Avalere's Hammelman says CMS appears determined to move forward with enforcement of the rule, which has drawn howls of protest from healthcare providers and their allies in Congress. "In their minds, this is a policy [CMS officials] have implemented." While recognizing there are exceptions to any rules, CMS has directed contractors to start looking at Medicare billing with the two -midnight rule in mind, he says.
The proposed IPPS payment statutory reductions such as those mandated under the PPACA and programs that will hit individual hospitals differently such as HAC penalties have been expected.
"It's all stuff that [CMS officials have] telegraphed," Hammelman said. And several quality programs such as HAC have the potential to take bigger and bigger bites out of bottom lines over time. "It will become a growing issue as we see hospitals face penalties in the six, seven, [or] eight percent range."
The proposed 2015 IPPS rules cover several other topics for healthcare providers and other Medicare stakeholders to consider during the 60-day comment period that began April 30.
Wolters Kluwer's Clark says CMS appears to be trying to rein in appeals of decisions made at the Provider Reimbursement Review Board. "About a third of the newly proposed regulations apply to the PRRB," he said. "They're trying to eliminate certain appeals that providers can do. … In recent years, the PRRB has been trying to reduce the number of appeals they have to deal with."