The 2017 IPPS Final Rule was posted on August 2, 2016 and will be effective October 1, 2016. Below is SCA’s summary on the rule as it affects disproportionate share hospitals (DSH).
Quick Review of the DSH Payment Under ACA
As a result of the ACA, the amount of total DSH reimbursement a provider may receive for discharges beginning October 1, 2013, is now based upon two components:
Topics: Medicare DSH Reimbursement, uncompensated care, S-10, regulations, final rule
On July 15, 2016, CMS posted the FFY 2014 SSI ratios to their website. The FFY 2014 SSI ratios should be used for computing the Disproportionate Share Hospital payment for cost reporting periods beginning on or after October 1, 2013, and before October 1, 2014. The FFY 2014 SSI ratio file (DSH Adjustment and 2013-2014 File [ZIP, 270KB]) can be found in the Downloads section of CMS' Disproportionate Share Hospital (DSH) webpage or by following the link below:
Topics: Medicare DSH Reimbursement
The 2017 IPPS Proposed Rule was put on display for public inspection on April 18, 2016 and is scheduled to be published in the Federal Register on Wednesday, April 27, 2016. The pre-publication version can be viewed HERE. All public comments to the proposed rule are to be received by 5 p.m. EST on June 17, 2016. Below is SCA’s brief, yet comprehensive summary on the proposed rule as it will affect DSH hospitals.
Topics: Medicare DSH Reimbursement, S-10, proposed rule
In February, HRSA posted a manufacturer refund notice for 340B covered entities to its website regarding Amgen USA, Inc. (Amgen) and 340B pricing for multiple products using NDC labeler codes 55513 and 58406. This includes Aranesp, Sensipar, Epogen, Neulasta, Neupogen, NPlate, Prolia, Vectibix and Enbrel. According to the notice, Amgen has made an adjustment to the 340B ceiling prices for the aforementioned National Drug Codes (NDCs) and as a result, a 340B covered entity may be eligible for a credit. Please see the manufacturer notice HERE for eligible NDCs and drug purchase timeframes as they include multiple products and timeframes ranging from Q4 2006 to Q1 2015.
Topics: 340B, 340B ceiling price, manufacturer refund
Each year, Southwest Consulting Associates takes time to celebrate the holiday season as a ‘family‘ by hosting a Thanksgiving Luncheon for its employees. In conjunction with the luncheon, SCA employees collect and donate necessities to a local charity. This year, SCA chose to partner with The Samaritan Inn of McKinney.
The Samaritan Inn is a comprehensive program that teaches self-sufficiency and life skills to meet the needs of individuals and families experiencing homelessness. All services and support are provided free of charge through funding made through donations. The Samaritan Inn helps willing people gain dignity and independence and is the only homeless shelter in Collin County, typically sleeping 160 people (almost half being children).
Topics: News & Events
Southwest Consulting Associates (SCA) hosted a webinar in October which focused on recent audit findings relating to 340B audits conducted by HRSA as well as 340B external audits conducted by SCA. More specifically, SCA touched on areas HRSA is reviewing during an audit, what is being found, as well as provided some best practices that could be used in the management of a covered entity's 340B program. In this blog, we will share the most important takeaways regarding both HRSA audits and suggested best practices.
Topics: 340B
As of October 1, 2015, HRSA had posted the results of 103 covered entity audits to its website. According to the 2015 workplan and presentations at both the Winter and Summer 340B Coalitions, HRSA announced that they planned on performing at least 200 340B audits by the end of 2015. According to Apexus, HRSA did in fact complete 200 audits in 2015. HRSA’s fiscal year has come to a close and although not all of the audit results have been published, Southwest Consulting Associates (SCA) has analyzed what is available to establish trends in the findings.
Topics: 340B
The 340B Drug Pricing Program Omnibus Guidance (Mega-Guidance) was published for public comment August 28, 2015. You can find it HERE. Please note, comments should be submitted on or before TUESDAY, OCTOBER 27, 2015. The Mega-Guidance is extremely comprehensive as it addresses numerous aspects of the 340B program but the most significant proposed changes were in the areas of:
patient definition
physician administered drugs (stricter guidance)
record retention standards
duplicate discounts including Medicaid Managed Care
contract pharmacy
In this article, we are going to focus on patient definition as it is today and what it would look like if the 340B Mega-Guidance is finalized as proposed.
Topics: 340B
Many 340B program stakeholders would agree that program integrity was at the forefront of HRSA’s priorities for the 2015 fiscal year. At the 340B Winter Coalition Conference in February, Captain Krista Pedley (Director of Office of Pharmacy Affairs) gave a presentation addressing the 340B Drug Pricing Program and specifically stated, “…program integrity is our highest priority.” At the 340B Summer Coalition Conference in July, Michelle Herzog, Deputy Director of the Health Resources and Services Administration Office of Pharmacy Affairs, provided the HRSA update to participants and clearly stated, “Program integrity remains the highest priority in OPA and HRSA intends to advance that mission and ensure that the 340B Program is sustainable in the long term for all of the stakeholders who participate”.
Topics: 340B
On Monday, September 14, 2015, HRSA posted a manufacturer refund notice on its website regarding Heritage Pharmaceuticals Inc. (Heritage) and 340B pricing for products using NDC labeler code 23155. According to the notice, Heritage did not extend 340B pricing to covered entities on drug purchases made between April 18, 2008 and December 31, 2014. As a result, a 340B covered entity may have purchased identified Heritage products above the 340B ceiling price.
Topics: 340B