During the COVID-19 federal public health emergency, due to federal requirements, Indiana Medicaid members were able to keep their coverage without interruption. Indiana Medicaid will begin to process eligibility redetermination actions beginning April 2023, with a 12-month plan to return to normal operations. Details of this plan can be found here.
It is estimated the 500,000 currently enrolled Medicaid members are at risk of losing coverage over the next 12 months. Hospitals should work to ensure their patients maintain coverage if eligible or seek alternative coverage through the marketplace. A toolkit has been developed to help organizations communicate and assist Medicaid members in choosing the appropriate pathways.
Communicating Changes to Medicaid - Ways You Can Help Hoosiers Stay Insured: A Toolkit
This recently launched toolkit is a collaborative effort of many organizations, including the Indiana Hospital Association, whose member hospitals serve Hoosiers with Medicaid. We hope you will join our collective effort to ensure Hoosiers either keep their Medicaid or find other health insurance coverage as Medicaid “unwinds" and returns to normal operations beginning in April.
The toolkit is for community organizations, businesses, faith-based organizations, schools, health centers, and other medical providers. With one in three Hoosiers currently enrolled in a Medicaid program, an "all hands on deck" approach is the best way to avoid a dramatic increase in the number of uninsured Hoosiers. We need YOU to help communicate the messages in this toolkit to your community by:
- Sharing information in your newsletters, social media, websites, etc.
- Forwarding this email to your partners.
- Hanging posters from the State and from Navigator organizations
- Telling everyone the three key messages (more details in the toolkit):
- Make sure the State has your correct contact information (update on the FSSA benefits portal or by calling)
- Open your mail from the State and your Managed Care Organization
- Seek help from an Indiana Certified Navigator
- Educating staff and volunteers so they can make referrals to Navigators
- Checking back for new editions and other updates to the toolkit; the Medicaid unwinding is a yearlong event
- Sending questions, suggestions or additional resources to dhiggins@ckfindiana.org
The toolkit will be housed on the websites for Covering Kids & Families of Indiana, Hoosier Action and the Indiana Primary Care Association.
IDOI Announces Onpoint as Administrator of APCD
On Feb. 14, the Indiana Department of Insurance announced Onpoint Health Data as the administrator for the All Payer Claims Database (APCD), the next step to operationalize the APCD as a source of health care transparency across the continuum. Read more here.
CMS Instructs IDRs to Pause Payment Determinations
Following a Feb. 6 court decision that vacated nationwide the federal government's revised independent dispute resolution (IDR) process for determining payment for out-of-network services under the No Surprises Act (NSA), the Centers for Medicare & Medicaid Services instructed certified IDR entities to hold all payment determinations until the Departments of Health and Human Services, Labor, and the Treasury (Departments) issue further guidance. Certified IDR entities have also been instructed to recall any payment determinations issued after Feb. 6.
"The Departments are currently reviewing the court's decision and evaluating current IDR processes, guidance, templates, and systems for updates that will be necessary to comply with the court's order," CMS said. "The Departments will provide specific directions to certified IDR entities for resuming the issuance of payment determinations that are consistent with the court's judgment and order. Certified IDR entities should continue working through other parts of the IDR process, including eligibility determinations, as they wait for additional direction from the Departments."
A Texas judge on Feb. 6 held that the revised IDR process skews the arbitration results in commercial insurers' favor in violation of the compromise Congress reached in the NSA. As a result of this decision, the regulations are vacated nationwide.
American Heart Month
February is American Heart Month, and IHA would like to remind members to prioritize their cardiovascular health. Watch this short video to learn how you can take part.
IHA Weekly News - Feb. 8, 2023
"Operation Nightingale": Fraudulent Nursing Diploma Scandal Exposed
The alleged scheme involved the selling of fake and fraudulent nursing degree diplomas and transcripts obtained from accredited Florida-based nursing schools to aspiring Registered Nurse (RN) and Licensed Practical/Vocational Nurse (LPN/VN) candidates. The scheme involved the distribution of more than 7,600 fake nursing diplomas and transcripts. IHA and Hall Render have put together a memo (below) outlining this national licensure fraud activity and steps organizations should consider to address any concerns.
COVID-19 Temporary Healthcare Provider Registry Update
The continuation of Indiana's COVID-19 Temporary Healthcare Provider Registry is linked to the duration of the federal PHE, which is now set to end on May 11, as reported last week. Accordingly, any temporary practitioner licenses must be transitioned to a full license by May 11 for a practitioner to continue providing healthcare services after that date in Indiana.
Reimbursement Changes for EMS Providers
The Indiana Health Coverage Programs (IHCP) announced upcoming changes to the reimbursement rates for Emergency Medical Services providers for advanced life support services, basic life support services, and nonemergency medical transportation services in accordance with the House Enrolled Act 1112 from the 2022 legislative session.
For dates of service on or after July 1, 2023, Medicaid will reimburse these services at the lower rate of one of the following:
- The provider's submitted charge.
- The allowable amount for that procedure code in the IHCP Professional Fee Schedule in effect for that date of service. The allowable amount is equal to the Medicare urban rate for Indiana as of each Jan. 1, if available.
- If the Medicare urban rate for Indiana is not available, the allowable amount is equal to the IHCP Professional Fee Schedule rate in effect for that date of service, adjusted for inflation as determined by the Office of Medicaid Policy and Planning.
Mar. 10 Deadline: Indiana Healthcare Benefits Survey
The Indiana Hospital Association and Gallagher Surveys invite all member facilities to participate in the 2023 Indiana Healthcare Compensation and Benefits Survey. The survey is the premier source of compensation and benefits data for healthcare organizations across the state. Your organization's participation will grant you access to an indispensable planning tool while also helping build a resource used by your peers. Logins and instructions were sent out to previous participants during the week of Jan. 30. If you or your designated representative did not receive the email, please reach out to
Dillon Kenny at Gallagher.
The reporting process for 2023 consists of 2 easy steps. The first step involves going online and completing the benefits section of the survey. The second step is to complete the compensation data spreadsheet and upload a copy to Gallagher’s secure server.
Important: If you are reporting for multiple hospitals/locations, you may include all of them on one compensation submission and only need to complete the online benefits section once for the whole system.
- Effective Date: Jan. 1, 2023
- Benefits Submission Deadline: Mar. 10, 2023
- Compensation Submission Deadline: May 1, 2023
The survey staff at Gallagher Surveys will be available to respond to any questions. Please contact Thomas Cummins or Dillon Kenny with any questions or concerns.
Dillon Kenny
Survey Analyst
Gallagher Surveys
Phone: 617-531-7768
Thomas Cummins, CCP
Managing Director
Gallagher Surveys
Phone: 617-531-7758
IHA Weekly News - Feb. 1, 2023
New Kaufman Hall Report: Indiana Hospitals Suffer Toughest Financial Year Since Before Pandemic
There is a new report by Kaufman Hall on the current state of Indiana hospital finances. IHA held a virtual press conference today with statewide media to announce the findings and share financial challenges hospitals are facing across the state. Please find our press release below with the report hyperlinked, as well as a recording of the press conference.
Administration to End COVID-19 Emergency Declarations on May 11
On May 11, the Biden Administration plans to end the COVID-19 national and public health emergencies declared in 2020, according to a
policy statement released yesterday by the Office of Management and Budget, opposing House resolutions that would end the emergencies immediately if passed. The Administration’s plan would align with its previous commitments to give at least 60 days’ notice before terminating the PHE.
2023 IHA Event Dates Announced
Save the date for the 2023 IHA Administrative Professionals Conference and Patient Safety Summit.
- Administrative Professionals Conference: May 11, CRG Event Center
- Patient Safety Summit: Jun. 22, Renaissance Indianapolis North Hotel
Event details and registration info will be coming soon!
IHA Weekly News - Jan. 25, 2023
2023 Patient's Compensation Fund Surcharges
On Jan. 12, 2023, the Indiana Department of Insurance published Bulletin 267 outlining the surcharges for physicians and hospitals for the Patient's Compensation Fund (PCF) effective July 1, 2023. Notably, Bulletin 267 provides that the 2023 PCF surcharges for physicians and hospitals will remain flat and will not change from the current effective rates as outlined in the Bulletin.
A more detailed memo on Bulletin 267 can be found here: 
PCF Memorandum.pdf.
Advancing Health Equity Among Hispanic/Latino PopulationsLearning series, in Spanish, on best practices and opportunities for action
The Health Resources and Services Administration’s (HRSA), Office of Intergovernmental and External Affairs (IEA) invites you to be part of the next round of our Advancing Health Equity Among the Hispanic/Latino Populations Spanish Learning Series.
