A Commitment on SUD, Surprise Billing, and more ...

Hospitals Take Another Step in Addressing SUD

Twelve hospitals in Boston and Cambridge have signed a commitment to provide mandatory substance use disorder (SUD) training to all of their hospital-based physicians and residents in key departments, and to also adopt at least three of 10 SUD initiatives designed to support their employees.
Boston Medical Center President and CEO Kate Walsh, Brigham Health President Betsy Nabel, M.D., and RIZE Massachusetts, the non-profit foundation addressing the opioid epidemic convened the hospital group earlier in 2019.
In addition to BMC and Brigham Health, the participating hospitals are Brigham and Women’s Faulkner Hospital; Tufts Medical Center; Massachusetts General Hospital; Beth Israel Deaconess Medical Center, Mount Auburn Hospital and New England Baptist Hospital, all part of Beth Israel Lahey Health; Cambridge Health Alliance; Boston Children’s Hospital; Carney Hospital; and St. Elizabeth’s Medical Center.
Specifically, the hospitals commit to mandatory training of all hospital-based ED physicians, hospitalists, obstetricians, psychiatrists, adolescent pediatricians, infectious disease specialists, primary care providers, and internal medicine residents who are not already waiver-trained to prescribe buprenorphine. (The federal government requires “X-waivers”, consisting of training and registration, before a clinician can prescribe buprenorphine for use in maintenance therapy for patients with SUD.) The training the 12 hospitals will offer will be focused on the fundamentals of addiction, effective treatment options, and addressing the stigma associated with SUD. The hospitals are also strongly encouraged to train other providers and commit to increasing the number of caregivers who are waiver-trained.
As for employee support, the hospitals are asked to choose at least three actions from the following list: free naloxone training, surveying employees about the need for SUD support, reviewing existing SUD benefits, putting existing benefits in an SUD guide for all employees, creating an SUD Employee Support Policy, developing training for managers to help them identify and support workers with SUD, setting up a family support group on site, holding a public “Town Hall” event to discuss the issue, sending a letter from the CEO promising a stigma-free workplace, and sharing a pledge to encourage employees to use stigma-free language (such as “person with SUD” as opposed to “addict”).

MassHealth Makes it Easier to Provide Substance Use Disorder Treatment

As the commonwealth continues to work to address the opioid crisis, MassHealth has released several bulletins regarding the coverage and coding of Medication for Addiction Treatment (MAT) in order to increase access to treatment. MHA and its member hospitals had advocated for, and worked with the state on, a number of the changes.
MassHealth will no longer require prescribers to fax their “X-Waiver” to it when buprenorphine prescriptions for MassHealth members are issued. This red-tape elimination increases timely access to MAT. Similarly, MassHealth is now requiring all of its managed care entities to provide access, without prior authorization, to at least one buprenorphine/naloxone treatment at a certain dosage. The coding for MAT has also changed, which will allow providers and plans to track how frequently MAT-related services occur. Opioid Treatment Programs, which had only been able to bill for the administration and dispensing of methadone, will now be able to serve as continuing treatment providers for patients in need of buprenorphine and naltrexone.

Surprise Billing Proposal in U.S. House Sets Default Rate

The U.S. House Energy and Commerce Committee last Wednesday passed H.R. 2328, which includes a provision that hospitals support to avert cuts to disproportionate share hospitals (DSH), but also contains “surprise billing” provisions that, while better than language that had previously circulated, still restricts the ability of providers and insurers to negotiate all payments. 
The DSH provision would eliminate Medicaid DSH cuts in FYs 2020 and 2021, and reduce the cut in FY 2022 to $4 billion – as opposed to $8 billion. The DSH language in the bill reflects an amendment sponsored by Rep. Joe Kennedy (D-MA) in the health subcommittee last week.
The surprise billing language comes from an amendment that passed during the bill’s markup. That amendment adds an arbitration process for hospitals and physicians that receive a median in-network payment of more than $1,250. If the payment is below $1,250, and the providers disagree with it, they have no recourse but to accept it.
Surprise billing occurs when a patient receives covered services from an out-of-network provider in an emergency situation or is treated by an out of network clinician at a facility that is in network. Just about every stakeholder, including hospitals, believe that patients should be protected from surprise bills and should pay no more than they would have paid if the service had been rendered in network. Determining how the out of network provider should be reimbursed has been more controversial. MHA believes that hospitals and insurers should use a model similar to one implemented in New York – essentially, baseball style arbitration is a backstop between the two parties if they are unable to come to an agreement on a rate. While last week’s Energy & Commerce bill does have an arbitration provision, it doesn’t kick in unless the rate exceeds the $1,250 default.
The American Hospital Association strongly opposed the surprise billing provision of H.R. 2328, saying, “It is the insurers' responsibility to maintain comprehensive provider networks, and a default payment rate would remove incentives for plans to contract with providers or to offer fair terms.”
Massachusetts legislators are working on their own surprise billing protections for patients. MHA will continue to press for a no-limit arbitration process like New York’s.
The American Hospital Association strongly opposed the surprise billing provision of H.R. 2328, saying, “It is the insurers' responsibility to maintain comprehensive provider networks, and a default payment rate would remove incentives for plans to contract with providers or to offer fair terms.”
Massachusetts legislators are working on their own surprise billing protections for patients. MHA will continue to press for a no-limit arbitration process like New York’s.

