The Hospital Council of East Central Michigan works to maintain relations with state and federal legislators, organizations and others in the region whose activities affect the health services of our community hospitals and encourages their support by providing opportunities to learn about issues that impact members' ability to improve the health of the population. HCECM also works with other advocacy groups to help keep member hospitals informed of all legislative matters affecting their services.
Protect Funding for Member Hospitals
Critical Access Hospitals and rural hospitals face many unique challenges that can impact the health of the population. So these hospitals can maintain financial viability and continue to operate and serve the needs of their communities, HCECM member hospitals work with legislators and advocacy organizations to secure state and federal funding that helps overcome these challenges.
In June 2014, the Centers for Medicare & Medicaid Services announced that low-volume payment adjustments and the Medicare-dependent Hospital (MDH) program were extended which will help our regional hospitals. Ambulance add-on payments for rural operators were also extended.
The Michigan Legislature also restored funding for the small and rural hospital pool and graduate medical education program, created a new small and rural hospital obstetrics stabilization fund and approved a provider tax-funded disproportionate share hospital pool expansion to address the HICA revenue shortfall.
CRNA Physician Supervision Opt-out
Under current federal law, CRNAs must be supervised by a physician. However, in 2001 the Centers for Medicare & Medicaid Services provided an opportunity for states to "opt out" or be exempted from the federal supervision requirements for CRNAs. HCECM hospital members have been working with regional legislators to try to get Michigan to opt out of the requirement.
Some of the problems of requiring CRNA supervision can include:
- Increases cost of healthcare and financial burdens on hospital unnecessarily for many reasons
- Creates staffing and access issues in rural areas
- Increases wait time per patient, which is not cost effective
- Has not been proven to improve care to patient
Supervision of Hospital Therapeutic Services
In 2009, CMS mandated that "a supervising physician be physically present in the department at all times when Medicare beneficiaries receive outpatient therapeutic services." It further complicated matters by stating that this was a clarification from a 2001 ruling.
For Critical Access, small and rural hospitals, this mandate:
- Creates unnecessary time and financial burdens
- Increases costs of healthcare
- Increases risk for unwarranted enforcement actions
- Increases risk for opportunistic whistleblowers to claim a hospital did not follow this at some point in the past 13 years
CMS made some positive changes; however, more needs to be done to reduce the burdens on CAHs and rural hospitals. According to the American Hospital Association, many CAHs and small rural hospitals will have no choice but to limit their hours of operation or close certain programs due to their inability to meet the requirements of direct supervision.
EHRs and Meaningful Use
HCECM hospital members are at various stages of participating in EHR and Meaningful Use incentive programs. The rules and guidance are complicated, burdensome and require significant resources, especially for Critical Access and rural hospitals. HCECM and its hospital members are working with other advocacy organizations to encourage CMS to clarify requirements and lessen the burdens for participation.
96-hour Physician Certification Requirement for CAHs
According to the American Hospital Association, "CMS has recently indicated that it will begin enforcing a condition of payment for CAHs that requires a physician to certify that a beneficiary may reasonably be expected to be discharged or transferred to a hospital within 96 hours after admission to the CAH. If enforced, CAHs would be forced to eliminate these '96-hour plus' services, and the resulting financial pressure on CAHs would severely affect their ability to operate and care for beneficiaries in rural communities."
HCECM and its hospital members have been working with other advocacy organizations to urge the CMS to remove this requirement as a payment condition. A few examples of how this could impact patients include:
- A patient with pneumonia who experiences a setback and needs more time to recover could be negatively impacted by transferring him/her to a tertiary center.
- A woman who gives birth by C-section or is in labor for 24 hours or more before the C-section could easily exceed the 96-hour rule.
- A patient with pancreatitis, often caused by alcohol abuse, could benefit more by staying close to a support system of community/family.
- A patient who undergoes bowel surgery often needs more time to recover.
- A patient who experiences a ruptured appendix resulting in peritonitis will likely need more time to receive treatment and recover.
Transitions in Care
HCECM is currently working with volunteers from numerous hospitals, agencies and organizations to address transportation challenges for regional residents in need of medical care. A major problem for people with medical issues is to have access to affordable and reliable transportation. Many are unable to make appointments, keep appointments or even make it to a facility when immediate medical help is needed.
A key priority of HCECM is to also work with others to foster effective care transitions through a hospital information process that provides a standardized system that supports the transfer of clinical and care planning information to the multidisciplinary providers continuing care of post acute care inpatients after discharge.
DOJ, HHS Call for Action to Address Abuse of Older Americans
HHS Awards $83.4 Million to Train New Primary Care Providers
RHRC Report: Support for Rural Recruitment and Practice Among U. S. Nurse Practitioner Education Programs
Policy to Allow RHC to Contract with Non-physician Practitioners Under Certain Conditions - Issued May 2, 2014
CMS Revisions - Issued May 12, 2014
AHA Small & Rural Hospitals Advocacy Paper 2013
NRHA Fiscal Year 2015 Appropriation Request
Rural Policy Research Institute
NRHA Save Rural Hospitals Action Kit
2015 Rural Health Policy Institute Requests
NRHA Legislative and Regulatory Agenda
Protect Rural Patients and Providers
Sequestration Impact on States