This four-part series includes didactic portions on selected topics as well as discussions about factors that contribute to health disparities, barriers to health equity, and successful strategies and models to improve access to care and advance health equity among Hispanic/Latino populations. Participants will be able to engage with subject matter experts and potential new partners and receive information on HRSA programs and resources to support their health equity efforts.
1st Session: Getting to Know HRSA
Date: Tuesday, February 7, 2023
Time: 1 p.m. - 2:15 p.m. EST
Session Objectives:
- Discuss HRSA programs, funding opportunities, and resources to enhance primary healthcare access and advance health equity.
- Share effective ways to collaborate and stay connected to HRSA to leverage resources and gain access to innovative and high-value programs.
Featured Speakers:
- Lauren DeVol, Public Health Analyst, HRSA Intergovernmental and External Affairs (IEA)
- Mayra Nicolas, Deputy Division Director, HRSA Office of Policy and Program Development (OPPD)
- Mae Ruppert, Supervisory Public Health Analyst, HRSA Ryan White HIV/AIDS Program (RWHAP)
- Natalia Vargas, Public Health Analyst, HRSA Federal Office of Rural Health Policy (FORHP)
Moderator:
- Veronica Roa, Public Health Analyst, HRSA Intergovernmental and External Affairs (IEA) Region 1, Boston
HRSA IEA will broadcast the session in Spanish with live language interpretation to English. Prior to the session, registrants will receive a copy of the presentation in English with instructions for accessing the interpretation services and closed captioning.
___________________________________________________________________________________________
Avanzando hacia la equidad en salud para las poblaciones hispanas/latinas
Serie de seminarios virtuales, presentados en español, sobre modelos exitosos y oportunidades para una comunidad hispana/latina más sana
La Oficina de Asuntos Intergubernamentales y Externos (IEA, por sus siglas en inglés) de la Administración de Recursos y Servicios de Salud (HRSA, por sus siglas en inglés) lo invita a ser parte de la próxima ronda de nuestra serie de aprendizaje en español Avanzando hacia la equidad en salud para las poblaciones hispanas/latinas.
Esta serie de cuatro entrenamientos incluye porciones didácticas de tópicos selectos, así como discusiones sobre los factores que contribuyen a las disparidades de salud, los obstáculos a la equidad, y estrategias y modelos exitosos para mejorar el acceso al cuidado de salud y la equidad para los hispanos/latinos. Los participantes se relacionarán con expertos en la materia y además recibirán información sobre los programas y recursos de HRSA para apoyar sus esfuerzos a favor de la equidad en salud.
Primera sesión: Conociendo a la Administración de Recursos y Servicios de Salud (HRSA)
Día: martes, 7 de febrero de 2023
Hora: 1 p.m. - 2:15 p.m. EST
Objetivos de la sesión:
- Discutir los programas de HRSA, las oportunidades de financiación y los recursos para mejorar el acceso a la atención médica primaria y promover la equidad en salud.
- Compartir formas efectivas de colaborar y mantenerse conectado con HRSA para aprovechar mejor los recursos y obtener acceso a programas innovadores y de alto valor.
Distinguidos presentadores:
- Lauren DeVol, Analista de Salud Pública, HRSA IEA
- Mayra Nicolas, Subdirectora de la División, Oficina de Desarrollo de Políticas y Programas, HRSA
- Mae Ruppert, Supervisora, Programa de Ryan White de VIH/SIDA, HRSA
- Natalia Vargas, Analista de Salud Pública, Oficina Federal de Política de Salud Rural, HRSA
Moderadora:
- Veronica Roa, Analista de Salud Pública, HRSA IEA Región 1 - Boston
El seminario web se transmitirá a través de Zoom en español con interpretación en vivo al inglés.
Para más información acerca de la sesión, por favor comuníquese con
Veronica Roa.
IHA Weekly News - Jan. 18, 2023
Public Health Day: Investing in Hoosier Lives
Public Health Day is Jan. 26 at the Statehouse. Please join the IN Department of Health from 11 a.m. to 1 p.m. in the North Atrium and help champion the biggest transformation in public health in Indiana in decades. Governor Eric J. Holcomb and other speakers will share why public health matters and discuss the efforts underway to ensure that every Hoosier has access to the same core public health services, regardless of where they live or work.
This initiative is the product of a months-long study of Indiana’s public health system conducted by the Governor’s Public Health Commission, which produced recommendations on issues ranging from funding and workforce to emergency preparedness, childhood and adolescent health, governance and services, and data integration.
Date/Time: Thursday, Jan. 26 from 11 a.m. - 1 p.m. ET
Location: Indiana Statehouse - North Atrium
Huron Webinar | Trends Shaping the Future of Healthcare
Date/Time: Tues, Jan. 24, 3 pm ET (60 minutes)
Faculty: Craig Deao, Huron
Healthcare is at an unprecedented time in its evolution. Disruptive trends threaten how care is consumed and delivered while creating opportunities to innovate and bring new value to healthcare consumers. We will examine key trends that will change how organizations compete in the market and consider how they may impact your organization's vision of the future.
Objectives:
- Describe industry trends disrupting the healthcare market across consumerism, technology, competition, care models, economics, and workforce.
- Reflect on the impact of these trends on your organization and how it compares with other organizations nationally
IHA Weekly News - Jan. 11, 2023
FTC Issues Proposed Rule on Noncompete Clauses
On Jan. 5, the Federal Trade Commission (“FTC") issued a Notice of Proposed Ruling Making (the “Proposed Rule") that seeks to make it illegal for employers to enter into non-compete clauses with workers. The FTC's Factsheet can be found here and the FTC's Proposed Rule can be found here.
A memorandum from Hall Render outlining the Proposed Rule, its background, the timing of the Proposed Rule, and the impact of the Proposed Rule on the health care industry can be found here. The FTC has limited jurisdiction over non-profit entities under the law used to promulgate the Proposed Rule, so the Proposed Rule should not apply to non-profit health systems and hospitals as currently drafted, but in the past, there has been bipartisan support to remove the non-profit limitation.
IHA encourages all members to review this memorandum closely. If you have any questions, please do not hesitate to contact Bill Berlin (wberlin@hallrender.com), Dana Stutzman (dstutzman@hallrender.com), John Williams III (jwilliams@hallrender.com), or another member of the IHA team.
IHA Weekly News - Jan. 4, 2023
Friends of Indiana Hospitals 2022 PAC Campaign Summary
The Friends of Indiana Hospitals 2022 campaign has now ended and IHA is grateful to all members who contributed to the campaign last year. In 2022, we increased donations and raised a total of $146,567. Thanks to your ongoing participation, Friends has seen a 35% increase in donations over the past two years. But, we can’t stop there. We must continue to run campaigns and increase donations to remain competitive in the political arena and reach our overall goal of $215,000. Your donations will make a meaningful impact on health care legislation this session and for years to come. Thank you!
We are grateful for the hospitals who met their goals for 2022:
- Adams Memorial Hospital
- Baptist Health Floyd
- Beacon Health System
- Cameron Memorial Community Hospital
- Clark Memorial Hospital
- Columbus Regional Hospital
- Community Health Network
- Deaconess Health
- Goshen Health
- Greene County Memorial Hospital
- Hancock Regional Hospital
- Harsha Behavioral Center
- Hendricks Regional Health
- King’s Daughters’ Health
- Lutheran Health Network
- Northwest Health
- OrthoIndy Hospital
- Perry County Memorial Hospital
- Pulaski Memorial Hospital
- River Bend Hospital
- Rush Memorial Hospital
- Schneck Medical Center
- Scott Memorial Hospital
- St. Elizabeth Dearborn
- Terre Haute Regional Hospital
- Wellstone Regional Hospital
Reminder: Universal Lead Testing
As a reminder, beginning Jan. 1, 2023, House Enrolled Act (HEA) 1313 requires all health care providers serving children to offer lead testing to their patients in accordance with guidance from the Indiana Department of Health (IDOH). IDOH has issued the timetable below. If a provider does not have a record of historical blood lead testing and finds no records in the Indiana Children and Hoosiers Immunization Registry Program (CHIRP) indicating a prior blood lead test has been done, it should be assumed a child has not been tested.
- Children should receive a blood lead test between the ages of nine (9) and fifteen (15) months, or as close as reasonably possible to the patient's appointment.
- Children should have another blood lead test between the ages of twenty-one (21) and twenty-seven (27) months, or as close as reasonably possible to the patient's appointment.
- Any child between twenty-eight (28) and seventy-two (72) months that does not have a record of any prior blood lead test must be offered a blood lead test as soon as possible.
Any provider or lab that tests a child's blood for the presence of lead is required to report the results of the test to IDOH within one (1) week of receiving the result. Also effective Jan. 1, providers will have the ability to enter blood lead test results directly into CHIRP as a means for submitting results to IDOH.
