August is traditionally a quiet month in D.C. when Congress is out on recess, less traffic and many people enjoying the last few weeks of summer before school starts again. However, this year is not traditional. As we focus on the implementation of health reform, we are working hard to provide policy information/analysis to the Department of Health and Human Services’ (HHS) staff writing guidance and regulation on issues of importance to children’s hospitals and their patients. Since the effective dates for several important provisions are coming up quick, HHS has not taken a break and neither have we.
On many of these policy issues, we do have the opportunity to make our case with the Centers for Medicare and Medicaid Services (CMS) before policies are developed. Here are some highlights of what is keeping us busy this month:
Medicaid Payment Floor for Primary Care Services: The application of the Medicaid payment floor to general pediatrics as well as pediatric specialists is a top priority for the Association. Within the last month, we have met with the CMS staffer assigned to the development of this policy and have shared critical data showing the importance of the inclusion of pediatric specialists. We will continue to reinforce this message in all communication with CMS.
- Medical Homes for Children with Chronic Conditions: The health reform legislation allows states enhanced Medicaid funding (90 percent FMAP) to establish “health homes” for people with chronic conditions. The effective date of this provision is Jan. 1, 2011. We have heard that CMS is working on guidance to go out in a state Medicaid Director letter to be followed by a regulation. We want to ensure that the guidance provided to states would allow programs focused on children to participate in the enhanced funding. Of course, establishing health homes would be up to the state. We know several children’s hospitals have medical home programs for children with chronic conditions, many of which have outcome data to show they have reduced costs and improved quality for children. We are collecting examples of these programs to share with CMS proactively to hopefully influence the policy development on this provision.
- Non-payment for Hospital-Acquired Conditions: Beginning in July 2011, CMS has to implement the provision in health reform that prohibits Medicaid funding for health care acquired conditions. CMS has reached out to the Association for input. We are eager to work with CMS to ensure that the conditions will work for children. Medicare has a current policy and we do worry that this policy will be applied wholesale to the Medicaid program. This could be detrimental to children since the Medicare conditions were not developed with kids in mind. We are collecting information from hospitals and plan to provide information to CMS by the end of the month.
- Private Insurance Reforms: Although most of the patients cared for at children’s hospitals are insured by Medicaid, some of them do have private insurance. There are also some children who only enroll in the Medicaid program because they have hit annual or lifetime limits imposed by private insurers or have been denied coverage because of a pre-existing condition. These private insurance reforms being developed right now will be positive for children overall, and may also help alleviate some of the financial burden on the state Medicaid programs. We are currently reviewing regulations that will phase out annual limits, end pre-existing condition exclusions and outline which preventive services need to be provided without cost sharing.We will provide comments to HHS on these regulations. Children’s hospitals will receive draft Association comments on these regulation so they can be used if the hospitals would like to submit individually.
And I won’t even mention the combined 1,000+ pages of regulations on payment for end stage renal disease and health information technology that we are reviewing to provide information to children’s hospitals on these final policies. Our August has been a bit busier this year, but we hope our efforts contribute to positive policies for children. When does August end again?