Reimbursement and Legislation

Cardiac Rehab NGS-LCD Update

Pulmonary Rehab NGS-LCD Update

MSCVPR/AACVPR Legislation Contact Information

Important Cardiac Rehab Cost Reporting Information

ATTENTION:  DIRECTORS OF HOSPITAL BASED CARDIAC REHAB PROGRAMS

January 2011

 

CMS has established a new opportunity for more accurate cost computations of cardiac rehabilitation programs, and that could lead to notably higher payment for cardiac rehab services under the Medicare program.

Background:  Several years ago CMS contracted with an outside consulting firm, RTI, to examine, among other issues, the way that cost reports collect data for certain services, including cardiac rehabilitation.  Until now cardiac rehab had no unique cost center assignment.  The result was an understatement of the actual cost of delivering this service. The study concluded that a shift of cardiac rehab to a specially designated but still “non standard” cost center could lead to notable increases in payment for cardiac rehab services (upwards of $100 vs. the current $38 payment).  Importantly, RTI believed this was a more accurate cost calculation for Medicare.

As you may know, all hospitals participating in the Medicare program must submit cost reports to CMS to assist the agency in setting payment amounts for hospital based services.  CMS has, for the most part, implemented the RTI recommendation related to cardiac rehab services, modifying the cost report to permit, but not require, specific cardiac rehabilitation program costs as a “non standard” cost center.  

What You Need to Do:  This new approach to cost reports took effect for all hospital cost reports filed for fiscal years beginning on or after October 1st, 2009. There are several steps you should take to ensure that your hospital files its cost report with Medicare reflecting this “non standard cost center” option.

  • Determine when the hospital’s fiscal year begins.  Many begin October 1st, but others may begin January 1st – it differs from institution to institution.  This is important because it will guide you in the all important timing of information you provide to your hospital’s CFO, accounting department, or whoever is responsible for filing the Medicare cost report.
  • Once you know when, identify who is actually responsible for the filing.  This is important for several reasons:
    • Make sure you have a relationship with this person as it is he/she that will ultimately submit the hospital cost report to CMS/Medicare.
    • Find out what his/her timetable actually is for working on the cost report.  It may be next week, or it may be months away, depending on the hospital’s fiscal year.
    • This person needs to know that cardiac rehab program costs can now be identified as a non standard cost center.  The change in the cost report is subtle and, because it is optional, even the most studious of CFOs might miss this change.
  • Determine what data you will need to provide.  To identify cardiac rehab as a separate cost center you will need to identify what are  usually referred to as “allocation statistics” that allow the cost report to assign overhead costs.  Set up a timetable to make sure these data are submitted to your hospital contact in time for inclusion in the next cycle of your hospital’s cost report submission.

What Happens Next:  This is a mix of good news and bad news.  First, CMS has already posted its proposed payment rates for hospital inpatient and outpatient services for next year.  The agency will begin to review data in January-February of 2011 for development of rates for 2012.  Cost reports for periods beginning October 1 2009 and ending September 30 2010 will probably not be filed until  February of 2011, and the data therefore will not available to CMS for use in any outpatient cost computations for at least  another year. Please know there is an unfortunately long lag time between this effort by cardiac rehab programs across the country and CMS review of the data in this new format.  It may be no earlier than the January-February review in 2012 for 2013 rates that changes could genuinely begin.  Success in that time frame is virtually 100% dependent upon all cardiac rehab programs across the country making sure that their hospitals take advantage of this new non standard cost center reporting process.

Remember that if hospitals do not make this important change on their collective cost reports, CMS will not have the data that is predicted to increase cardiac rehab payment rates. 


 

 

 
NGS Cardiac Rehab LCD-Update
 

NGS is no longer requiring a Cardiologist to supervise cardiac rehab.  Nurse Practitioners can prescribe cardiac rehab, but cannot supervise.

Also, they have relaxed the wording for using stable angina as a diagnosis.  They are no longer requiring a pre-stress test with ST changes. 

Click here for the entire final LCD from NGS

 

NGS Draft Pulmonary Rehab LCD-Update

National Government Services (NGS) is the local Medicare contractor that serves as MAC (Medicare Administrative Contractor) for J-13 and as Fiscal Intermediary for some programs that have not rolled to a MAC yet. NGS recently retired its "Pulmonary Rehabilitation" Local Coverage Determination (LCD) because it was not in compliance with the CMS rules for PR, 410.47, effective 1-1-2010.
 

NGS does not have an LCD for "respiratory care" or "respiratory therapy" services as other MACs have had prior to the new pulmonary rehabilitation coverage policy and continue to have. This does not mean that NGS no longer covers patients who qualify for respiratory therapy/respiratory care services (i.e., those with non-COPD diagnoses who do not have a qualifying diagnosis to enter a "Pulmonary Rehabilitation" program). Patients are covered for respiratory care services if there is medical necessity in the same way PR programs operated prior to 1-1-2010. NGS is currently considering the need for an LCD that addresses respiratory therapy services. In the interim, PR programs are providing and receiving Medicare reimbursement for respiratory therapy care services (what CMS would refer to as components of a PR program, but not a comprehensive PR program) to non-COPD patients who demonstrate medical necessity.


MSCVPR/AACVPR Legislative Contact Information

Below is a link to the AACVPR site which contains legislative language and various other links and information regarding these important issue.

Click here for the AACVPR Legislative Updates Page

If you have any further questions, feel free to contact Donna Donakowski at 248.609.0122 or donna.donakowski@comcast.net

You can also contact Phil Porte, AACVPR’s legislative consultant 301.718.0202 or pporte@erols.com