Finally, please note, IDOH's guidance states that if a parent or guardian refuses to allow their child to be tested, providers are encouraged to document the refusal in writing and have the parent or guardian sign an attestation of refusal. Further details around this requirement and subsequent compliance can be found here and here.
2023 Fee Guidance for the IDR Process
On Dec. 23, CMS issued an amendment to the 2023 fee guidance for the independent dispute resolution (IDR) process under the federal No Surprises Act. The updated guidance amends the 2023 administrative fee that disputing parties must pay to participate in the IDR process from $50 per party to $350 per party for disputes initiated during the calendar year beginning January 1, 2023. No changes have been made to the 2023 certified IDR entity fee ranges for single or batched determinations.
Guidance on Disposition of Fetal Remains
With the injunction of Indiana's fetal disposition laws now lifted, the Indiana Department of Health has issued the following guidance letter as a reminder on compliance with Indiana laws concerning the disposition of aborted and miscarried fetal remains. All providers are encouraged to review the letter, and please contact IHA's Deputy General Counsel, Laura Brown, at Lbrown@ihaconnnect.org with any questions.
IHA Weekly News - Dec. 21, 2022
Managed Care Programs Will Follow the Same Utilization Management Hierarchy
Beginning April 1, 2023, Healthy Indiana Plan (HIP), Hoosier Care Connect, and Hoosier Healthwise will follow the same utilization management (UM) medical criteria hierarchy for all managed care programs. Managed care programs will retire all customized guidelines by April 1, 2023 and ensure that any authorization reviewed on or after April 1, 2023 will be reviewed with consideration to the outlined hierarchy.
Jan. 13: Hall Render Webinar on Web Tracking Technologies
Join Hall Render Killian Heath & Lyman, P.C. attorneys Mark Swearingen and Cory Brennan for a webinar discussing the use of web tracking technologies such as cookies, web beacons, tracking pixels, and fingerprinting scripts to track and collect information from hospital website users. Common tracking technologies include Meta (Facebook) Pixel, Google Analytics, Microsoft Clarity, Adobe Analytics, Salesforce, Hotjar, and SiteImprove.
- The discussion of web tracking technologies first came to light in June of 2022, through an investigative report published by The Markup, which reported that health care organizations across the country may have installed the Meta Pixel on their patient portal and other patient-facing websites and that the Pixel appeared to be transmitting PHI to Meta.
- Several entities have reported HIPAA breaches relating to their use of web tracking technologies, and there are numerous pending investigations by the HHS Office for Civil Rights (OCR), State Attorneys General, and Congress. Class action lawsuits are also regularly being filed against health care organizations that utilize web tracking technologies.
- On Dec. 1, 2022, OCR released a bulletin on the use of web tracking technologies by covered entities and business associates, which outlined concerns and provided guidance for ensuring HIPAA compliance when utilizing web tracking technologies.
- Hospitals utilizing web tracking technologies on any web pages should work with legal counsel to undertake a detailed forensic investigation to understand what those technologies are collecting and transmitting and to determine whether or not a HIPAA violation may have occurred.
Date & Time: Jan. 13, 10 – 11 a.m. ET
Content conveyed at, or in conjunction with, this event does not constitute the opinion or views of IHA.
Mark Swearingen - Attorney at Hall, Render, Killian, Heath & Lyman, P.C.
Mark Swearingen has practiced in the area of health information privacy and security for over 20 years, with particular focus on HIPAA compliance, data breach response, government investigations, HIPAA audits and 42 C.F.R. Part 2. Since the HIPAA Breach Notification Rule was issued in 2009, Mark has handled a substantial number of health care data breaches, including cases involving ransomware, email phishing, lost/stolen devices, insider threats and medical devices. He regularly guides clients through government investigations of privacy and security incidents and has successfully negotiated resolutions and settlements with both federal and state agencies. Mark also advises clients on issues relating to emerging technologies, such as telemedicine, medical apps and artificial intelligence.
View full bio.
Cory Brennan - Attorney at Hall, Render, Killian, Heath & Lyman, P.C.
Cory Brennan concentrates her practice on information and clinical systems security. Providing over a decade of experience in developing risk management strategies and implementing advanced technology solutions, Cory serves as a trusted partner to clients as they navigate their security needs. With extensive practical knowledge of health care information security and compliance standards, including HIPAA/HITECH, NIST and ISO, Cory advises clients on all aspects of security and risk management strategies, including conducting risk assessments, incident and breach response, business continuity planning and governance development. View full bio.
Jan 4: IHA Quality & Patient Safety Quarterly Update
Please join the Indiana Hospital Association's Quality & Patient Safety Team for a virtual all-member webinar on Jan. 4 at 3 p.m. ET as we kick-off 2023. IHA will host four quarterly webinars focused on quality and patient safety in 2023.
The team invites you to learn more about 2023 priorities and engage in discussion relevant to health care quality and patient safety. It's more important than ever for Indiana hospitals to remain connected and informed. We hope you will find these quarterly webinars to be of value.
Stop & Take a Break During the Holidays We recognize the holiday season can be a time of increased stress and chaos.
During this time, don’t forget to STOP:
- Step out of auto-pilot
- Take a mindful breath
- Observe what's happening
- Proceed with a greater sense of intention
Happy Holidays from IHA
We are thankful for our hospitals, healthcare centers, every one of our members, as well as our business partners. We thank you for taking care of Hoosier patients and our communities across the state. Happy Holidays from your friends at IHA! IHA Weekly News - Dec. 14, 2022
Regulatory Flexibilities Available for RSV, Flu
On Dec. 2, the Secretary of the U.S. Department of Health and Human Services issued a letter announcing the regulatory flexibilities still available to health care providers as a result of the federal COVID-19 public health emergency (PHE) can also be used to "help address many of the challenges brought on by the current confluence of COVID-19 with other respiratory and seasonal illnesses, including RSV and flu." These regulatory flexibilities remain available until the federal PHE expires or is otherwise rescinded, which is currently set to expire on Jan. 11, 2023.
Since the release of the letter, the Indiana Department of Health has outlined the following process for utilizing regulatory flexibilities that require a waiver of a state licensure rule. A waiver request for a state licensure rule should contain:
- The specific rule reference and citation.
- The reason for the waiver (i.e., an explanation / justification).
- A description of the substitution that will be used in place of the rule.
The waiver request must be on a formal letterhead and should be emailed to jhembree@health.in.gov. If you have any questions, please contact IHA's Vice President of Regulatory & Hospital Operations, Andy VanZee, at avanzee@ihaconnect.org, or IHA's Deputy General Counsel, Laura Brown, at lbrown@ihaconnect.org.
Important: Compliance with Online Data Tracking Technologies
The Office for Civil Rights at the U.S. Department of Health and Human Services issued a bulletin to highlight the obligations of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) on covered entities and business associates ("regulated entities") under the HIPAA Privacy, Security, and Breach Notification Rules ("HIPAA Rules") when using online data tracking technologies. These online data tracking technologies, like Google Analytics or Meta Pixel, collect and analyze information about how internet users are interacting with a regulated entity's website or mobile application.
Some regulated entities share electronic protected health information (ePHI) with online data tracking technology vendors, and the bulletin asserts some may be doing so in a manner that violates the HIPAA Rules.
The HIPAA Rules apply when the information that regulated entities collect through online data tracking technologies or disclose to online data tracking technology vendors includes ePHI. Regulated entities are not permitted to use tracking technologies in a manner that would result in impermissible disclosures of ePHI to online data tracking technology vendors or any other violations of the HIPAA Rules.
The bulletin explains what online data tracking technologies are, how they are used, and what steps regulated entities must take to protect ePHI when using online data tracking technologies to comply with the HIPAA Rules, including executing Business Associate Agreements. If you have any questions, please contact IHA's Deputy General Counsel, Laura Brown, at Lbrown@ihaconnect.org.
Indiana's Labor of Love infant mortality summit recently celebrated their 10th anniversary. This year's theme was "Year of the Mom," a nod to the importance that maternal health plays in ensuring healthy pregnancies and improving both maternal and mortality rates.
Brittany Waggoner, IHA Maternal & Infant Quality Improvement Advisor, IHA President Brian Tabor, and IHA Clinical Director Annette Handy presented the INspire Awards to Hospitals of Distinction.
IHA Weekly News - Dec. 7, 2022
CMS Issues Memo on Violence
A new memorandum from the Centers for Medicare & Medicaid Services focuses on the agency's role in enforcing regulatory expectations that patients and hospital staff have an environment that prioritizes their safety to ensure effective delivery of health care. The memo, from the directors of the Quality, Safety & Oversight and Survey & Operations groups, reminds hospitals of their responsibility, per Medicare's conditions of participation, to provide adequate training, sufficient staffing levels, and ongoing assessment of patients and residents for aggressive behavior and indicators, with an overarching expectation that care interventions and environments are appropriately adapted. CMS notes that in the past, it has cited hospitals for failure to meet these obligations.
