, including drug company efforts to diminish the program by limiting contract pharmacy arrangements and attempting to change access to 340B pricing from an upfront discount to a back-end rebate. </p> </div> </li> </ul> </div> <strong> <div class="col-md-12 cc_tabs"> /* reset */ .cc_tabs ul.a-container { margin: 0; padding: 0; list-style: none; } .cc_tabs input[type=checkbox] { display: none; } /* style */ .cc_tabs .a-container { width: 100%; margin: 20px auto; } .cc_tabs .a-container label { display: block; position: relative; cursor: pointer; font-size: 18px; font-weight: bold; padding: 10px 20px; color: #63666a; background-color: #eee; border-bottom: 1px solid #ddd; -webkit-transition: all .2s ease; -moz-transition: all .2s ease; -ms-transition: all .2s ease; -o-transition: all .2s ease; transition: all .2s ease; margin-bottom:15px } .cc_tabs .a-container label:after { content: ""; width: 0; height: 0; border-top: 8px solid #aaa; border-right: 6px solid transparent; border-bottom: 8px solid transparent; border-left: 6px solid transparent; position: absolute; right: 10px; top: 16px; } .cc_tabs .a-container input:checked + label, .cc_tabs .a-container label:hover { background-color: #003087; color: #fff; } .cc_tabs .a-container input:checked + label:after { border-top: 8px solid transparent; border-right: 6px solid transparent; border-bottom: 8px solid #fff; border-left: 6px solid transparent; top: 6px; } .cc_tabs .a-content { padding: 0 20px 20px; display: none; height:auto; max-height: 40vh; overflow: auto } .cc_tabs .a-container input:checked ~ .a-content { display: block; } /* Style the tab */ .cc_tabs .tab { background-color: #fff; width: auto; height: auto; overflow: auto; } /* Style the buttons inside the tab */ .cc_tabs .tab button { display: block; background-color: lightgry; color: #003087; padding: 10px 16px 10px 20px; width: calc(50% - 30px); border: solid 1px lightgray; outline: none; text-align: center; cursor: pointer; transition: 0.3s; font-size: 20px; float: left; overflow: auto; margin: 0px 15px; -webkit-border-top-left-radius: 15px; -webkit-border-top-right-radius: 15px; -moz-border-radius-topleft: 15px; -moz-border-radius-topright: 15px; border-top-left-radius: 15px; border-top-right-radius: 15px; font-weight: 700; } @media (max-width:452px){ .cc_tabs .tab button{ padding: 10px 5px 10px 5px; width: calc(50% - 4px); font-size: 17px; margin: 0px 2px; } } /* Change background color of buttons on hover */ .cc_tabs .tab button:hover { background-color: #003087; color:#fff } /* Create an active/current "tab button" class */ .cc_tabs .tab button.active { background-color: #003087; color: #ffffff } /* Style the tab content */ .cc_tabs .tab .tabcontent { float: left; padding: 15px 12px; border: 1px solid #ccc; width: 100%; height: auto; } .cc_tabs .tablinks:after { content: '\2610'; color: #777; font-weight: bold; float: right; margin-left: 5px; } .cc_tabs .tablinks.active:after { content: "\2611"; } Get CertifiedRecertify </div> --> </div> </strong> </div> <strong> <p class="a-items"> <ul class="a-container"> item 1 <div class="a-content"> <p> ==== </p> </div> </li> </ul> <div> --> function openCity(evt, cityName) { var i, tabcontent, tablinks; tabcontent = document.getElementsByClassName("tabcontent"); for (i = 0; i < tabcontent.length; i++) { tabcontent[i].style.display = "none"; } tablinks = document.getElementsByClassName("tablinks"); for (i = 0; i < tablinks.length; i++) { tablinks[i].className = tablinks[i].className.replace(" active", ""); } document.getElementById(cityName).style.display = "block"; evt.currentTarget.className += " active"; } // Get the element with id="defaultOpen" and click on it document.getElementById("defaultOpen").click(); </p> </strong> </div><p> </p><p class="a-items"> Get CertifiedRecertify </div> --> <ul class="a-container"> item 1 <div class="a-content"> <p> ==== </p> </div> </li> </ul> <div> --> function openCity(evt, cityName) { var i, tabcontent, tablinks; tabcontent = document.getElementsByClassName("tabcontent"); for (i = 0; i < tabcontent.length; i++) { tabcontent[i].style.display = "none"; } tablinks = document.getElementsByClassName("tablinks"); for (i = 0; i < tablinks.length; i++) { tablinks[i].className = tablinks[i].className.replace(" active", ""); } document.getElementById(cityName).style.display = "block"; evt.currentTarget.className += " active"; } // Get the element with id="defaultOpen" and click on it document.getElementById("defaultOpen").click(); </p></div><div class="col-md-4"><p class="text-align-center"><a class="btn btn-primary" href="/system/files/media/file/2025/02/2025-Rural-Advocacy-Agenda.pdf">Download the Rural Advocacy Agenda</a><br> </p><p><a href="/system/files/media/file/2025/02/2025-Rural-Advocacy-Agenda.pdf"><img src="/sites/default/files/inline-images/cover-2025-Rural-Advocacy-Agenda_0.png" data-entity-uuid="43454eb5-2a7a-44ba-a764-b47efb669806" data-entity-type="file" width="655" height="847" alt="AHA 2025 Rural Advocacy Agenda page 1."></a></p><p> </p><p><a class="btn btn-wide btn-primary" href="/advocacy/2020-01-27-rural-advocacy-agenda-archives">View the Rural Advocacy Agenda Archives</a></p><p><a class="btn btn-wide btn-primary" href="/advocacy-agenda" title="2025 AHA Advocacy Agenda PDF">View the AHA 2025 Advocacy Agenda</a></p></div></div></div> Fri, 23 Feb 2024 23:01:00 -0600 Regulatory Relief /lettercomment/2023-10-04-aha-responds-cms-requirement-report-telehealth-provider-home-addresses <div class="container"> <div class="row"> <div class="col-md-8"> <p>October 4, 2023</p> <p>The Honorable Chiquita Brooks-LaSure<br> Administrator<br> Centers for Medicare & Medicaid Services<br> Hubert H. Humphrey Building<br> 200 Independence Avenue, S.W., Room 445-G<br> Washington, DC 20201</p> </div> <div class="col-md-4"> <div class="external-link spacer"><a class="btn btn-wide btn-primary" href="/system/files/media/file/2023/10/AHA-Responds-to-CMS-Requirement-to-Report-Telehealth-Provider-Home-Addresses.pdf" target="_blank" title="Click here to download the AHA Responds to CMS’ Requirement to Report Telehealth Provider Home Addresses letter PDF.">Download the Letter PDF</a></div> </div> </div> <div class="row"> <div class="col-md-8"> <p><em>Submitted Electronically</em></p> <p><strong><em>Re: Provider Home Address Reporting Requirements</em></strong></p> <p>Dear Administrator Brooks-LaSure:</p> <p>On behalf of our nearly 5,000 member hospitals, health systems and other health care organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 health care leaders who belong to our professional membership groups, the ���������� Association (AHA) appreciates the Centers for Medicare & Medicaid Services’ (CMS’) continued support of telehealth services and ongoing work to create a long-term structure for the efficient provision of digital care.</p> <p>At the outset of the COVID-19 pandemic, CMS moved quickly to issue regulatory waivers to ensure hospitals and health systems could leverage telehealth services to efficiently and effectively respond to a wave of unprecedented need. While the waivers were intended to support the administration of care during the pandemic, the resulting unprecedented growth in telehealth services fundamentally transformed care delivery, expanded access for millions and increased convenience in caring. For example, waivers allowed practitioners to render telehealth services from their home without having to report their home address on Medicare enrollment or claims forms. However, CMS issued guidance in a Frequently Asked Questions document that the waiver will continue through Dec. 31, 2023.<sup><a href="#fn1">1</a></sup> As such, beginning Jan. 1, 2024, these providers will be required to report their home address on enrollment and claims forms.</p> <p><strong>While we understand and support CMS attempting to establish appropriate reporting for program integrity, we are deeply concerned with this requirement. It poses potential privacy issues to providers since home addresses may be publicly available without their knowledge or consent on sites like Medicare Care Compare. We therefore urge CMS to permanently remove this requirement as soon as possible.</strong> At a minimum, the agency should conduct rulemaking to propose a process, solicit alternative options and extend the current waivers until rules can be finalized with an appropriate transition time for organizations to comply.