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Arizona Health Care Cost Containment System Hospital Assessment Work Group May 8, 2013. Meeting Agenda. Hospital Assessment Overview. Hospital Assessments Overview. Provider Assessment Programs
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Arizona Health Care Cost Containment SystemHospital Assessment Work GroupMay 8, 2013
Hospital Assessments Overview • Provider Assessment Programs • Oftentimes used by states to replace or supplement the state share of payments eligible for federal matching funds • Defined under federal regulations as a licensing fee, assessment or other mandatory payment related to healthcare items or services • Assessment is considered to be related to healthcare if at least 85% of the burden of the assessment revenue falls on healthcare providers • Many classes of healthcare services can be assessed using a healthcare-related tax, including hospital services
Hospital Assessments Overview Simple Example of How Provider Assessment Programs Work CMS State Draws $50 in FFP State Certifies $100 Payments State Medicaid Program Healthcare Service Providers State Collects $50 in Assessments State Makes Payments of $100
Hospital Assessments Overview • Federal Requirements - 42 CFR § 443.72 • A state may receive, without reduction in FFP, healthcare-related assessment amounts if all of the following conditions are met: • The assessment is broad based • The assessment is uniformly imposed throughout a jurisdiction • The assessment program does not violate the hold harmless provisions • If these conditions are not met, the state may receive a waiver from CMS – AHCCCS anticipates the need to obtain waivers
Hospital Assessments Overview • Broad-Based and Uniformity Requirements • Broad-based - An assessment is considered to be broad-based if the assessment is imposed on at least all health care items or services in the class of providers of such items or services, and is imposed uniformly • Uniformly Imposed – Assessment must be imposed uniformly across all providers. A provider assessment is considered to be imposed uniformly even if it excludes Medicaid and/or Medicare amounts (although the exclusion of Medicaid revenues must be applied uniformly to all providers being taxed.
Hospital Assessments Overview • Uniformity Requirements • A provider assessment is considered to be imposed uniformly if it meets any one of the following criteria: • Licensing fee (or similar): If the assessment is the same amount for every provider furnishing those items or services within the class • Licensing fee (or similar) on the basis of the number of beds: If the amount of the assessment is the same for each bed of each provider of those items or services in the class • Assessment imposed on provider revenue or receipts: If the assessment is imposed at a uniform rate for all services in the class on all the gross revenues/receipts, or on net operating revenues relating to the provision of all services in the state, unit, or jurisdiction • Assessment imposed on items or services on a basis other than those specified: If the state establishes that the amount of the assessment is the same for each provider
Hospital Assessments Overview • Uniformity Requirements • Aprovider assessment is not considered to be imposed uniformly if it meets either one of the following two criteria: • The assessment provides for credits, exclusions, or deductions, which have as its purpose, or results in, the return to providers of all, or a portion, of the assessment paid, and it results, directly or indirectly, in an assessment program in which (1) The net impact of the assessment and payments is not generally redistributive; and (2) The amount of the assessment is directly correlated to payments under the Medicaid program. • The assessment holds taxpayers harmless for the cost of the tax (based on the hold-harmless provisions)
Hospital Assessments Overview • Waivers • Astate may request a waiver from CMS for the broad based and uniformity requirements for healthcare-related assessments. For CMS to approve a waiver, the state must demonstrate that its assessment program meets all of the following requirements: • The net impact of the assessment and any payments made to the providers by the state under the Medicaid program is generally redistributive • The amount of the assessment is not directly correlated to Medicaid payments • The assessment program does not fall within the hold harmless provisions
Hospital Assessments Overview • Waivers (Continued) • Broad-based Waiver (P1/P2 Test) - If a state requires a waiver of only the broad-based assessment requirement, it must demonstrate compliance with a redistributive test that measures, in aggregate, the proportion of the assessment burden to Medicaid providers. • Uniformity Waiver (B1/B2 Test) - If a state requires a waiver of the uniform tax requirement, whether or not the assessment is broad-based, it must demonstrate compliance with a different redistributive test that measures, for each provider, the relationship between the assessment burden and each provider’s “Medicaid Statistic”. • Hold Harmless – To qualify, CMS prohibits states from violating hold harmless provisions • See handouts for technical requirements for each of the above
Assessment Basis Options • Assessment Basis Options • FYE 2011 net patient revenues • Total, inpatient or outpatient • With or without Medicare net patient revenues • FYE 2011 patient days • With or without Medicare days • FYE 2011 patient discharges • With or without Medicare discharges
Assessment Basis Options • Net Patient Revenues • Net patient revenues are available in the following data sources: • Arizona Hospital Uniform Accounting Report (UAR) • Medicare Cost Report • Hospital Financial Statements • Inpatient vs. outpatient net patient revenues must be calculated using gross patient revenues • Medicare net patient revenues are available in the Medicare cost report
Assessment Basis Options • Net Patient Revenues (Continued) • Of the available data sources, the UAR most easily reconciles to the audited hospital financial statements • UAR’s breakout of bad debt expense amounts allows for the determination of net patient revenues less bad debt consistently across hospitals • Medicare cost is also an option if an approach can be developed to remove bad debt from net patient revenues for all providers
Assessment Basis Options • Patient Days and Discharges • The Medicare cost report is a reasonable data source for patient days and discharges because reported amounts are subjected to an audit process • However, a validation process may be necessary to make sure Medicare and Medicaid HMO days are reported consistently across providers
Questions and Discussion Questions and comments may be addressed to Jean Ellen Schulik at JeanEllen.Schulik@azahcccs.gov (602) 417-4335 Hospital Assessment Website: http://www.azahcccs.gov/publicnotices/HospitalAssessment.aspx