GFE Co-Provider Requirement
On Dec. 2, the Centers for Medicare and Medicaid Services published
the following FAQ to extend the current enforcement discretion for non-compliance with the No Surprises Act requirement that Good Faith Estimates for uninsured or self-pay patients include expected charges from co-providers or co-facilities until future rulemaking is issued. The FAQ notes that “any rulemaking...will include a prospective applicability date that gives providers and facilities a reasonable amount of time to comply with any new requirements."
Online Tracking Technologies Bulletin
On Dec. 1, the Office for Civil Rights at the U.S. Department of Health and Human Services issued a bulletin to highlight the obligations of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) on covered entities and business associates (“regulated entities") under the HIPAA Privacy, Security, and Breach Notification Rules (“HIPAA Rules") when using online tracking technologies. These online tracking technologies, like Google Analytics or Meta Pixel, collect and analyze information about how internet users are interacting with a regulated entity's website or mobile application.
The HIPAA Rules apply when the information that regulated entities collect through tracking technologies or disclose to tracking technology vendors includes electronic protected health information (ePHI). Regulated entities are not permitted to use tracking technologies in a manner that would result in impermissible disclosures of ePHI to tracking technology vendors or any other violations of the HIPAA Rules.
The bulletin explains what tracking technologies are, how they are used, and what steps regulated entities must take to protect ePHI when using tracking technologies to comply with the HIPAA Rules, including executing Business Associate Agreements. If you have any questions, please contact IHA's Deputy General Counsel, Laura Brown, at Lbrown@ihaconnect.org.
Save the Date: Public Health Day - Investing in Hoosier Lives
Join the Indiana Department of Health for Public Health Day. Show your support for public health in Indiana by wearing blue and gold.
Thursday, Jan. 26 | 11 a.m. - 1 p.m.
Indiana Statehouse - North Atrium
Featuring Gov. Eric J. Holcomb
IHA Weekly News - Nov. 30, 2022
HHS Launches Website to Address Surge in Pediatric Viral Respiratory Illness
As the surge of pediatric viral respiratory illness continues to impact hospitals nationwide, HHS has launched a
website to highlight resources developed to help address the response. The site includes a resource library, assistance center, and an information exchange discussion board to allow for near-real time engagement among users. We encourage you to engage and share these materials with your team.
Set Your Employees Up for Success in 2023
The Indiana Hospital Association in partnership with more than 40 state hospital associations offers
careLearning, an online education company designed for health care organizations by health care organizations.
careLearning helps Hoosier hospitals by providing reliable, trusted, and easily accessible talent management solutions. Their competency, eLearning, and performance products are developed to ensure that your employees are provided with the appropriate training based on an assessment of the skills, knowledge, and abilities required.
Training and Education for Health Care Professionals
- Regulatory Training
- Customized Courses
- Learning Management System (LMS)
- Continuing Education
- Live Event Management
- Clinical Student Orientation
Users can create an unlimited number of facility-specific courses, manage instructor-led meetings, and automatically track and run reports with a few quick clicks in the system.
Interested in Learning More?
The Indiana Hospital Association invites your health care facility to learn more about the education management solution on Thurs., Dec. 1 at 11 a.m. ET as careLearning hosts a 60-minute informational webinar.
Who Should Attend?
Anyone who has a vested interest in providing education to employees. This might include: Staff Educators, Human Resources, Nursing Executives/Managers, & Compliance Officers.
To Register
Fairbanks School of Public Health Accepting Applications for MHA Degree
Continue building your health care career with a Master of Health Administration (MHA) degree from the Fairbanks School of Public Health. Their program was the first MHA program in Indiana, so it is a well-developed program with a rich alumni association. This degree will prepare you for greater organizational responsibilities and leadership roles.
The Richard M. Fairbanks School of Public Health MHA Program is taking applications for both the Executive MHA and Traditional MHA Programs.
Hospital Leaders Gather at Statehouse for Organization Day
IHA members from across the state gathered at the Indiana Statehouse last week to observe Organization Day and meet with legislators. On Organization Day, the legislature reconvenes to swear in new legislators, and legislative leadership discusses essential goals for the upcoming session.
IHA members met with individual legislators to share hospital accomplishments and policy priorities, had lunch discussions with legislators across the state on various healthcare issues, and viewed the session. In addition, IHA Board Chair Brad Smith, Public Health Committee Chair Dr. Brad Barrett, and IHA President Brian Tabor spoke to the group, sharing information about IHA and the legislative process for health policy.
The proactive nature of this gathering allowed hospital leaders to connect with legislators and advocate for their hospitals in advance of any legislative challenges that may arise in the 2023 session. IHA is grateful to the members who could attend the event last week and to all of our members who continue to advocate for their hospitals in the local community. There is no substitute for face-to-face conversations, and your representation of Indiana hospitals will continue to produce benefits in the coming months.
If you would like assistance connecting with your local legislators to share about your hospital’s impact on your community, please reach out to IHA’s Government Relations Team.
4C Health Expanding Psychiatric Hospital & Crisis Services
Adolescent psychiatric inpatient beds, expansion of crisis stabilization services, and psychiatric urgent care will enhance North Central Indiana’s rural behavioral health access. The new facility will encompass more than 20,000 square feet and allow 4C Health to expand current crisis services, along with integrated care where behavioral health and primary care work together. Remodel began in the Summer of 2022 and full opening of all services is anticipated in the Fall of 2023.
IHA Weekly News - Nov. 16, 2022
Congratulations to the 2022 Annual Award winners, who recently accepted their awards at our Annual Awards Luncheon. We were honored to be able to recognize these individuals in-person, and we thank our members for joining us in this celebration.
See below for a full list of the awards that were presented at our Annual Meeting.
IHA Annual Awards
- Distinguished Service Award: Brian Shockney, HFA, FACHE - IU Health South Central Region
- Award of Merit: Kristina Box, M.D., FACOG - State Health Commissioner
- Caregiver of the Year Award: Matthew Tucker, DO - Deaconess Health System
- Administrative Professional Excellence Award: Debra Swain - Good Samaritan Hospital
- Stella Scholarship: Elizabeth Quinn - IUPUI Fairbanks School of Public Health
PAC Awards
- Most Improved Effort: Greene County General Hospital
- Highest Percentage of Goal: Schneck Medical Center
- Highest Donor: Ascension St. Vincent
ACHE Winners
- Early Careerist Award: George Zhang, Administrator, Ascension St Vincent Dunn and Clay
- Senior Executive Award: Stephanie J. Long, FACHE, CEO, North Central Health Services
100-Year American Hospital Association Membership Milestone Award
- Ascension St. Vincent Anderson - Anderson, IN
- Indiana University Health Ball Memorial Hospital - Muncie, IN
- Terre Haute Regional Hospital - Terre Haute, IN
- Union Hospital - Terre Haute, IN
- IU Health Morgan - Martinsville, IN
Updated Quality Measures Table Reflects Final Outpatient, ASC and ESRD Rules
The Centers for Medicare & Medicaid Services (CMS) issued final rules this month for their Prospective Payment Systems that affect the quality measure reporting requirements for hospital outpatient departments and ambulatory surgery centers for calendar year 2023, and for End-Stage Renal Disease facilities for payment year 2023. IHA has updated the quality measures table to reflect these changes. For questions regarding the quality measures table, please contact Elaine Pittman at 317-423-7735 or epittman@IHAconnect.org.
IHA Weekly News - Nov. 9, 2022
CMS Issues Revised Survey Guidance for COVID-19 Vaccination Requirement
On Oct. 26, CMS issued QSO 23-02 providing revised survey guidance for compliance with CMS's COVID-19 vaccination rule for health care workers.
QSO 23-02 is applicable to all states, and highlights of the new QSO are as follows:
- Threshold for Compliance: A previous QSO allowed for certain thresholds for compliance, but the new QSO states, “CMS expects all providers' and suppliers' staff to have received the appropriate number of doses of the primary vaccine series unless exempted as required by law, or delayed as recommended by CDC. Facility staff vaccination rates under 100% constitute noncompliance under the rule."
- Noncompliance: However, the QSO goes on to state, “Noncompliance does not necessarily lead to termination, and facilities will generally be given opportunities to return to compliance. For example, a facility that is noncompliant and has implemented a plan to achieve compliance would not be subject to an enforcement action."
