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March 8, 2020
Taking on Coronavirus in Maryland
The situation regarding coronavirus/COVID-19 is evolving at a fast pace. As of Sunday evening, the number of confirmed cases in Maryland remains just a handful, and it appears that all those patients acquired their illnesses on foreign travel. But a number of new cases have been reported in neighboring areas. We need to prepare for community spread.
 
Your hospitals are clearly on the front lines, already being called and visited by people who believe they have symptoms and want to be tested or treated. This all needs to be managed.
 
It’s evident MDH is doing all they can, particularly in testing. Several of our health systems report they are standing up their own testing capabilities as well.
 
It’s also plain that so much more is needed and that MDH is welcoming the hospital field’s leadership in protecting Marylanders.
 
MHA was already coordinating between hospitals, state agencies and others, including nursing facilities and health plans. As the new week begins, we will intensify this effort. It will be valuable if we can all follow consistent protocols for patient triage, including through remote means so EDs don’t get swamped; handling patients in primary/urgent care settings; specimen collection for people believed to warrant testing; health facility visitor policies; messaging to patients and the public generally; and much more.

Other state hospital associations are sharing what they’ve done, and we’re leveraging their learnings as we proceed.
 
Meghan McClelland , MHA’s senior vice president of operations, is leading our effort. She already knows the point people at all hospitals and health systems and will work through them on further coordination. 

To find the latest news for Maryland hospitals compiled in one place, go to mhaonline.org/coronavirus . We will update that page steadily.
Bob Atlas
President & CEO
COVID-19 Payment and Coverage
The American Hospital Association (AHA) recently shared information on COVID-19 coverage and payment details from Centers for Medicare & Medicaid Services (CMS). See below for AHA’s descriptions and links to the CMS documents including a second Healthcare Common Procedure Coding System (HCPCS) code that can be used by laboratories to bill for certain COVID-19 diagnostic tests.
Medicare Coverage and Payment : CMS says that local Medicare Administrative Contractors (MACs) are responsible for developing the payment amount for the new COVID-19 HCPCS codes until Medicare establishes national payment rates. As with other laboratory tests, there is generally no beneficiary cost sharing under original Medicare. In addition to diagnostic tests, Medicare covers all medically necessary hospitalizations, as well as brief "virtual check-ins," which allow patients and their doctors to connect by phone or video chat.

Medicaid and CHIP Coverage and Payment : Testing and diagnostic services are commonly covered services, and laboratory and X-ray services are a mandatory benefit covered and reimbursed in all states. States are required to provide both inpatient and outpatient hospital services to beneficiaries. All states provide coverage of hospital care for children and pregnant women enrolled in CHIP. CMS specifies that detailed questions on covered benefits should be directed to the respective state Medicaid and CHIP agency.

Individual and Small Group Market Coverage and Payment : Laboratory services are a category of Essential Health Benefits (EHB) that individual and small group market issuers are generally required by law to include in their benefit packages. However, whether any diagnostic or laboratory service is covered by a plan varies and is based on the specific benchmark plan selected by each state and the terms of the plan. Large group market plans and self-insured plans are not subject to EHB coverage requirements. CMS states that patients should check with their health insurance company to determine coverage for lab tests and related services for the diagnosis and treatment of COVID-19. Standard cost sharing may apply for these services.

Additional HCPCS Code for Coronavirus Lab Tests: CMS developed a second HCPCS code for laboratories to bill for certain COVID-19 diagnostic tests. Specifically, the first code, U0001, is used for CDC testing laboratories to test patients for SARS-CoV-2. However, the second code (U0002) is used for non-CDC laboratory tests for SARS-CoV-2/2019-nCoV (COVID-19). That is, on Feb. 29, 2020, the Food and Drug Administration (FDA) issued a new, streamlined policy for certain laboratories to develop their own validated COVID-19 diagnostics — this second code may be used for tests developed by these additional laboratories when submitting claims to Medicare or health insurers. CMS expects that having specific codes for these tests will encourage testing and improve tracking. The Medicare claims processing systems will be able to accept these codes starting on April 1, 2020, for dates of service on or after Feb. 4, 2020.

