Massachusetts Health & Hospital Association


> New RFA Supplemental Payment
> Commercial vs. Medicare Payments
> DPH’s Alternate Space Guidance
> Commonwealth Institute Award
> Mass. League Gala June 18
> ED Access Regulations


MassHealth Adjusts RFA to Address Boarding Crisis

The behavioral health boarding crisis that results in hundreds of patients – including children – stuck in hospital emergency departments (ED) and medical surgical floors as they await a behavioral health bed just got additional some relief from the state.

MassHealth last week released an amendment to the 2022 acute hospital Requests for Applications – the main contract between hospitals and the Medicaid program – that will provide a supplemental payment to promote enhanced ED psychiatric services.

The lump-sum payments are for the rest of Rate Year 2022 – or May 1 to October 31. To get the funding, a hospital must attest that it has the capacity to provide baseline services to all ED-presenting MassHealth psychiatric patients and that it has the capacity to provide at least one enhanced service to ED-presenting MassHealth psychiatric patients during the May-to-October period. Baseline services include family support and education, screening for substance use disorder, being able to refer to community-based providers for post-discharge care, and observation for those with suicidal and/or homicidal ideation. Enhanced services include medication management and evaluation, specific services for children, and group therapy.

The amount a hospital receives will be based on boarding days the hospital recorded in calendar 2021. The supplemental payment is for RY22 only; MassHealth anticipates incorporating boarding payment for RY23 and beyond as part of the conversation on the development of the RY23 RFA to reform the relationship between EDs and Emergency Services Programs (ESPs) as envisioned in the Executive Office of Health and Human Services’ Roadmap for Behavioral Health Reform.

“As the boarding crisis continues – including the growing length of stay for boarding patients before they gain an inpatient admission– it is increasingly difficult for acute care hospitals to have the resources to care for these patients under the current payment mechanism for ED visits,” said MHA’s Senior Director of Healthcare Policy Leigh Simons Youmans. “We are grateful for the significant support MassHealth has provided for the behavioral health system during this crisis and this MassHealth RFA amendment is an additional welcome step forward.”

Commercial Insurer vs Medicare Payments

A new study by the RAND Corporation published in Health Affairs (purchase required) shows that nationwide the average commercial insurer-to-Medicare price ratios – that is, how insurance company payments to hospitals compare to what Medicare pays – were “relatively stable.”

However, the study found that in some national hospital referral regions (HRRs) commercial insurer payments increased dramatically – up to 38% — between 2012 and 2019. The HRRs with high ratios in 2012 and large ratio increases in 2012–19 were in Washington State, California, Oregon, Colorado, Montana, Wisconsin, and Virginia. Notably, Massachusetts did not experience a large commercial-to-Medicare ratio increase.

The RAND study found that the percentage-point change in commercial-to-Medicare hospital price ratios from 2012 to 2019 in some parts of Massachusetts ranged from negative 5% to 5%, and in some parts greater than 5%.

“Massachusetts stands out as a state in which commercial-to-Medicare price ratios were low from the period 2012–19, illustrating how trends varied substantially across the country by HRR and within states,” the researchers wrote.

Facing High Volume of Patients, Hospitals Welcome Space Flexibility

DPH issued guidance last week that allows hospitals to continue using current licensed alternative spaces for adult med/surg or ICU care. The update extends the expiration of the alternative space flexibility from April 30, 2022, to July 15, 2022.

Hospitals had pressed for the extension as they face an influx of patients who deferred care during the height of the pandemic, and continuing delays in patient discharges as community transmissions once again increase. In issuing the guidance, DPH wrote, “The purpose of this memorandum is to continue to enable hospitals to increase the number of patients cared for by providing additional or alternate space to meet the demand and ongoing infection control best practices given the ongoing high levels of community transmission of COVID-19 and demand for healthcare system utilization. DPH believes this guidance will support the health and well-being of all patients by continuing to provide access to high-quality healthcare services.”

Alternate acute inpatient space includes post-anesthesia care unit beds, beds out of service, and inpatient rehabilitation units. Beds considered appropriate for acute inpatient care use must be equipped with medical gases (one oxygen outlet and one vacuum outlet for each bed), be spaced appropriately from another bed, and have access to hand washing sinks and privacy partitions.

Nominate an Extraordinary Woman

The Commonwealth Institute’s Extraordinary Women Advancing Healthcare Awards recognize 10 outstanding individuals across Massachusetts for their career achievements, demonstrating collaboration, mentorship, innovation, and fostering diversity in their organizations and in the healthcare community. Nominations are reviewed by a panel of distinguished judges based on the nominee’s impact in advancing healthcare, their inspiration to others, and their ability to innovate to bring about changes, improvements, or new healthcare services. View past winners and nominate a leader for the 2022 award by visiting here.

Mark Your Calendars: Mass. League Gala in June

The Massachusetts League of Community Health Centers turns 50 in 2022 and will celebrate with an anniversary gala, which will include the League’s annual community health center awards. Mark your calendar for Saturday, June 18 from 6 p.m. to midnight at the Sheraton Boston Hotel. Check back at for updates or e-mail questions to Mass League’s Cheryl Shaughnessy.

DPH Hearing on Hospital ED Access Standards

The Department of Public Health (DPH) will hold a public hearing on Friday, April 22 at 10 a.m. to review proposed changes to the hospital licensure regulation to address safe patient access to emergency departments.

In January 2021, Governor Charlie Baker signed An Act Ensuring Safe Patient Access to Emergency Care, which is known as “Laura’s Law” after Laura Levis, who died of an asthma attack just outside of an ED. The law required DPH to convene a working group to craft standards relating to, among other things, access, lighting, signage and staffing for each hospital to follow. The workgroup’s recommendations were released in December 2021. The April 22 hearing is on the proposed regulations to codify many of the recommendations in that December report.

MHA convened an ED Access Working Group of ED chiefs, chief nursing officer, facilities experts and others in September 2019 to make statewide best practice recommendations for emergency department signage, security, and staff education and training, among other topics. DPH’s report and proposed regulatory changes align closely with many of the recommendations MHA’s working group made in February 2020.

The hearing notice, a link to the proposed regulations, and an overview of the proposed changes are all here.

John LoDico, Editor