With the New Year upon us, HW&Co. would like to wish you a happy, healthy and prosperous New Year. The New Year always brings many changes to the Long-Term Care Industry even in years that we are not dealing with the challenges of a pandemic. We are pleased to provide you with updates on some of these changes.

In this issue:

  1. PRF Reporting Period 4 Now Open
  2. 2023 Part B Fee Schedules
  3. Therapy Caps Update
  4. Multiple Procedure Payment Reduction Remains in Effect
  5. Make Sure your PS&R System Login is Active!
  6. 2023 Medicare Part A Coinsurance & Medicare Part B Deductible
  7. January 1, 2023 Ohio SNF Medicaid Rates
  8. House Bill 45 – Relief Funding for Ohio Healthcare Providers
  9. Medicaid Benchmarking Reports Available

PRF REPORTING PERIOD 4 IS NOW OPEN

Reporting Period 4 for Federal Provider Relief Funding is now open.  All providers who received more than $10,000 of Provider Relief Funds (PRF) between July 1, 2021 and December 31, 2021 must report to the Health Resources Services Administration (HRSA) no later than March 31, 2023. This would include most providers who received either PRF Phase 4 funds or ARPA Rural distribution funds.

The reporting portal is available on the HRSA website, which also includes information and FAQs on allowable expenses and other reporting matters.

Please contact us if you need any assistance with your Provider Relief Fund reporting.

MEDICARE UPDATES

2023 Part B Fee Schedules

The Medicare Part B Physician Fee Schedule Final rule was released by the Centers for Medicare & Medicaid Services (CMS) on November 2, 2022.  The final rule called for cuts of 4.5% to overall fee schedule payments.  The cuts were the result of the expiration of a temporary increase passed last year to avoid cuts and a budget neutrality adjustment.

However, on December 27, 2022, President Biden signed the “Consolidated Appropriations Act, 2023” which reduced the cut to approximately 2.0%.  The final conversion factor, the main underlying component of the fee schedule payment calculation, is $33.89, which is lower than last year’s conversion factor but considerably higher than the 2023 final rule.  As with every year, the payment rates for individual HCPCS codes may vary from the stated percentage change due to changes in the other underlying components of the payment calculation.

The Therapy fee schedules provided below are effective from January 1, 2023 through December 31, 2023.  It is important to forward the fee schedules to your business office personnel to use for January bills. Our Revenue Cycle Consultants are available to assist with any billing questions you may have. In addition, if you use PointClickCare, the Part B fee schedules are automatically updated in your system.

2023 Ohio Therapy Medicare Part B Fee Schedule

Many of the fee schedules change or are updated every quarter. Please review the appropriate schedule based on the Centers for Medicare & Medicaid Services (CMS) updates. Check the CMS website regularly for updates to these schedules. Please note that these schedules are not all-inclusive. We have attempted to limit this information to the most commonly used Healthcare Common Procedure Coding System (HCPCS) codes for long-term care facilities.

Fee schedules for lab, radiology, PEN and DMEPOS services are also available.  These fee schedules may be helpful in negotiating contracts with your ancillary service providers.  Please contact your HW Healthcare Advisor if you would like a copy of one of these fee schedules for 2023 services.

 

Therapy Caps Update

The therapy caps for Part B therapy services were eliminated in the Bipartisan Budget Act of 2018.  However, the KX modifier must still be used when services over the limits are provided as a provider attestation of medical necessity.  The limits for 2023 are $2,230 for physical and speech therapy (combined) and occupational therapy.  The 2018 budget act also lowered the threshold for targeted medical reviews of therapy claims from $3,700 to $3,000, which will be in effect through calendar year 2028.

 

Multiple Procedure Payment Reduction Remains in Effect

The Multiple Procedure Payment Reduction (MPPR) remains in effect for 2023. The MPPR cuts the practice component of the fee schedule payment for certain HCPCS codes by 50% when more than one kind of therapy is provided to a resident in a single day.

