Back to the Drawing Board: Next Occupational Mix Survey by IPPS Hospitals Due July 3, 2017

The expression “Back to the drawing board” is associated with failure of a plan or design and the need to start fresh. The phrase actually originated as the caption to a cartoon in a 1941 New Yorker magazine. The cartoon shows military men racing toward a crashed plane and a man, with a roll of plans under his arm, walking away saying “Well, back to the old drawing board!”

CMS often takes this approach in determining how to reimburse providers for Medicare services, including how wage data is handled for Inpatient Prospective Payment System (IPPS) hospitals.

The reporting of wage index data in one form or another has been required since the implementation of DRGs and the IPPS in 1983. Initially, CMS collected the data every few years, but in 1989 Congress passed legislation directing CMS to update the index annually. The first Medicare wage data was from 1990 cost reports and was used to adjust 1994 IPPS rates. This four-year lag continues today due to the length of the cost reporting cycle and the need to allow time for review and correction.

An occupational mix adjustment was introduced also, but was not implemented for various reasons until 1990 with the passage of the Benefits Improvement and Protection Act (BIPA). BIPA mandated the collection of data on the occupational mix of employees’ data via a survey every three years.

Tip #34:

The next occupational mix survey is due July 3, 2017. Hospitals paid under IPPS must submit wage and hour data for full-time, part-time, contracted employees, and Home Office allocated salaries.

Further guidance can be found on the Centers for Medicare and Medicaid Services (CMS) website:

CMS Occupational Mix Survey

Questions? Please contact Marie White at 612.253.6546 or mewhite@eidebailly.com.

 

Exception-al CRNAs: Sometimes the Sole Provider in Rural Areas

According to the American Association of Nurse Anesthetists, nurse anesthetists are the oldest nurse specialty group in the United States and have been providing anesthesia care to patients in the United States for more than 150 years. The CRNA (Certified Registered Nurse Anesthetist) credential came into existence in 1956.

CRNAs are the primary providers of anesthesia care in rural America, enabling health care facilities in these medically underserved areas to offer obstetrical, surgical, pain management and trauma stabilization services. In some states, CRNAs are the sole providers in nearly 100 percent of the rural hospitals.[1]

The services of a non-physician anesthetist (CRNA) generally are paid for by the Part B contractor based on a fee schedule rather than on reasonable cost basis through the cost report.

But for some qualified rural hospitals or Critical Access Hospitals, a request can be made on an annual basis for an exception if the facility employed or contracted with not more than one FTE (2080 hours) non-physician anesthetist. There is also a threshold of 800 or fewer surgical procedures requiring anesthesia services and there can be no professional fee billing for the CRNA.

Tip #33:

Rural and Critical Access hospitals can request an exception to the CRNA Fee schedule if they meet certain criteria (CMS Pub 15-2, Section 4013). Further guidance can be found on the Centers for Medicare and Medicaid Services (CMS) website:

Provider Reimbursement Manual 15-2, Chapter 40

Questions? Please contact Marie White at 612.253.6546 or mewhite@eidebailly.com.

[1] American Association of Nurse Anesthetists, “Certified Registered Nurse Anesthetists Fact Sheet.”