October 20, 2019
The State’s New Diabetes Action Plan: Potential Implications for Hospitals
Recently the Maryland Department of Health (MDH) released a new Diabetes Action Plan that aims to create conditions conducive to better health and reduce the impact of diabetes on Marylanders. MDH understands the plan will require an “all in” effort from a wide variety of actors, including state and local policymakers, payers, employers, school boards and administrators, community groups and others.

The plan is extensive, and we have found the recommendations for action are most relevant to hospitals and health systems. Drawn heavily from the American Diabetes Association’s 2019 Standards of Medical Care in Diabetes, the suggestions are organized by where an individual is on the continuum of diabetes.

MHA will focus on efforts that will help hospitals to meet our targets under the Total Cost of Care Model contract. We’re inclined to concentrate our energies on people who have the disease—13% of the total population and 26% of the Medicare population are estimated to have diabetes mellitus, diagnosed or not. Exacerbations and complications, often preventable, not only add to costs but worsen patients’ lives.

We know most of your organizations already have traction in this area, along with some successful programs. What is needed to sustain those initiatives? Can they be scaled up? What else could really make a difference and is feasible to do? Who are the best outside partners and what should we expect of them? Please share your comments with me or Traci La Valle by November 4.

MHA intends to leverage the Diabetes Action Plan as we continue to support the field in engaging other stakeholders.
Bob Atlas
President & CEO
U.S. Representative Cummings Leaves Legacy of Support for Maryland, Health Care
Long-time U.S. Rep. Elijah E. Cummings passed away Thursday. He was in his 13th term serving Maryland in the House of Representatives. Cummings was a towering voice for Maryland at the state and federal level—and a staunch advocate for expanding access to health care. He was a strong supporter the Affordable Care Act and a frequent champion for greater access to affordable prescription medication. Maryland has benefited from his passion, compassion and exceptional leadership. Rick Pollack, president and CEO of the American Hospital Association, released a statement on Cummings’ passing, saying in part that “Bipartisanship and collaboration were hallmarks of his chairmanship of the Oversight and Reform Committee, where he led hearings that focused on the urgent health care needs of American communities, highlighting the opioid epidemic, veterans’ health care quality and the mental health needs of children. He fought to ensure that every American—particularly those who felt marginalized and disenfranchised—had the opportunity to achieve a successful life. We will miss his wise counsel and leadership.”
HSCRC Approves Medicare Performance Adjustment (MPA) Framework, Delays Action on Integrated Efficiency Policy
The Health Services Cost Review Commission on Wednesday approved HSCRC staff’s final recommendation on the MPA framework , which includes two components: MPA savings (MPA-SC) and MPA reconciliation (MPA-RC). The commission adopted the MPA-RC recommendation with an amendment that requires HSCRC staff to report to the commission in 2020 about how CTIs have progressed and how HSCRC addressed measuring CTI savings. The commission delayed action on its final recommendation to adopt an integrated efficiency policy until Spring 2020. For more on these and other HSCRC actions during its public meeting, read the latest edition of MHA Newsbreak .
MHA Holds First Health Equity Task Force Meeting
MHA held the first meeting of the Health Equity Task Force on Thursday. Representatives from a cross section of hospitals convened to begin the very important work of developing the course for implementing health equity-related initiatives in MHA’s 2019-2021 strategic plan. Task force members discussed:
  • The healthcare environment in Maryland, which is driving an increased focus on health disparities and health equity
  • Mechanisms, including analytics and screening tools, that may be used to identify opportunities to reduce health disparities and target specific patient populations for interventions
  • Opportunities for MHA to engage in efforts to improve social determinants of health and health equity in Maryland
  • A shared definition of health equity, which will serve as a basis for developing the task force’s scope of the work.
Task Force members said it will be important to change the paradigm in which health equity is discussed. While meeting financial goals of the total cost of care model is important, stakeholders, including hospitals, will need to approach health equity progress through a different lens given that many interventions to address social risk should be implemented “upstream,” and as such, any return on investment, is inherently over a longer period relative to other types of interventions.

Task Force members agreed certain upstream interventions that address social determinant risk are key to preventing chronic conditions and unnecessary utilization. There was consensus that these social determinant risk issues are key drivers in the recent spike in hard to place patients in our hospitals.
They also stressed the importance of partnerships with other stakeholders, including government agencies, providers, and community organizations to implement health equity efforts. In addition, many task force members raised the importance of understanding and addressing unconscious bias among the healthcare workforce as well as institutional bias in our organizations. In addition to housing instability, some of the most relevant social determinant risks in communities are food insecurity, transportation barriers, low health literacy, and loneliness.

The task force and MHA staff agreed that to begin tackling these issues, we will need to make compelling cases for addressing them directly for use with regulators, legislators and key stakeholder partners.
The next meeting will be held on December 19. MHA staff plans to work with members to solidify the Task Force’s scope, and to identify and prioritize the key issues in MHA’s health equity platform.
Performance Measurement Work Group Update
The Health Services Cost Review Commission’s (HSCRC) Performance Measurement Work Group convened October 16 via webinar. HSCRC staff informed the field of the proposed updates to the rate year 2022 Quality-Based Reimbursement policy. Staff provided data comparing Maryland’s QBR performance to various national Value-Based Purchasing (VBP) measures, highlighting the fact that Maryland performance is essentially on par with or unfavorable compared to the nation. Staff indicated that the draft recommendation would include a continuation of the rate year 2021 domain weighting, and the rate year 2021 reward/penalty cut point. Additionally, staff advised the group of updates to the mortality measure and their plan to monitor additional measures. HSCRC plans to convene a subgroup in calendar year 2020 to consider options for overhauling the QBR program. The rate year 2022 draft recommendations will be presented at the November monthly commission meeting. The next Performance Measurement Work Group meeting is November 20.