For 2023, the MPPR covers therapy services billed under 51 different HCPCS.  The last column of the therapy fee schedules provided above shows the payment that would be made under the MPPR for the affected therapy codes.

 

Make Sure your PS&R System Login is Active!

Just a quick reminder that passwords for the CMS PS&R system expire every 60 days and must be changed.  In addition, to avoid being locked out, the PS&R system must be accessed at least once every six months.  We recommend you address any password or login issues now to avoid delays in accessing your PS&R reports for the Medicare cost reports due in May.

Please contact your HW Healthcare Advisor if you have any questions on accessing the PS&R system.

 

2023 Medicare Part A Coinsurance & Medicare Part B Deductible

Effective January 1, 2023, the Medicare Part A coinsurance rate for SNFs will increase to $200.00 per day from $194.50 for days 21 through 100. The Part B deductible will be $226.00 for 2023, down $7 from 2022.

MEDICAID UPDATES

January 1, 2023 Ohio SNF Medicaid Rates

The Ohio Department of Medicaid (ODM) has posted updated rate letters to providers’ MITS portals in for new rates effective January 1, 2023.  For most providers, the only change was an update to the direct care price for the average of June and September 2022 case mix scores. The statewide average rate increased by $.35 to $232.07.

We recommend you review your rate closely to ensure it has been calculated correctly.  Should you believe ODM has made an error, you must file a request for rate reconsideration within 30 days of the date of the rate letter.  Please contact us if you would like an analysis of your rate.

 

House Bill 45 – Relief Funding for Ohio Healthcare Providers

Governor Mike DeWine recently signed House Bill 45, a significant appropriations bill that included relief funding for several types of healthcare providers.  The bill included $345 million for skilled nursing facilities and $40 million for assisted living facilities, with additional funding for other providers, including Medicaid waiver and hospice providers.

The nursing facility funding will be determined using a calculation based on 2021 Medicaid days and July 1, 2022 quality points.  The funding is split 60% to the quality portion of the payment and 40% to the Medicaid days portion of the payment.  The quality points payment will use the July 1, 2022 points earned, with no exclusion for those under the 25th percentile.  In addition, facilities with occupancy in excess of 75% in 2021 will receive an additional 7.5 quality points for purposes of this calculation.  We have provided our clients with estimated payments.  Please contact your HW Healthcare Advisor with any questions.

Assisted living providers will likely be paid based on licensed residential care beds, similar to prior assisted living relief payments.  We estimate the payment to be approximately $600 per licensed bed.

The funds will be paid by the Ohio Office of Budget Management (OBM).  As a result, we expect OBM to use the same application portal that was used for the Coronavirus Relief Fund payments in 2020.  The portal has not yet opened.  We will continue to update our clients as more information is known.

 

Medicaid Benchmarking Reports Available

The 2021 Medicaid Nursing Facility (NF) Cost Report database from ODM and the ICF-IID cost report database from DODD allow us to analyze annual cost, census, and staffing trends.  We can compare your facility’s expenses, census and staffing against selected competitors, as well as county, peer group and statewide averages.  These reports provide valuable information to assist you in optimizing the operations of your facility.  Please contact us if you are interested in a benchmarking report.

HW HEALTHCARE ADVISORS

Our team consists not only of CPAs, but also highly trained and experienced billing/revenue cycle consultants, certified medical office managers and LNHAs.  We are dedicated to working with the regulatory, operational and reimbursement challenges that providers face in an ever-changing healthcare environment.

We can assist you in streamlining your processes, optimizing your operations and identifying potential opportunities and risks.  Please contact any of our HW Healthcare Advisors to discuss how we can help you and your facility stay on the path to success.

 

Disclaimer:  Information in this article is subject to change and is based upon current information as of the issue date.

Steve Anderson CPA
Principal
steven.anderson@hwco.cpa