- Surveys: State agencies and accrediting organizations will only be expected to perform compliance reviews of the vaccination rule as part of initial certification, standard recertification or reaccreditation surveys, and in response to specific complaint allegations related to the vaccination requirement. Surveyors may modify their vaccination compliance review if the provider was determined to be in substantial compliance within the previous six (6) weeks.
- Hospital Specific Guidance: On Page 36 of the PDF, specific guidance for hospital surveys is included, which outlines the process for surveyors to undertake when determining compliance.
- Infection Prevention & Control Practices: The hospital specific guidance also includes the following note: “Regardless of a facility's compliance with the staff vaccination requirements, surveyors should closely investigate infection prevention and control practices to ensure proper practices are in use, such as proper use of personal protective equipment, transmission precautions which reflect current standards of practice, and/or other relevant infection prevention and control practices that are designed to minimize transmission of COVID-19."
Thanks for Attending IHA's 2022 Annual MeetingOur Annual Meeting took place last week in downtown Indianapolis. Thank you to our members who joined us as we honored 100 years of advancing health care together. Attendees heard a livey political banter session from Donna Brazile and Micheal Steele, pictured. We will be sharing the full photo gallery once it's available. Watch for announcements on the 2023 meeting!
IHA Weekly News - Oct. 26, 2022
Important: Updated No Surprises Act Toolkit & Forms
On August 26, 2022, the federal Departments of Health and Human Services (“HHS"), Labor, and the Treasury (“Departments") published their first final rule implementing certain requirements of the federal No Surprises Act (“Final Rule"). This Final Rule is narrow in scope and responds to stakeholder comments related to the federal independent dispute resolution process and the need for health plans to provide greater transparency into how the qualifying payment amount (“QPA") is determined.
Angela Smith and Matt Reed with Hall Render have updated the IHA Toolkit for Compliance with Surprise Billing Laws accordingly.
Importantly, Attachment A (Model Disclosure Notice Regarding Patient Protections Against Surprise Billing) and Attachment B (Standard Notice and Consent to Balance Bill) of the Toolkit have also been updated per a recently released set of FAQs.
Although providers and facilities are not required to use the Model Disclosure Notice (Attachment A), so long as the notice they provide to patients complies with the requirements under the No Surprises Act, HHS will consider providers' and facilities' use of the updated model disclosure notice to be good faith compliance with the No Surprises Act's disclosure requirements beginning on or after January 1, 2023. However, the revised Standard Notice and Consent to Balance Bill (Attachment B) must be used starting January 1, 2023.
IHA Toolkit for Compliance with Surprise Billing Laws_October 2022.pdf
Attachment A_Indiana Model Disclosure_October 2022.docx
Attachment B_Standard Notice and Consent to Balance Bill_October 2022.docx
2022 American Hospital Association Grassroots Champions Award
On October 21, IHA President Brian Tabor presented Beacon Health System board member Tom Cassady Jr. with the 2022 American Hospital Association Grassroots Champions Award for Indiana. Cassady serves as a member of the AHA’s Committee on Governance and is also a member of the IHA’s Board of Directors where he represents the perspective of hospital trustees across the state. He has also served in multiple governance roles with Beacon, including chair of the Memorial Hospital Foundation.
The award was created by the AHA to recognize individuals who communicate hospitals’ vital role in their communities and are exceptional proponents of sound health policy. “Tom is a tireless advocate with an incredible statewide network, and we are fortunate to have him in IHA leadership," said Tabor. “He’s helped us not only with our outreach to state and federal lawmakers, but he’s also shaped our strategy when it comes to embracing transparency and engaging directly with employers on bending the cost curve.”
Hall Render Webinar, Nov. 3 - Provider Relief Fund Federal Audits are Here: What to Expect and How to Prepare
The Health Resources and Services Administration (HRSA) has distributed nearly $170 billion in Provider Relief Fund (PRF) payments to eligible health care providers since April 2020. With the PRF largely expended, the federal government has now started PRF recipient audits.
The scope of each audit can broadly cover compliance with the applicable Terms and Conditions attached to the receipt of PRF payments, how an entity used PRF funds to reimburse eligible expenses and lost revenue or specific PRF compliance requirements such as the restriction against balance billing out-of-network patients for COVID-19 treatment. The audits can be conducted by HRSA via non-government contractors, the Office of Inspector General or other government agencies, and are in addition to the Single Audit requirement many recipients are subject to. Regardless of the scope of the audit or which government agency oversees the work, providers should prepare for potential government audits now. Every PRF recipient is required to comply with the relevant reporting obligations and other PRF requirements and restrictions, and non-compliance can result in the recoupment of some or all the applicable PRF payments.
Join Hall Render attorney
Ben Fee for this 30-minute webinar. He will discuss the various government audits underway, what providers can do now in advance of a potential audit and recommendations and strategies for navigating the audit process.
IHA Weekly News - Oct. 19, 2022
AHA Launches Annual United Against the Flu Campaign
The American Hospital Association is continuing its annual work to help hospitals and health systems encourage their communities to stay healthy and protect themselves against the flu and COVID-19 through vaccination. For the eighth year in a row, AHA’s United Against the Flu campaign is guiding the field’s efforts to raise awareness in local communities with engaging content, information, and resources that hospitals and health systems can customize and deploy throughout the communities they serve.
Visit AHA’s redesigned webpage, which also includes information on partnership opportunities, graphics for use on the web and social media, and augmented reality filters, along with other helpful resources, such as the Centers for Disease Control and Prevention’s flu shot finder tool and promotional messaging.
IHA Weekly News - Oct. 12, 2022
Applications Open for Second Round of Health Issues & Challenges Grant Program
On Oct. 7, the Indiana Department of Health announced $7.5 million in grants will be available as part of a second round of funding through the Indiana Health Issues and Challenges Grant program, which was established by the Indiana General Assembly and supported by IHA in 2021 with funding from the American Rescue Plan Act.
Entities are eligible to apply for funding for programs to help improve health outcomes related to one or more of the following priority areas: tobacco cessation, food insecurity/obesity, lead exposure, chronic disease and public health prevention programs, including community paramedicine and community health workers. Priority will be given to organizations that can demonstrate a high need and high impact in their grant proposals.
Applications must be submitted by Nov. 18, and application and grant guidance can be found
here. Award notifications are expected in early 2023.
More than $35 million was previously awarded through the first round of funding in June for programs addressing issues such as asthma, cancer prevention, heart disease, diabetes, lead prevention, food insecurity and obesity, community health workers and community paramedicine. The list of previous recipients can be found
here. All funds must be spent by Dec. 31, 2026.
IHA Weekly News - Oct. 5, 2022
IHA Advertorial Highlights Continued Financial Challenges for Hospitals
A recent survey of Indiana hospitals highlights the significant increase in costs hospitals must bear – an unprecedented workforce crisis, skyrocketing costs of drugs, labor, and equipment, and lingering supply shortages that strain resources and threaten access to care. Meanwhile, inflation has exacerbated these increases, resulting in widespread financial losses. These financial impacts are hitting just as hospitals are rebuilding from the highest inpatient levels in our state’s history, and they are compounded by looming reductions in government payment programs that will be especially difficult for our safety net and rural facilities to sustain.
In a recent advertorial in the Indianapolis Business Journal, IHA President Brian Tabor highlights these challenges and more.
View the full article.pdf
Senators Manchin & Braun Urge HHS to Crack Down on Pharmaceutical Company Violations
U.S. Senators Joe Manchin and Mike Braun urged U.S. Department of Health and Human Services (HHS) Secretary Xavier Becerra to crack down on the actions of numerous pharmaceutical companies who continue to violate the 340B Drug Pricing Program that helps provide medicines to low-income West Virginians and Hoosiers. There are 37 hospitals in the state of West Virginia and 58 hospitals in the state of Indiana that participate and rely on the 340B Program.
"Our members are grateful to Senator Braun and Senator Manchin for leading in support of health care providers in Indiana and West Virginia, as well as those across the country on this urgent issue. The 340B drug pricing program is critical for hospitals and other entities that serve low-income patients. Given the current financial difficulties that our members are facing, further erosion of the 340B program threatens access to care in communities across Indiana," said Brian Tabor, President of the Indiana Hospital Association.
Read the full press release.
AHA Coding Case Study & Webinar
Cameron Memorial Community Hospital, an independent critical access hospital in northeastern Indiana, shares how it embraced the use of ICD-10-CM Z codes to detect and address patients’ social needs as part of the hospital’s health equity strategy.
View AHA's case study.
Want to understand the who-what-when-where-and-why of Z codes? Join AHA’s Coding Clinic experts, including IHA's Quality & Patient Safety Advisor Madeline Wilson, on Oct. 18 at 1 p.m. ET for a discussion of “Z codes,” the ICD-10-CM categories for social determinants of health and social needs. Experts will cover official coding guidelines affecting these codes and their application, along with Z codes’ importance for promoting health and equity.
