Learning Objective 4 - Government Programs Flashcards
physician reimbursement uses a fee schedule based on:
RBRVS - resource-based relative value scale
Impact of the CMS-HCC model being additive
will incrementally increase payment for multiple conditions that are not closely related.
MLR for MA plans under the ACA
85%
Individuals eligible for Medicare Coverage
- Aged - at least age 65 and eligible for Social Security or Railroad Retirement benefits
- Disabled - entitled to Social Security or Railroad Retirement disability benefits for at least 2 years
- ESRD - insured workers with ESRD, including spouses and children with ESRD
- Some other aged and disabled individuals who pay mandatory premiums
Types of Medicare coverage
- Part A - hospital insurance (HI) - eligible persons receive coverage automatically with no premium charge
- Part B - supplementary medical insurance (SMI)
a. Requires a monthly premium ($99.90 in 2012, higher for high incomes)
b. Beneficiaries can decline coverage, but a premium penalty (10% per year) applies if coverage is elected at a later date - Part C - Medicare Advantage
a. Alternative to Parts A & B. Offered by private plans, which receive a capitation from Medicare, which varies by county and enrollee risk.
b. Typically offer lower cost sharing plus coverage from some services not covered under Medicare. - Part D - covers most Rx. Provided through private insurers.
- Medicare Supplement - private insurance to cover OOP costs and some other benefits not covered by Medicare.
Services covered by Medicare Part A
- Inpatient Hospital - semi-private room and ancillary services and supplies
- SNF - semi-private room, meals, skilled nursing and rehabilitative services after a related 3 day inpatient hospital stay
- Home health agency - services following discharge from a hospital or SNF
- Hospice care - provided to terminally ill patients with life expectancies less than 6 months
Medicare Part A cost sharing and coverage limits
Based on a benefit period, which starts at admission and ends 60 days after discharge from hospital or SNF. The $ amounts are indexed; amounts shown are for 2015.
- Inpatient Hospital
Cost-sharing: $1,260 deductible per benefit period
$350/ day for days 61-90 of ben period
$630/ day for days 91-150 each lifetime reserve day
Coverage Limits: 60 lifetime reserve days; No coverage beyond lifetime reserve - SNF
Cost Sharing: $157.50/ day for days 21-100 of each benefit period
No coverage after 100 days each benefit period - Home Health Agency
Cost Sharing: None
Coverage Limits: 100 visits per illness - Hospice Care
No cost sharing or coverage limits - Blood
Cost Sharing: cost of 1st 3 pints of blood
No coverage limit
Services covered by Medicare Part B
- Outpatient hospital ( including ER)
- Medical care by qualified health practitioners (including diagnostic tests, supplies, and DME)
- An initial preventive care visit within 12 months of enrolling in Part B and yearly wellness visits thereafter
- Ambulance
- Clinical laboratory and radiology
- Physical and occupational therapy
- Speech pathology
- Outpatient rehabilitation
- Radiation therapy
- Transplants
- Dialysis
- Home health care beyond that covered by Part A
- Drugs & biologicals that cannot be self-administered
- Certain preventive services (such as an annual flu shot or cancer screenings)
Medicare Part B cost sharing
- Calendar year deductible ($147 in 2015)
- Coinsurance after the deductible (usually 20% of the Medicare-approved amount, but does not apply to clinical lab and certain preventive care services)
Drug types excluded from standard Part D coverage
- Drugs covered by Part A or B
- Anorexia and weight loss drugs
- Fertility drugs
- Cosmetic drugs (including hair loss)
- Drugs used to relieve cough and cold symptoms
- Vitamins and minerals (except for prenatal vitamins and fluoride)
- OTC drugs
Funding sources for the Medicare Program
- Medicare is funded on a pay-as-you-go basis
- SMI
a. Part B is financed through contributions from the general fund of the Treasury (75%) and beneficiary premiums (25%)
b. Part D is financed through a separate account in the SMI trust fund, from general revenues (74.5%) and premiums (25.5%) - HI (Part A)
a. Payroll tax rate is 1.45% of all earnings (not caped), with a matching employer tax
b. The ACA added an additional 0.9% payroll tax and a 3.8% tax on investment income for high-income taxpayers.