</p> <h2>Reporting Home Addresses Poses Privacy and Safety Concerns</h2> <p><strong>Requiring providers to list their personal home addresses on enrollment and claims forms, to which patients or others in the public have access, poses privacy and safety risks. This is a particular concern to us given the increased incidence in violence against health care workers.</strong> The pandemic placed significant stress on the entire health care system, and unfortunately, in some situations, patients, visitors and family members have attacked health care staff and jeopardized our workforce’s ability to provide care. Recent studies indicate, for example, that 44% of nurses reported experiencing physical violence and 68% reported experiencing verbal abuse during the COVID-19 pandemic.<sup><a href="#fn2">2</a></sup> A report from the Bureau of Labor Statistics found that even before the pandemic, amongst all industries, health care and social service industries have the highest rates of injury due to workplace violence.<sup><a href="#fn3">3</a></sup> In fact, health care workers were five times more likely to experience workplace violence injuries than all workers.<sup><a href="#fn4">4</a></sup></p> <p>Requiring providers to report their home addresses in a manner that may be posted publicly exposes our workforce to unnecessary and inappropriate risk. They cannot provide attentive care in such an environment. <strong>At a minimum, CMS must implement a mechanism to automatically mask the home address from any public sites and directories.</strong></p> <h2>The Requirement Will Erode Telehealth’s Potential as a Provider Retention Tool</h2> <p>Given the experience with COVID-19, many hospitals, health systems and providers have moved to hybrid schedules where some physicians and staff work remotely. This fosters improved retention, especially in light of the significant staffing shortages nationwide. Specifically, providers can manage patient panels that may be geographically dispersed, while minimizing travel time to different settings. Yet, requiring providers to list their home address may disincentivize them from delivering telehealth services altogether (since they do not want their personal address listed publicly) and as such minimize telehealth’s potential as a workforce retention tool for organizations.</p> <h2>The Requirement Poses Untenable Administrative Burden</h2> <p>Hospitals and health systems also are concerned about the operational and administrative burden of completing enrollment forms for provider home addresses, as well as tracking and reporting changes in providers’ home addresses if they move. Given the current timeline, it is not operationally feasible for many organizations not only to update enrollment forms for all providers administering telehealth from their homes, but also to make necessary updates in billing software and electronic health records to add home addresses as sites of care. It also would add costs for organizations to update systems and for CMS and the Medicare Administrative Contractors to process changes when providers move.</p> <p>We appreciate your consideration of our requests. Please contact me if you have questions or feel free to have a member of your team contact Jennifer Holloman, AHA’s senior associate director of policy, at <a href="mailto:jholloman@aha.org?subject=RE: AHA Responds to CMS’ Requirement to Report Telehealth Provider Home Addresses">jholloman@aha.org</a>, or Joanna Hiatt Kim, AHA’s vice president of payment policy, at <a href="mailto:jkim@aha.org?subject=RE: AHA Responds to CMS’ Requirement to Report Telehealth Provider Home Addresses">jkim@aha.org</a>.