The CDC previously issued official guidance on how to code the diagnosis of health care encounters and deaths related to COVID-19. If you have questions, please contact Roslyne Schulman at [email protected] or Nancy Foster at [email protected] .
CMS Suspending Non-Emergency Inspections
On Thursday, the Centers for Medicare & Medicaid Services (CMS) announced they are suspending survey activities. In order to ensure hospitals and other health care facilities can concentrate on COVID-19 preparedness, CMS will refocus their resources to address the spread of the virus. Emergency surveys alleging infection control concerns and serious patient injury, or harm will proceed along with re-visits to resolve current enforcement actions or initial certifications. Hospitals should check with their accreditation leadership and potentially connect with Joint Commission to understand how this will affect evaluations for your facilities. More details can be found here and here .
MIA Calls on Carriers to Waive Cost-Sharing for COVID-19 Related Testing and Treatment
On Friday, the Maryland Insurance Administration (MIA) issued a notice to insurers, health maintenance organizations, and nonprofit health service plans to ensure that they are prepared to address COVID-19 cases and provide all medically necessary covered health services. Under the emergency regulations, Commissioner Al Redmer is requiring that all carriers must waive any time restrictions on prescription medication refills, authorize payment to pharmacies for at least a 30-day supply of any prescription medication and more. See the full notice here . 
#Caring4Md: Focus on Hospital Caregivers
This week’s #Caring4Md messaging focuses on the 108,000 caregivers who work every day in Maryland hospitals. We’re highlighting the work you do to heal patients and the work you do to support your communities. If you need material for your hospital or health system’s social media channels, you can find it here . Please send ideas for employee and patient stories to [email protected] .
HSCRC Payment Models Work Group Discusses Annual Revenue Update and Clinic Conversion
The Health Services Cost Review Commission (HSCRC) Payment Models Work Group met March 3 to discuss the rate year 2021 annual hospital update and the upcoming clinic conversion. HSCRC staff presented a preliminary draft of the proposed update, including the most recent inflation projection of 2.77%. MHA will process the hospital field’s update position in our upcoming Council on Financial Policy and Executive Committee meetings. HSCRC staff also discussed its proposed Clinic RVU conversion that would lower clinic charges in a revenue neutral manner by shifting revenue among clinic visit levels and shifting revenue to other rate centers. For more information on these and other HSCRC items, please contact MHA’s Health Care Payment leaders, Brett McCone or Katie Eckert .
2020 MHA Bond Program Opens March 27
The 2020 MHA Bond Program application process opens March 27. The Hospital Bond Program provides an opportunity to apply for state allocated funding to complete private capital projects. Hospitals applying for funding under this program must request the appropriate approvals/ exemptions from both the Maryland Health Care Commission and Health Services Cost Review Commission by April 27. 
Applications must be submitted by June 19. Application materials will be available on MHA’s website along with updates to the project selection scoring guidelines and other application materials. Application forms and other supporting documentation are submitted via hospital-specific SharePoint site. If you have questions, please contact  Brett McCone ,  Jennifer Witten , or  Jane Krienke . MHA will host a webinar that provides an overview of the 2020 Hospital Bond Program March 30 at noon. Click here to register.
Final Evaluation of Maryland All-Payer Model
The Center for Medicare & Medicaid Innovation presented the results of the independent evaluation of the Maryland All-Payer Model January 23. If you missed the webinar and would like to hear RTI International discuss how Maryland performed on the goals of the model agreement with CMMI, you can see the full presentation here.
Patient Experience Improvement Project
Many hospitals find it challenging to engage staff in patient experience improvement. Despite considerable investments in time and resources, it may be difficult to effectively implement best practices and sustain improved performance. This spring, MHA is providing support for members to explore two staff engagement techniques:
  • Learning from Failure: Frontline staff members look at common causes of failure and develop a checklist of pitfalls to avoid and recommendations for improvement.
  • Creating Always Events®: Identify and implement initiatives that hospitals must consistently perform because they are so critically important to the patient experience using a technique developed by the Picker Institute and the Institute for Healthcare Improvement.
March 12, at noon: Introductory webinar, register here .
April 8, from 8 a.m. to noon: In-person train-the-trainer workshop at MHA conference center in Elkridge, Md. More details and registration information to come.