Learn more and register here.
IHA Weekly News - Sept. 28, 2022
CDC Updates COVID-19 Infection Control Guidance for Health Care Settings
Last Friday, the Centers for Disease Control and Prevention updated its COVID-19 infection control guidance for U.S. health care settings based on current information. The guidance updates the circumstances when source control (respirator and face mask use) and universal personal protective equipment are recommended, and no longer uses vaccination status to inform source control, screening testing, or post-exposure recommendations. It also updates recommendations for testing frequency, and clarifies that facilities may use their discretion regarding screening testing for asymptomatic health care personnel, among other changes. To allow for earlier intervention to prevent a strain on the health care system, the guidance recommends health care facilities use data on COVID-19 community transmission rather than COVID-19 community levels to guide certain practices.
AHA has released a special bulletin describing key changes in the guidance. While the latest CDC guidance provides some flexibility on how hospitals manage their COVID response, hospitals should evaluate the potential impact for all areas of the facility and other infectious diseases within the community.
IHA will be convening our Council on Quality & Patient Safety to explore best practices for infection control given this new guidance. Comments and Questions can be referred to Karin Kennedy (kkennedy@ihaconnect.org), IHA VP of Quality & Patient Safety or Andy VanZee (avanzee@ihaconnect.org), IHA VP of Regulatory & Hospital Operations.
Donors Needed at The Susan G. Komen Tissue Bank
The Susan G. Komen Tissue Bank at the IU Simon Cancer Center was created in response to a need by scientists carrying out breast cancer research: understanding wh at is abnormal in
breast cancer is slowed down by our lack of knowledge about wh at is normal. By collecting tissue from women with and without breast cancer, or with a variety of benign breast conditions, scientists will be able to determine differences which ultimately could lead to a better understanding of the breast cancer process.
Tissue Donation Information:
Date and Time: Saturday, Nov. 12, 8 a.m. - 2 p.m.
Location: IU Health Simon Cancer Center, 2nd floor Women's Clinic,
1030 W Michigan St, Indianapolis, IN 46202
IHA Weekly News - Sept. 21, 2022
Patient Safety Summit
Thank you to all those who attended yesterday’s IHA Patient Safety Summit!
President Brian Tabor spoke to attendees and expressed gratitude for their tireless efforts to keep patients out of harm’s way. Other topics for the day included innovation, high reliability leadership, and reducing the threat of violence to staff and patients.
The Summit also hosted an insightful member panel highlighting crucial pivots that were made to ensure patient safety during their facilities’ recent cyberattacks. A special thank you to Hendricks Regional Health, Johnson Memorial Health, and Norton King's Daughters' Health for sharing your experiences.
IHA Weekly News - Sept. 14, 2022
IDOH: Updated Terminated Pregnancy Report Submission Guidance
"Treatment of a missed miscarriage, septic abortion, inevitable miscarriage, ectopic pregnancy, molar pregnancy, or any pregnancy where the fetus has died in utero continue to not be required to be submitted as a terminated pregnancy report."
We encourage you to review the guidance with your team and legal counsel as you update any policies and procedures ahead of the effective date of Senate Enrolled Act (SEA) 1 on Sept. 15. To date, no action has been taken by either the Monroe County Circuit Court or the Marion County Superior Court on the lawsuits filed challenging SEA 1. As such, hospitals and ambulatory outpatient surgical centers should continue to work towards ensuring compliance with SEA 1 starting Sept. 15.
While IHA cannot provide legal advice, please do not hesitate to contact a member of our team with any questions.
IHA Weekly News - Sept. 7, 2022
Versiti Blood Center of Indiana Needs Donors
Versiti would like to remind Hoosiers of the need in our community to donate blood, especially around holiday weekends.
IHA Weekly News - Aug. 31, 2022
BBW 2022: 10 Years, A New Foundation
This year marks the 10th anniversary of Black Breastfeeding Week. Join in celebrating the countless stories and families - past, present & future. The new foundation of lactation support is built on racial equity, cultural empowerment, and community engagement and is powered by our collective resilience.
SEA 1 Q&A and Abortion Certification Form
In addition to the Senate Enrolled Act (“SEA") 1 memorandum distributed on Aug. 10 detailing Indiana's updated abortion framework, IHA has compiled a SEA 1 Q&A document, as well as a sample Abortion Certification Form.
Please note, these documents do not constitute legal advice. If you have any questions, please contact IHA's Deputy General Counsel, Laura Brown, at Lbrown@ihaconnect.org.
Submit a Hardship Exception Application by Sept. 1
On May 1, the Centers for Medicare & Medicaid Services (CMS) opened the Hardship Exception Application period for eligible hospitals and critical access hospitals (CAHs) that participated in the Medicare Promoting Interoperability Program in Calendar Year (CY) 2021. The Hardship Exception Application period closes Sept. 1, 2022.
About Hardship Exception
CMS mandates that downward payment adjustments be applied to eligible hospitals and CAHs that were not meaningful users of certified electronic health record technology (CEHRT) and scored below the 50-point minimum requirement and failed to report two self-selected calendar quarters of electronic clinical quality measures (eCQMs) data on four self-selected eCQMs. Participants may be exempt from Medicare penalties and avoid a downward payment adjustment if they can show that compliance with the requirement for being a meaningful CEHRT user would result in a significant hardship.
To be considered for an exemption, participants must complete a hardship exception application and provide proof of hardship (e.g., natural disaster, lack of internet access, etc.). If approved, the hardship exception is valid for only one payment adjustment year. Eligible hospitals and CAHs would need to submit a new application for subsequent years and no eligible hospital or CAH can be granted more than five exceptions.
Hardship Exception Application Details
- The deadline for eligible hospitals and CAHs to submit a hardship exception application for the CY 2021 reporting period is this Thursday, Sept. 1, 2022.
- More information on the Medicare Hardship Exception Application can be found here (PDF).
- Previously registered users should already have account access, and new users can sign up by visiting QualityNet and selecting “Register" to create a new account.
- If an electronic submission is not possible, you may verbally submit your application over the phone by calling the Center for Clinical Standards and Quality (CCSQ) Service Center at (866) 288-8912.
For more information, visit the Promoting Interoperability Program website or contact Matt Browning, IHA Vice President Data Services & Member Solutions.
IHA Weekly News - Aug. 24, 2022
IHEN Annual Awards Program
Indiana Healthcare Executives Network (IHEN, the local chapter of the American College of Healthcare Executives) will host their Annual Awards program, Inclusive Leadership: Leveraging Diversity as a Strength, with Stephan Davis, DNP, MHSA, FACHE, FNAP on Sept. 15 at the Golf Club of Indianapolis. The format of the evening includes 3 Face to Face education credits, networking, an awards presentation, and a plated dinner.
Quality Measures Table Includes Changes Finalized and Proposed in CMS PPS Rules
The Centers for Medicare & Medicaid Services (CMS) issued final rules in August that affect acute care hospitals, inpatient rehabilitation facilities, inpatient psychiatric facilities, long-term care hospitals, and PPS-exempt cancer hospitals. They also issued proposed rules that affect outpatient services in acute care hospitals, ambulatory surgery centers and ESRD facilities. IHA has updated the quality measures table to reflect the changes to quality measurement reporting requirements announced in the rules.
IHA Weekly News - Aug. 17, 2022
Updated Out-of-State Telehealth Certification Forms
The Indiana Professional Licensing Agency (IPLA) has updated its Out-of-State Telehealth Certification Forms for practitioners, employers, and contractors as a result of Senate Enrolled Act (SEA) 284 from the 2022 legislative session. The updated form for practitioners can be found here, and the updated form for employers and contractors can be found here. The updated forms are also available on the Indiana Archives and Records Administration's State Forms Catalog webpage, and IPLA intends to add the updated forms to IPLA's telehealth webpage as well.
As a result of SEA 284, several additional practitioners are now included on the forms, including behavior analysts; students who are pursuing a course of study in or who are a graduate from a health care profession that is permitted to practice telehealth in Indiana; qualified behavioral health professionals within a community mental health center; and more. If you have any questions, please contact IHA's Deputy General Counsel, Laura Brown, at Lbrown@ihaconnect.org.
2022 Perinatal Substance Use Virtual Conference
The Indiana Perinatal Quality Improvement Collaborative and IHA will be presenting the 2022 Perinatal Substance Use Virtual Conference on Aug. 31 from 10 a.m. – 1 p.m. EST. View the flyer.