The materials from the October 16 meeting are here . For questions or additional information, contact Brian Sims .
MHA Hosts Free Cybersecurity Forum
In collaboration with the Health Services Cost Review Commission, Maryland Health Care Commission and Maryland Chapter of the Healthcare Information and Management Systems Society, your MHA will host a free cybersecurity forum October 23 from 3:30-6 p.m. Registration is open for the event, which will include networking, followed by presentations, a panel of hospital experts and a question-and-answer session. The forum will focus on re-evaluating security, risk and governance to ensure a well-rounded approach to cybersecurity.

For more information, contact Jennifer Witten or Jane Krienke .
CMS, HHS OIG Publish Proposed Rules for Stark Law and Anti-Kickback Statute Overhaul
On October 17, the Centers for Medicare & Medicaid Services (CMS) and the Office of the Inspector General (OIG) for the Department of Health and Human Services (HHS) published proposed rules to update the Stark Law and Anti-Kickback Statute , respectively. Major changes are aimed at decreasing regulatory barriers to value-based arrangements for care coordination. CMS is also seeking comment on price transparency as it relates to the Stark Law and whether to require cost-of-care information at the point of referral for an item or service. A high-level summary from AHA is available here . MHA is analyzing the regulations for impact on Maryland’s hospitals, including current and contemplated value-based arrangements. The deadline to comment on the proposed regulations is December 31. For questions, contact Nicole Stallings , MHA senior vice president.
Hospital Care Redesign Program Approved for Commercial Expansion
The Maryland Insurance Administration (MIA) recently reviewed the governing documents submitted by Doctors Community Hospital (DCH) on their Hospital Care Improvement Program (HCIP). The MIA concluded that the HCIP program at DCH does not “constitute the business of insurance.” This will enable DCH to increase physician engagement by expanding the program to their non-Medicare population. This will permit DHC to engage a broader number physicians by allowing the hospital to pay incentives on both Medicare and commercial cases. The process to expand care redesign programs was authorized by MHA-supported legislation in 2017. HCIP participating hospitals received an email from MHA with additional details on this opportunity. Learn more and view upcoming deadlines in October’s MHA Care Redesign Program Update . Contact Erin Dorrien for additional information.
MHA Discusses Workforce Challenges, Opportunities at AHA Forum
Last week MHA staff attended the American Hospital Association’s A2 workforce meeting where state hospital associations from across the country shared innovative workforce development programs, discussed challenges with workplace violence prevention and barriers to recruitment and retention of employees, among other topics. Moving forward on MHA’s strategic goal of building a robust, diverse, inclusive and engaged workforce will require unique solutions. Looking ahead to the 2020 legislative session, your MHA will be focused on initiatives that support this goal such as loan repayment, expanded scope of practice and workplace violence prevention.
Contact: Jennifer Witten
Maryland Health Insurance Coverage Protection Commission Meets
The Maryland Health Insurance Coverage Protection Commission held its second 2019 interim meeting this past Tuesday. The commission heard from the Maryland Insurance Administration (MIA) and Maryland Health Benefit Exchange (MHBE), as well as representatives from Massachusetts. The MIA presented a report on cost-sharing and utilization trends in the individual and small group markets. Commission member Bob Atlas, MHA President & CEO, noted the stark difference between the relatively low hospital spending in Maryland and increases in enrollee cost-sharing. This sentiment was echoed by other commission members. The MHBE presented on its Affordability Workgroup report . One of the recommendations from this group is that the state consider additional, state-level subsidies for individuals purchasing insurance through the state exchange, in an effort to attract young, healthy adults who remain uninsured. Representatives from Massachusetts shared their experience with providing state-level subsidies. Specifically, they noted that the increases in insurance uptake by the young, healthier adult population as a result of additional subsidies to make coverage more affordable led to an improved risk pool and lower premium rates. The commission will meet next in December, when it will contemplate recommendations and legislative proposals for the 2020 session.

For more information, contact Maansi Raswant or Jennifer Witten .
Maryland Insurance Administration Launches Webpage Devoted to Maryland’s Health Care Provider Community
The Maryland Insurance Administration designed a new webpage to better serve a key stakeholder group: Health Care Providers. “Our agency spends a lot of resources to engage in outreach with all of our stakeholders,” said Insurance Commissioner Al Redmer, Jr. “It became apparent that not all providers know that we are here, or how we can serve them. This provider specific access is one of many tactics that we are deploying to better serve this important part of the health care industry.” The Life and Health Complaints Unit routinely hears from the provider community on topics such as prompt pay, clean claims, credentialing and issues of retroactive claims. As a result of these calls, the MIA acted to simplify access to information on these topics.
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