For details contact MHA’s Tracy Blanchard .
Annapolis Update
This week is crossover week in Annapolis. Next Monday is crossover day, the day by which each chamber must send bills to the opposite chamber they wish to pass favorably this session.

Last week, the Senate Budget & Taxation Committee announced their final budget decisions, which include additional funding for Maryland’s Loan Assistance & Repayment Program and a $15 million Medicaid Deficit Assessment reduction. The committee rejected the Department of Legislative Services recommendation to eliminate the $15 million reduction included in Gov. Larry Hogan’s budget and to remove the commitment to reduce the assessment in the future. Additionally, MHA’s bill to enhance the Loan Assistance Repayment Program was voted favorably in both Senate committees last week and will go to the Senate floor early this week.

MHA and several members testified in support of another top hospital priority, the Infant Lifetime Care Trust, before the Senate Finance Committee. MHA provided verbal and written testimony on several other issues last week, including facility fees, hospital financial assistance policies, community benefits, and hospital worker retraining. For more information on bills MHA is tracking, click here . 
MHA Hosts Meeting on New Bundled Payment Program With HSCRC
On March 2, MHA hosted an informational session on the Episode Quality Improvement Program (EQIP). EQIP is a proposal the Health Services Cost Review Commission (HSCRC) is recommending to the Center for Medicare & Medicaid Innovation. The program, set for a January 2021 launch, allows for certain non-hospital providers to participate in risk-sharing arrangements not currently available in Maryland—in much the same way as the national Bundled Payments for Care Improvement Advanced program. At this meeting HSCRC discussed the proposal and answered questions, including how this program will interact with the current Episode Care Improvement Program. To access a recording of the meeting, click here . For materials from this session contact Erin Dorrien .
Quarterly Meeting of the Stakeholder Innovation Group Scheduled for March 13
The Stakeholder Innovation Group will hold its first meeting of the year March 13. The group will discuss priority recommendations from the Secretary’s Post Acute Care Workgroup, the work of the SIG EMS subgroup and begin discussions on new payment models and waivers to request from the Center for Medicare & Medicaid Innovation. The meeting will be held at MHA from 9 a.m.-11 a.m. For more information contact Erin Dorrien . 
Commit to Support Victims of Human Trafficking
MHA is asking every hospital to adopt the new Human Trafficking Guidelines for Healthcare Providers . Maryland’s hospitals are on the front lines of the human trafficking crisis. It’s estimated that 88% of human trafficking victims encounter the health care system. These guidelines educate and empower frontline staff members to see signs of human trafficking and implement safe strategies to support and assist victims. Please complete this form and send it to Jane Krienke .
U.S. Public Charge Rule Takes Effect
The U.S. Department of Homeland Security’s (DHS) rule on Inadmissibility on Public Charge Grounds took effect last month and could have implications for individuals seeking care at Maryland hospitals. DHS issued rules that allow the government to deny an individual's application for entry into the U.S. or deny an application to change their immigration status if they use public benefits, including Medicaid. The rule defines a “public charge” as an immigrant who uses public benefits or relies on the government for financial support.

Individuals can be considered a public charge if they use public benefits or are likely to use them in the future. The determinations are based on education and income levels, among other factors. The Maryland Health Connection, which administers qualified health insurance plans with corresponding federal subsidies, recently provided an overview of the rule and list of resources for immigration services. MHA will continue to share resources that hospitals can use to educate staff and patients. MHA provided a comment letter in 2018 outlining concerns about this change—mainly that it could affect people’s access to medical care.
Supreme Court to Hear Challenge to Affordable Care Act’s (ACA) Individual Mandate
The Supreme Court of the United States announced it will hear Texas v. California (previously known as Texas v. Azar or Texas v. United States). The court will review whether the individual mandate, as currently set to zero dollars, can still be considered a tax and thus constitutional. If it is found to be unconstitutional, then they must also decide whether that provision is severable from the rest of the ACA.
If the standard Supreme Court schedule is followed, the decision may not be released until 2021. MHA continues to monitor developments and determine implications for the Maryland Total Cost of Care Model. MHA is actively engaged in working with legislators to ensure continued protections for Maryland’s residents if ACA is struck down. For more information, contact Maansi Raswant .
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Maryland Hospital Association | www.mhaonline.org