Speakers:
Implementation of a Standardized Clinical Definition of Opioid Withdrawal in the Neonate
Dr. Shahla M Jilani
Office of the Assistant Secretary for Health
US Department of Health and Human Services
Mandated Reporting of Perinatal Substance Use: the Root of Inequity
Dr. Caitlin Bernard
Assistant Professor of Clinical Obstetrics & Gynecology
Indiana University School of Medicine
Dr. Brownsyne Tucker Edmonds
Vice President and Chief Health Equity Officer at Indiana University Health
Associate Professor of Obstetrics & Gynecology and Pediatrics at Indiana University School of Medicine
Engaging Community Stakeholders into Family Care Plans
Kathy Detweiler, MHL, BSN, RN
Director, Perinatal Center and Nurse Navigation Women's & Children's Services
Parkview Regional Medical Center
IHA Weekly News - Aug. 10, 2022
Indiana's Updated Abortion Framework
Late in the evening of August 5, 2022, Governor Holcomb signed Senate Enrolled Act (“SEA") 1 into law, which updates Indiana's abortion framework in light of the U.S. Supreme Court's Dobbs v. Jackson Women's Health Organization opinion. The provisions of SEA 1 are effective Sept. 15, 2022. Highlights of the new law can be found here.
Final Report Released: Governor's Public Health Commission
The Governor's Public Health Commission report is now available and includes recommendations for improvements in six workstreams: funding; workforce; governance and infrastructure; data and analytics; emergency preparedness; and childhood and adolescent health. Those recommendations will form the basis of proposed legislation for the 2023 legislative session.
Indiana Hospital Association applauds the Governor’s public health commission recommendations in a statement from IHA President Brian Tabor:
"Indiana’s hospitals are truly grateful for Governor Holcomb’s leadership and commitment to improving Hoosiers’ health. The Commission’s in-depth review of Indiana’s public health system provides an opportunity to address a decades-old problem—we can no longer tolerate being 45th in the nation in terms of per capita funding. IHA looks forward to partnering with policymakers to reinvigorate our health care workforce and create a healthier Indiana."
Aug. 25 Webinar: Preparing for the End of the Public Health Emergency
The COVID-19 Public Health Emergency (PHE) has been in effect for so long now that our “new” processes have become our standards. Which leaves many wondering, what happens after the PHE expires?
Join IHA and H4 Technology for a virtual presentation with guidance on:
- How to take inventory of your office’s current PHE guidelines
- Reviewing changing regulations against current practice policies and procedures
- Parity training guidance for staff hired before, during, and after the PHE expires
-
New telehealth guidelines that may change once the PHE is expired
Get prepared in advance by attending this webinar on Aug. 25 at noon CT / 1 p.m. ET, free to all IHA members.
Register here.
Content conveyed at, or in conjunction with, this event does not constitute the opinion or views of IHA.
IHA Weekly News - Aug. 3, 2022
Individual Facility COVID-19 Waivers
While the Indiana Department of Health's (IDOH) COVID-19 Regulatory Blanket Waivs expired on July 1, hospitals and ambulatory surgical centers may now request individual waivers to continue temporary changes to physical plant requirements, such as temporary negative pressure isolation rooms. More information regarding individual waiver requests can be found here, and any requests should be submitted to Jennifer Hembree at Jhembree@isdh.in.gov.
If a hospital or ambulatory surgical center intends to make a physical plant change permanent, the facility must submit a plan review application, and the plans must be received by IDOH Health Care Engineering within 60 days of the application being submitted. Facilities do not need to submit a request for a temporary waiver if the plan review application has been submitted and may continue to operate until the plan review process is finalized.
Please note, while IDOH's COVID-19 Regulatory Blanket Waivers have expired, unless IDOH issues an individual waiver, the federal Centers for Medicare and Medicaid Services' (CMS) 1135 Waiver is still currently in effect as a result of the federal public health emergency. CMS's 1135 Waiver can be found in full here.
IPLA to Implement Licensure by Reciprocity in Tranches
As a result of Senate Enrolled Act 5, an IHA priority bill enacted during the 2022 legislative session, which creates reciprocity for health care professionals licensed in other states, the Indiana Professional Licensing Agency (IPLA) recently announced the agency will implement licensure by reciprocity in tranches through the end of the year.
Licensure by reciprocity is now available to applicants for medical (physicians and osteopathic physicians) licenses and physician assistant licenses. IPLA expects to implement licensure by reciprocity for pharmacists, physical therapists, occupational therapists, and other health care professionals by Oct, 17, 2022, and for nurses dentists, and other health care professionals by Dec. 12, 2022.
The application instructions for physicians and physician assistants applying for licensure by reciprocity are now available on the Medical Licensing Board's webpage, as follows:
Licensure by Reciprocity: The Medical Licensing Board shall issue a license to an applicant if the applicant satisfies the following conditions:
- Holds a current license from another state or jurisdiction; and
- that state's or jurisdiction's requirements for a license are substantially equivalent to or exceed the requirements for a license of the Board; or
- when the person was licensed or certified by another state:
- there were minimum education requirements in the other state or jurisdiction;
- if there were applicable work experience and clinical supervision requirements in effect, the person met those requirements to be licensed in that state; and
- if required by the other state or jurisdiction, the person previously passed an examination required for the license or certification.
- Has not committed any act in any state or jurisdiction that would have constituted grounds for refusal, suspension, or revocation of a license, certificate, registration, or permit to practice that occupation in Indiana at the time the act was committed.
- Does not have a complaint or an investigation pending before the regulating agency in another state or jurisdiction that relates to unprofessional conduct.
- Is in good standing and has not been disciplined by the agency that has authority to issue the license or certification.
- If a law regulating the applicant's occupation requires the board to administer an examination on the relevant laws of Indiana, the Board may require the applicant to take and pass an examination specific to the laws of Indiana.
- Pays any fees required by the Board for which the applicant is seeking licensure.
Provisional Licenses: An applicant for a license by reciprocity is entitled to a provisional license, if all the following conditions are met:
- The individual signs an attestation, under the penalties for perjury, the following:
- The individual is in good standing in all states and jurisdictions in which the individual holds a license or certificate for the occupation applied for.
- The individual has not had a license revoked and has not voluntarily surrendered a license in another state or jurisdiction while under investigation for unprofessional conduct.
- The individual has not had discipline imposed by the regulating agency for the occupation in another state or jurisdiction.
- The individual does not have a complaint or an investigation pending before the regulating agency in another state or jurisdiction that relates to unprofessional conduct.
- The individual does not have a disqualifying criminal history.
- The individual submits verification that the individual is currently licensed or certified in at least one (1) other state or jurisdiction in the occupation applied for.
- The individual has submitted an application for a license or certificate under this chapter with the board and has paid any application fee.
The provisional license shall be issued not more than 30 days after the requirements for a provisional license are met and is valid until the earlier of the following:
- Three hundred sixty-five (365) days after it is issued.
- The date on which the board approves and issues the individual a full license for the occupation.
- The date on which the board denies the individual's application for a full license for the occupation.
IHA is still working with IPLA to understand if the provisional license number and full license number can be issued to match and will keep members updated. If you have any questions, please contact IHA's Vice President of Regulatory & Operations, Andy VanZee, at avanzee@ihaconnect.org or IHA's Deputy General Counsel, Laura Brown, at lbrown@ihaconnect.org.
Terminated Pregnancy Report Submission Guidance
With the recent launch of the fetal death and terminated pregnancy modules of the state's new Database for Registering Indiana's Vital Events, the Indiana Department of Health (IDOH) would like to remind providers of the statutory requirements for reporting terminated pregnancies. Providers are encouraged to review IDOH's Terminated Pregnancy Report Submission Guidance here.
IDOH Guidance for Implementation of Newly Enforceable Informed Consent Requirements
On Aug. 1, the Indiana Department of Health (IDOH) updated its guidance regarding newly enforceable informed consent requirements for patients seeking abortions. The updated guidance can be found here and is a result of the Seventh Circuit U.S. Court of Appeals lifting an injunction that had previously stayed the enforcement of an additional provision of Indiana's informed consent disclosure laws.
Effective immediately, as a part of the informed consent process, providers are required to disclose that Indiana does not permit an abortion based on race, color, national origin, ancestry, sex, or diagnosis or potential diagnosis of Down syndrome or any other disability. Additional informed consent requirements are outlined in the guidance document.
IDOH is in the process of updating all appropriate state forms and documents, but until those updates are completed, providers should continue to document informed consent and disclosure in the patient's medical record to verify compliance with state laws.
IHA Weekly News - July 27, 2022
IDOH Monkeypox Update
The Indiana Department of Health (IDOH) is tracking a global outbreak of monkeypox, a rare disease caused by infection with the monkeypox virus. As a key component of the outbreak response, IDOH has created a website to provide comprehensive information about monkeypox to the public and clinicians. Please visit
monkeypox.health.in.gov for the most recent up
dates.