DMH Issues Final Rule on Licensing, Operations

The Department of Mental Health has amended the regulations relating to its oversight of the licensing and operation of mental health facilities. Most of the changes relate to the implementation of Chapter 208 of the Acts of 2018 – last year’s substance use disorder law.
The final regulation incorporates feedback that MHA and the Massachusetts Association of Behavioral Health Systems (MABHS) provided, requiring DMH, when determining licensing, to consider the health needs of persons in the commonwealth with a mental illness, including underserved populations and persons with co-occurring mental illness and substance use disorder, as outlined in Chapter 208.
Among other guidelines, DMH’s regulations require all licensed DMH facilities to provide services to commonwealth residents with public health insurance on a non-discriminatory basis, and require the reporting of the facility’s payer mix to DMH on a quarterly basis. DMH will accept payer mix reports from existing public data sources, including those from the Center for Health Information and Analysis. The reporting reflects a process that MHA and MABHS had proposed.

Other regulations relate to transport of patients, the designation of comfort or sensory places in a facility, and allowing the greater use of telemedicine to meet the requirements of a patient’s timely interaction with a clinician.

More and More Doctors Exploring Telemedicine

A recent study has found that the number of physicians who self-reported telemedicine as a skill doubled between 2015 and 2018 and continues to increase by approximately 20% per year. The data also shows that female physicians were 10% more interested in telemedicine job opportunities, relative to their male counterparts. Doximity, a physician social network, based the findings on job postings within its network.
MHA is a founding member of tMED – the Massachusetts Telemedicine Coalition – which is advocating for: parity in insurance coverage for telemedicine services on par with in-person treatment; a flexible definition of telemedicine that recognizes the adoption of new technologies that are being used to provide care; and streamlining the credentialing process for Massachusetts-licensed clinicians using telemedicine services within the state to reduce the paperwork burden for providers. Telemedicine is a tool that healthcare providers, payers, patients, and employers can use to improve access to care for patients, improve health outcomes for chronic illnesses, reduce costs for patients seeking in-person medical visits, keep employees productive at their jobs, and allow children to stay in the classroom instead of taking time out to travel to and from medical care.

Hospital Developments in Mass. and R.I.

Somerville Hospital, part of Cambridge Health Alliance, has announced that it will convert its emergency department (ED) to an urgent care center, effective in the spring of 2020. The hospital said the changing demographics of its service area drove the change. It noted that ED visits are down 36% over the past 10 years and that the kind of care patients seek in the Somerville ED is closer to urgent care level than an emergent level. Somerville Hospital said all affected employees will be offered comparable positions within the urgent care center or elsewhere within Cambridge Health Alliance.
In Rhode Island, Care New England, the parent of Butler, Kent and Women & Infants hospitals, has called off merger negotiations with Providence-based Lifespan health system and Brown University. Massachusetts-based Partners HealthCare had been negotiating with Care New England but ended its talks earlier this year at the request of Rhode Island’s governor, who wanted to craft a Rhode-Island-focused merger. 

18th Annual Women Leaders in Healthcare Conference

Join us for one of MHA’s more popular annual programs – the Women Leaders in Healthcare Conference, taking place on Thursday, September 26 from 8 a.m. to 2:30 p.m. at the Sheraton Framingham Hotel. This year we’ll feature a speaker from the Studer Group, discussing their popular book Compassionomics: The Revolutionary Scientific Evidence That Caring Makes a Difference. The book presents a rigorous review of the science, coupled with captivating stories from the front lines of medicine, to demonstrate that the human connection in healthcare matters in astonishing ways.  Also, author and speaker Debra Fine will deliver a talk entitled The Fine Art of Building Business Relationships and Expanding Networks: One Conversation at a Time.  She’ll discuss the importance of conversation, networking, and rapport-building skills in advancing one’s career. Learn more and register by visiting here.

John LoDico, Editor