Approaches for improving Medicare solvency
- Increase taxes
- Reduce or eliminate some covered services
- Increase Medicare cost sharing through higher deductibles and copays
- Raise the eligibility age for benefits to age 66 or 67
- Adjust reimbursement to providers of care
- Encourage new initiatives and expand existing initiatives that lower trend.
Medicare provider reimbursement
- Hospitals - reimbursed on a prospective payment system based on the diagnosis-related grouping (DRG) methodology. Paid a set amount for each admission (which encourages hospitals to provide services efficiently) based on the patient’s condition and the services provided.
- Physicians - uses a complex fee schedule to assign relative values to services. Reimbursement equals the sum of area-adjusted unti values, multiplied by a nationwide conversion factor. Unit values for the procedures are based on:
a. Work Value - measuring the time and skill required
b. Practice expense - reflecting the cost of rent, staff, supplies, equipment, and overhead
c. Malpractice value - measuring the associated professional liability costs - Outpatient services - reimbursed on an outpatient prospective payment system known as ambulatory payment classification (APC)
Categories of Medicaid-eligible individuals
- Categorically eligible groups
a. These groups include children, parents or other caretakers with dependent children, pregnant women, individuals with disabilities and seniors
b. Individuals in these categories must also meet income and asset requirements (the minimum criteria is set by the federal government). For example, states cover all pregnant women and children under age 6 with incomes below 138% of the FPL - Medically-needy individuals - states often extend coverage to these individuals, who qualify when their medical expenses reduce income below defined limits
- The State Children’s Health Insurance Program (CHIP) allows states to expand coverage to uninsured children from low-income families not eligible for Medicaid, typically with an upper limit of 200% of FPL
- The ACA expanded eligibility to everyone under age 65 with income up to 138% of FPL (in states that choose to expand)
Workers in the US who are not covered by Social Security
- Federal employees hired before 1984
- About 1/4 of state and local workers (who are covered by plans comparable to Social Security)
- A very small # of people who object to receiving governmental benefits on religious grounds
- Certain agricultural and domestic workers
- Railroad employees who are covered by a program similar to Social Security
Requirements for insured statuses under Social Security
One credit is earned for each $1,200 of wages (year 2014 amount; indexed), up to a max of 4 per year. All 4 credits can be earned at any time during the year. (Many earn all 4 in January)
- Disability-insured status - requires between 6-40 credits. Some credits must have been earned recently, as follows:
a. For those required to have 20 or more credits, 20 credits must be from the last 40 quarters
b. for those required to have more than 6 and less than 20 credits, at least half must have been earned after age 21
c. For those required to have 6 credits, all must be from the last 12 quarters - Fully-insured status - requires credits equal to the worker’s age minus 22, with a minimum of 6 an a max of 40
- Currently -insured status - requires 6 credits in the 13 calendar quarters ending with the quarter of death
Eligibility and benefit amounts for Social Security disability and survivor benefits
- Disabled-worker benefits
a. Eligibility - must be disability insured and fully-insured and be unable to engage in any “substantial gainful activity” because of a physical or mental impairment that has lasted or is expected to last for 12 months or to result in death.
b. Benefit amounts - calculated using essentially the same procedures used for retired-worker benefit amounts, using an assumed age of 62 and no early-retirement reduction factor. - Survivor Benefits
a. Eligibility - family members may receive survivor benefits if the worker was either fully insured or currently insured at the time of death
b. Benefit amounts - the worker’s primary insurance amount (PIA) is computed using the standard procedures assuming an age of 62. Survivors receive a % of the PIA:
I. 75% for eligible children
ii. grading linearly from 71.5% at age 60 to 100% at normal retirement age for eligible widows or widowers
iii. 82.5% for an eligible surviving parent, or 75% each for 2 parents. ( a family max applies, typically 175%)
Equivalence requirements for Part D employer group wavier plans (EGWPs)
- Benefits must be at least as rich as standard Part D benefits
- The deductible must be no greater than the standard Part D deductible
- Benefits in the same coverage gap must be at least as rich as standard Part D benefits
- Catastrophic coverage must be at least as rich as standard Part D catastrophic coverage
Types of Part D plans
- Prescription Drug Plans (PDPs) - private stand-alone plans that offer drug-only coverage.