</p> <p>Sincerely,</p> <p>/s/</p> <p>Ashley Thompson<br> Senior Vice President<br> Public Policy Analysis and Development</p> <hr> <ol> <li id="fn1"><a href="https://www.cms.gov/files/document/physicians-and-other-clinicians-cms-flexibilities-fight-covid-19.pdf" target="_blank">https://www.cms.gov/files/document/physicians-and-other-clinicians-cms-flexibilities-fight-covid-19.pdf</a></li> <li id="fn2"><a href="/system/files/media/file/2022/09/Fact-Sheet-Workplace-Violence-and-Intimidation-and-the-Need-for-a-Federal-Legislative-Response.pdf">/system/files/media/file/2022/09/Fact-Sheet-Workplace-Violence-and-Intimidation-and-the-Need-for-a-Federal-Legislative-Response.pdf</a></li> <li id="fn3"><a href="https://www.bls.gov/iif/factsheets/workplace-violence-healthcare-2018.htm" target="_blank">https://www.bls.gov/iif/factsheets/workplace-violence-healthcare-2018.htm</a></li> <li id="fn4"><a href="https://www.bls.gov/iif/factsheets/workplace-violence-healthcare-2018.htm" target="_blank">Ibid.</a></li> </ol> </div> <div class="col-md-4"> <p><a href="/system/files/media/file/2023/10/AHA-Responds-to-CMS-Requirement-to-Report-Telehealth-Provider-Home-Addresses.pdf" target="_blank" title="Click here to download the AHA Responds to CMS’ Requirement to Report Telehealth Provider Home Addresses letter PDF."><img alt="AHA Responds to CMS’ Requirement to Report Telehealth Provider Home Addresses letter page 1." data-entity-type="file" data-entity-uuid="50e892c2-42a3-44e8-8151-2d9de60d692c" src="/sites/default/files/inline-images/Page-1-AHA-Responds-to-CMS-Requirement-to-Report-Telehealth-Provider-Home-Addresses.png" width="692" height="900"></a></p> </div> </div> </div> Wed, 04 Oct 2023 06:00:00 -0500 Regulatory Relief /news/headline/2023-03-10-bill-would-repeal-medicares-96-hour-rule-critical-access-hospitals <p>Reps. Adrian Smith, R-Neb., and Terri Sewell, D-Ala., today introduced legislation that would repeal a Medicare rule that requires physicians at a Critical Access Hospital to certify that inpatients are likely to be discharged or transferred to another hospital within 96 hours. AHA has <a href="/rural-advocacy-agenda" target="_blank">urged</a> Congress to pass legislation to permanently remove the requirement. </p> <p>“The ���������� Association applauds Representatives Smith and Sewell for their leadership in working to permanently remove the 96-hour condition of payment for Critical Access Hospitals,” said Aimee Kuhlman, AHA’s vice president of advocacy and grassroots. “This would allow CAHs to serve patients needing critical medical services that may have lengths of stay greater than 96 hours. CAHs play a vital role treating patients and saving lives each and every day, and this legislation is long overdue for rural hospitals to be able to provide the types of services their communities need and seek close to home.”</p> Fri, 10 Mar 2023 14:49:16 -0600 Regulatory Relief /news/headline/2023-02-07-op-ed-working-congress-keep-our-hospitals-strong-and-communities-healthy <p>In an op-ed yesterday in The Hill, AHA President and CEO Rick Pollack explains why hospitals and health systems are working with government and other stakeholders this year to enact legislation and policies to ensure access to care and provide financial, regulatory and administrative relief; strengthen the health care workforce; and advance health care quality, equity and transformation. <strong><a href="https://thehill.com/opinion/congress-blog/3846172-working-with-congress-to-keep-our-hospitals-strong-and-communities-healthy/">READ MORE</a></strong>   </p> Tue, 07 Feb 2023 16:02:00 -0600 Regulatory Relief /news/perspective/2023-01-06-advancing-health-america-bipartisan-goal-we-can-all-get-behind <p>The convening of the 118th Congress this week is a reminder of Washington’s highly-charged political environment.</p> <p>The once-in-a-century floor tussle over the Republicans’ selection for Speaker of the House; the narrow Democratic majority in the Senate and slim GOP majority in the House; and the specter of the 2024 presidential election looming over everything all point to a challenging period ahead.</p> <p>But we also know our country – and our nation’s hospitals and health systems – are facing significant challenges that will require bipartisan compromise and bold action.</p> <p><strong>Preserving the ability of hospitals and health systems to continue to advance health for individuals and communities is not a Republican issue or a Democratic issue. It is an American issue that transcends party politics. And that’s why the AHA will continue to approach and frame all of our initiatives in a manner that can gain bipartisan support.