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Connection newsletter 7-20-23

Read about the OPPS and physician fee schedule proposed rules, next steps for the ground ambulance rule, and updated CMS guidance on ligature-associated risks and assessment.

CMS releases OPPS and physician fee schedule proposed rules

On Thursday, July 13, Centers for Medicare & Medicaid Services (CMS) released the calendar year 2024 outpatient prospective payment system (OPPS) and physician fee schedule proposed rules.

The proposed OPPS rate would increase by a net 2.8% above the current year’s rate which includes a 3% market basket update offset by a 0.2% percentage point reduction for productivity. Like other recently proposed rates, these rates do not accurately reflect the increased costs that hospitals are seeing, particularly with the labor market.

CMS has also proposed a number of improvements to behavioral health services, including new coverage for intensive outpatient program services and a new payment code for remote group psychotherapy. Additional changes would also be made for the hospital price transparency initiative including modifying standard charge display requirements and using a specific template when displaying standard charges. The proposed physician fee schedule includes a 1.25% pay cut, in part due to a 3.34% decrease in the conversion factor.

Comments for both proposed rules are due on Monday, Sept. 11, and AzHHA intends to submit comments. 

Ground ambulance rule revision expected in August

The Arizona Department of Health Services (ADHS) is revising its ground ambulance regulations and expects to post an updated draft in August to solicit additional feedback. For the first time, the rules will provide a methodology for evaluating ground ambulance performance on response times for interfacility transports and require corrective action plans for entities not meeting performance metrics. AzHHA held a member listening session with ADHS on Wednesday, July 12 to provide feedback prior to the initial Sunday, July 16 comment period deadline. Read AzHHA’s comments. The ADHS Director’s Blog explains more on the process and next steps.

CMS updates guidance on ligature-associated risk and assessment

On Monday, July 17, the Centers for Medicare & Medicaid Services (CMS) issued updated regulatory guidance regarding requirements for hospitals to assess patients and hospital environments for ligature-associated risks to patients. The guidance will influence how surveyors evaluate hospital compliance with Medicare Conditions of Participation.

Under the guidance, hospitals:

  • Do not need to have the same ligature risk abatement configurations throughout the facility as long as the specific needs and risks of individual patients are considered.
  • Can demonstrate compliance with patient safety rights by outlining the processes they are taking to minimize risks in accordance with nationally recognized standards and guidelines.

The updates are effective immediately; the State Operations Manual will be revised to reflect these changes.

Federal rule proposed to increase consumer protections around “skinny plans”

Last week, the Departments of Health and Human Services, Labor and Treasury released a proposed rule intended to limit the sale of non-comprehensive healthcare coverage and promote greater consumer understanding of their coverage options. Specifically, the rule would restrict the length of short-term, limited-duration insurance to no more than four months and prohibit the sale of fixed indemnity excepted benefits coverage that mirrors comprehensive health plans without needing to offer the same consumer protections.

In addition, it would amend the consumer notice requirements to ensure consumers understand the clear differences between these types of plans and comprehensive coverage as well as their options for purchasing comprehensive coverage. Comments are due Monday, Sept. 11.

🏆Your name here ____

AzHHA’s Quality Awards are open for submissions from outstanding applicants wanting to highlight their work in:

  • Patient Safety
  • Community Engagement
  • Emergency Management

Apply by Monday, July 31 and get ready to stand when you hear, “And the award goes to…”

Learn more about the awards and download application instructions.

The latest: Potential UPS worker strike

The big picture: United Parcel Service (UPS) is one of the largest third-party logistics providers in the world and a strike could have a significant impact on the healthcare supply chain. With drug shortages being at an all-time high in the U.S., a strike could further exacerbate the drug shortage issue. There would be potential slow-downs during the last-mile delivery of medical goods and pharmaceuticals. These are time- and quality-sensitive products and alternate sources of delivery are not particularly abundant. In fact, both USPS and FedEx do not have the current capacity to absorb all of UPS’ market share.

Timeline: The deadline for the company and the union to reach an agreement is Monday, July 31.

What’s happening now: The company’s main objective is to reach a deal before the deadline. However, UPS is ramping up preparations in the event of a walkout, and the union is also preparing for a potential strike. Read more about the preparations.

Implementation plan for cybersecurity strategy released by the White House

In follow up to the National Cybersecurity Strategy that was released in March 2023, last week the White House released a federal plan to collaborate with the private sector to implement the strategy.

The implementation plan aligns to the strategy’s pillars and strategic objectives. The five pillars are:

  1. Defending critical infrastructure
  2. Disrupting and dismantling threat actors
  3. Shaping market forces and driving security and resilience
  4. Investing in a resilient future
  5. Forging international partnerships to pursue shared goals

The full implementation plan is available here.

Calling all preceptors! You may be eligible for the Arizona State Preceptor Grant Program

Are you a certified nurse midwife, certified nurse anesthetist, clinical nurse specialist or a registered nurse practitioner? Have you recently served as a volunteer preceptor? If so, you may be eligible for a grant from Arizona Nurses Association.

Preceptors are limited to one $1,000 grant per state fiscal year (July 1-June 30) regardless of the number of preceptorships the applicant provides in that year.

Learn more about the program, requirements and how to apply.


Thursday, Aug. 31 - Introduction to POLST  
Join physician orders for life-sustaining treatment paradigm (POLST) for their one-hour virtual workshops equipping healthcare professionals with knowledge and resources to begin using POLST in Arizona.

The objectives of the workshops are:

  • To describe what POLST is at the state and national level.
  • Explain why POLST is important.
  • Define the population for POLST.
  • When to begin the conversation and who completes POLST.
  • Describe the process for completing, reviewing and updating POLST.
  • Learn the process of submitting healthcare planning documents to the Arizona Healthcare Directive Registry.

Register now.

Friday, Sept. 15 – AIM Collaborative Conference 
Register now for our second annual event focusing on AIM’s obstetric hemorrhage maternal health bundle. Hear from engaging speakers from around the state presenting on maternal health initiatives and integrating health equity into patient care. Attendees will include clinicians and executives from hospitals and birthing facilities, leaders from state agencies, community partners, not-for-profits, tribal healthcare and students. Sponsorship opportunities are available. Contact [email protected]. 

Friday, Oct. 13 – Arizona Burn Symposium 
The Arizona Burn Symposium is an opportunity for medical professionals to gather, learn and connect with experts in the field of burn care. The symposium features engaging speakers, informative panel discussions and interactive workshops that provide the latest advancements in burn care. Register today.


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