- Medicare Advantage prescription drug plans (MA-PDs) - plans that offer both prescription drug and health coverage
Late enrollment penalty for Part D plans
- Applies to those who do not sign up for Part D when they are 1st eligible
- is 1% of the base beneficiary premium for every month the person waited to enroll
- Is paid every month for the beneficiary’s lifetime
- Does not apply if the individual had creditable coverage through another source (such as an employer or retirement plan). Coverage is creditable if it is at least as good as Medicare Part D
Options provided by CMS to incentivize employers to participate in Part D
- Retiree Drug Subsidy (RDS)
a. To qualify for the subsidy, the plan must provide an actuarial attestation that it provides coverage at least as rich as the original Par D benefit design (gross test) and with a subsidy at least as great as the Part D subsidy (net test). The net value is calculated by subtracting retiree premiums from the gross value.
b. government reimburses the sponsor for 28% of prescription drug spending otherwise covered by Part D for drug costs between the cost threshold ($310 in 2011) and cost limit ($6,300 in 2011)
c. Drug rebates are subtracted from the amount eligible for the subsidy
d. Easiest option, but now less attractive after the ACA eliminated the subsidy as of 2013 - Employer group waiver plan (EGWP) - was conceived to be superior to the RDS. Two options:
a. Direct contract EGWP - contract directly with CMS to become a PDP
b. “800” series EGWP - outsource to a 3rd party PDP or MA-PDP, who performs the administrative and financial functions of the plan - Coordinate benefits in a wraparound plan
a. Employer plan fills in benefit voids that are not covered by Part D (e.g., paying the deductible or a % of the coverage gap or total OOP costs)
b. A concern with this option is that pharmacies may not be prepared to manage patients with 2 benefits (Part D wrap around plans)
Advantages of using EGWP instead of RDS
- Cost Savings - savings are about 15-20% in RDS compared to 19-35% under EGWP
- Minimal disruption to the membership - current plan design can usually be maintained
- Ta obligations are treated equally between EGWP & RDS
- Direct monthly subsidy is received from CMS
- Governmental Accounting Standards Board Statements 43/45 liability is reduced
- Part D benefit provides catastrophic coverage
- Additional advantages of using an “800” series EGWP
a. administrative functions are handled by the 3rd party sponsor
b. Risk avoidance - risk is shifted to the 3rd party sponsor
c. The employer has no direct contact with CMS
d. The 3rd party will handle compliance and regulatory issues.
Beneficiary cost sharing for the standard Part D benefit design
$0 - $320: deductible
$320.01 - $2,960: 25% coinsurance
$2960.01 - $4,700 (TrOOP): Coverage gap (“donut hole”), 65% generic, 45% brand coinsurance*
After TrOOP: about 5% coinsurance**
- due to the ACA, these %s are gradually decreasing until they both reach 25% in 2020
- *Greater of 5% or a copay of $.2.65 for generics and preferred multiple source drugs or $6.60 for other drugs
- TrOOP = True OOP costs
- the deductible, initial coverage limit ($2,960), TrOOP, and catastrophic copays are indexed annually. Amounts shown here are for 2015
- Low-income beneficiaries have a different benefit design. For example, dual eligible pay no premium, have no deductible, and pay only a small copay for drugs.
Impact of regulations on the MA program
Programs where Medicare contracts with private plans to provide benefits to seniors and the disabled.
- The Tax Equity and Fiscal Responsibility Act (TEFRA) of 1982 authorized the Medicare program to pay HMOs on a capitated basis. These HMOs were able to lower costs and use the savings to offer more comprehensive benefits than FFS Medicare, so these plans grew steadily.
- The Balanced Budge Act (BBA) of 1997 significantly reduced health plan payments. About half of the beneficiaries in Medicare health plans exited over the next few years.
- The Medicare Modernization Act (MMA) of 2003 reignited enrollment:
a. Creating the Medicare Part D drug benefit
b. Creating regional MA PPOs
c. Creating special needs plans (SNPs)
d. Dramatically increasing payment for MA plans
e. Introducing competitive bidding and risk-adjusted payments. - The ACA made dramatic changes to MA:
a. MA plans suffered cuts of $136 billion over 10 years.
b. A new payment methodology was introduced, reducing county benchmark rates to between 95% and 115% of FFS Medicare rates.
c. Bonus payments were introduced for plans that achieve at least four start under a new star rating system. High-quality plans will receive a bonus of 5% of the new benchmark payment rate, with certain counties being eligible for double bonuses. Rebates were also tied to quality ratings
d. A minimum medical loss ratio standard of 85% was also imposed.