</strong></p> <p>In fact, thanks in large part to hospital leaders’ efforts to share their stories, many members of both parties have already shown their recognition of the immense pressure America’s hospitals, health systems and caregivers are facing.</p> <p>Just a few weeks ago, Congress passed and President Biden signed legislation that prevented massive new Medicare cuts, mitigated physician payment reductions, extended critical regulatory flexibilities provided under the Public Health Emergency for telehealth and the Acute Hospital Care at Home program, extended vital rural health programs, improved access to behavioral health, and put into place a practical glide-path for dealing with Medicaid – that protects historically marginalized populations – as we approach the expected end of the PHE, among other provisions. See our detailed <a href="/special-bulletin/2022-12-20-appropriations-committees-release-omnibus-spending-bill-health-provisions?utm_source=newsletter&utm_medium=email&utm_campaign=aha-today" target="_blank">summary of provisions</a> included in the legislation.</p> <p>While we were pleased to secure some very important provisions, we recognize this is just a part of what needs to be done to support hospitals and those on the front lines caring for patients.</p> <p>Hospitals and health systems just concluded the most difficult financial year since the start of the pandemic. These financial struggles are expected to continue this year as the field continues to experience exorbitant increases for the costs of caring for patients, including labor, drugs and supplies.</p> <p>This year, the AHA will work with Congress – including the seven new senators and 75 new representatives – and the Administration in a bipartisan manner to educate them on the challenges facing the field and enact provisions that have bipartisan support to advance health for patients and communities. Be certain, we will be working to educate these new legislators and you can also play a role in doing that. Starting later this month, we’ll be offering new tools and resources that can assist you in your advocacy efforts with your lawmakers, including tips on engagement and outreach to enhance your relationships.</p> <p>We will work to:</p> <ul> <li>Establish a temporary per-diem payment targeted to hospitals to address the issue of hospitals not being able to discharge patients to post-acute care or behavioral facilities because of staffing shortages.<br />  </li> <li>Create a designation for metropolitan anchor hospitals that assist hospitals that have extremely high volumes of Medicare, Medicaid and uninsured patients and typically serve historically marginalized communities.<br />  </li> <li>Examine the method of updating Medicare payment rates through the market basket when the cost of caring or input prices hospitals are forced to absorb outstrip annual adjustments.<br />  </li> <li>Protect the 340B drug pricing program.<br />  </li> <li>Strengthen the workforce, including protecting health care workers from violence and increasing the talent pipeline for the future.<br />  </li> <li>Relieve the field of unnecessary regulatory and other administrative burdens and hold commercial health plans accountable for policies that compromise patient safety and add burden to care providers.</li> </ul> <p>These are only a few of our priorities for 2023. We’re continuing to work on our short-term agenda for financial relief with the AHA Board of Trustees, and state and metropolitan hospital associations. Watch for our detailed 2023 Advocacy Agenda later this month.</p> <p>At the same time, our Board of Trustees also will be focusing on the long-term strategies necessary to secure our future. These require innovative, bold and creative solutions to ensure that hospitals remain key players in delivering care in their communities not only for today but for tomorrow too.</p> <p>America needs strong hospitals and health systems so we can have healthy and thriving communities. We must do everything we can to support our caregivers and ensure that the care will always be there.</p> Fri, 06 Jan 2023 09:56:51 -0600 Regulatory Relief