The website includes frequently asked questions as well as information and guidance on testing, vaccine, treatment and more. In addition, a clinical guide to monkeypox in Indiana and a quick reference for ordering the JYNNEOS vaccine are attached and can also be found on the website. Please continue to check the website for new information.
CDC COCA Call: Monkeypox Outbreak: Updates on the Epidemiology, Testing, Treatment, and Vaccination
The Clinician Outreach and Communication Activity (COCA) had a call on July 26 that provided updates on the epidemiology of the monkeypox outbreak, commercial testing capability, how to obtain and use TPOXX (Tecovirimat) to treat monkeypox, and vaccine strategy.
IHA Weekly News - July 20, 2022
HHS Renews Federal PHE – Emergency Practitioner Temporary Licenses & 1135 Waiver Also Extended
On July 15, the U.S. Department of Health and Human Services renewed the federal public health emergency for another 90 day period, through Oct. 13.
Health care practitioners who hold an emergency practitioner temporary license in Indiana under Indiana Code § 25-1-5.7 may continue to practice under their temporary license for the duration of the extension, and the Indiana Professional Licensing Agency's system will now reflect an expiration date of Oct. 13 for these temporary licenses. However, we continue to encourage those practicing under an emergency practitioner temporary license to begin moving toward full licensure.
Further, the COVID-19 Emergency Declaration Blanket Waivers for health care providers under the Centers for Medicare & Medicaid Service's current 1135 Waiver are also extended for the duration of the extension. If any portions of the 1135 Waiver are repealed prior to Oct. 13, IHA will keep you updated.
If you have any questions, please contact IHA's Vice President of Regulatory & Operations, Andy VanZee, at avanzee@ihaconnect.org or IHA's Deputy General Counsel, Laura Brown, at lbrown@ihaconnect.org.
IDOH Guidance for Implementation of Newly Enforceable Informed Consent Requirements
On July 19, the Indiana Department of Health (IDOH) issued guidance for the implementation of newly enforceable informed consent requirements for patients seeking abortions. The guidance can be found
here and is a result of the Seventh Circuit U.S. Court of Appeals lifting an injunction that had previously stayed the enforcement of certain informed consent disclosure laws.
Effective immediately, providers are required to disclose additional information to patients seeking an abortion as part of the informed consent process, as outlined in the guidance, and disseminate the Perinatal Hospice Brochure for patients diagnosed with a lethal fetal anomaly. The Perinatal Hospice Brochure can be found
here.
IDOH is in the process of updating all appropriate state forms and documents, but until those updates are completed, providers should continue to document informed consent and disclosure in the patient’s medical record to verify compliance with state laws.
IHA Weekly News - July 13, 2022
CMS Issues Guidance Reinforcing EMTALA Obligations
On July 11, CMS issued
QSO 22-22 reinforcing EMTALA obligations specific to patients who are pregnant or are experiencing pregnancy loss. Highlights of the QSO can be found below, and we encourage members to review the memorandum in its entirety.
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EMTALA: The EMTALA statute requires that all patients receive an appropriate medical screening examination, stabilizing treatment, and transfer to another hospital, if necessary, that has the capabilities to provide stabilizing treatment.
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Emergency Medical Conditions: The QSO states an emergency medical condition includes medical conditions with acute symptoms of sufficient severity that, in the absence of immediate medical attention, could place the health of a person (including pregnant patients) in serious jeopardy, or result in a serious impairment or dysfunction of bodily functions or any bodily organ. The QSO states emergency medical conditions involving pregnant patients may include, but are not limited to ectopic pregnancy, complications of pregnancy loss, or emergent hypertensive disorders, such as preeclampsia with severe features.
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Stabilizing Treatment: The EMTALA statute requires that stabilizing treatment prevent material deterioration. The QSO states that if qualified medical personnel determine that the patient's condition, such as an ectopic pregnancy, requires stabilizing treatment to prevent serious jeopardy to the patient's health (including a serious impairment or dysfunction of bodily functions or any bodily organ or a threat to life), the qualified medical personnel is required by EMTALA to provide the treatment.
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Transfers: The QSO clarifies that a hospital cannot cite State law or practice as the basis for transfer. Hospitals that are not capable of handling high-risk deliveries or infants often have written transfer agreements with facilities capable of handling high-risk cases, but the hospital must first meet the screening, treatment, and transfer requirements of EMTALA.
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Hospital's Obligation: Finally, the QSO notes that a hospital's EMTALA obligation ends when a physician or qualified medical person has made a decision that no emergency medical condition exists (even though the underlying medical condition may persist); that an emergency medical condition exists and the individual is appropriately transferred to another facility; or that an emergency medical condition exists and the individual is stabilized or admitted to the hospital for further stabilizing treatment. The QSO states that any State that has a more restrictive definition of emergency medical condition or that has a definition that directly conflicts with any definition above is preempted by the EMTALA statute.
If you have any questions, please contact IHA's Vice President of Regulatory & Operations, Andy VanZee, at
avanzee@ihaconnect.org or IHA's Deputy General Counsel, Laura Brown, at
lbrown@ihaconnect.org.
Order Issued Lifting Dismemberment Injunction
On July 7, the U.S. District Court for the Southern District of Indiana
issued an Order lifting the preliminary injunction that was placed on various provisions of
House Enrolled Act (HEA) 1211, enacted during the 2019 legislative session, including Ind. Code §§ 16-18-2-96.4, 16-34-2-1(c), 16-34-2-7(a), 16-34-2-9, and 16-34-2-10.
Specifically, the provisions prohibit an individual from knowingly or intentionally performing a dismemberment abortion unless reasonable medical judgment dictates that performing the dismemberment abortion is necessary to prevent any serious health risk to the mother or to save the mother's life. The term “dismemberment abortion" is defined under Ind. Code § 16-18-2-96.4, which can be found
here.
The preliminary injunction was originally issued on June 28, 2019 and is lifted immediately, thereby allowing the above provisions of HEA 1211 to go into effect. If you have any questions, please contact IHA's Deputy General Counsel, Laura Brown, at
Lbrown@ihaconnect.org.
CMS Issues Infection Prevention and Control & Antibiotic Stewardship Program Guidance
On July 6, CMS issued
QSO 22-20 providing guidance on the “Medicare and Medicaid Programs; Regulatory Provisions to Promote Program Efficiency, Transparency, and Burden Reduction"
Final Rule, which included revisions for the hospital Condition of Participation at 42 CFR §482.42 regarding infection prevention and control and antibiotic stewardship programs.
The QSO clarifies:
- The final rule allows for flexibility and does not require hospitals to adhere to a specific set of regulatory guidelines or best practices in implementing the programs; and
- The final rule does not dictate whether the programs must be together or separate; the final rule allows hospitals to have unified and integrated infection prevention and control and antibiotic stewardship programs, or separate programs, accordingly to the hospital's design.
Downcoding Policies Webinar: Aug. 18
Join IHA for a virtual presentation with Lash & Goldberg LLP. Alan Lash and Jason Coe will discuss strategies for addressing emergency department downcoding policies.
Date: Aug. 18, 2022
Time: 2 – 3 p.m. ET
Register Today. Contact Laura Brown with any questions.
Content conveyed at, or in conjunction with, this event does not constitute the opinion or views of IHA.
Save The Date: Perinatal Substance Use Virtual Conference
The Indiana Perinatal Quality Improvement Collaborative and IHA will be presenting the 2022 Perinatal Substance Use Virtual Conference on Aug. 31 from 10:00 am – 1:00 pm EST.
Speakers:
- Dr. Shahla M Jilani - Office of the Assistant Secretary for Health, US Department of Health and Human Services
- Dr. Caitlin Bernard - Assistant Professor of Clinical Obstetrics & Gynecology, Indiana University School of Medicine
- Kathy Detweiler - Parkview Regional Medical Center, Community Engagement in Family Care Plans
Stay tuned for more information.
Leadership in Times of Crisis: July 20 Webinar
The Massachusetts Health and Hospital Association is offering a free webinar with Dr. Thom Mayer on July 20. Learn how to lead through crisis with Dr. Mayer's inspiring yet highly pragmatic message.
Content conveyed at, or in conjunction with, this event does not constitute the opinion or views of IHA.
IHA Weekly News - July 6, 2022
Cybersecurity Advisory: Ransomware Threat
The FBI, Cybersecurity and Infrastructure Security Agency, Department of the Treasury, and Financial Crimes Enforcement Network is urging organizations to take action to protect their networks from MedusaLocker ransomware, which uses vulnerabilities in the Remote Desktop Protocol to access victims’ networks and encrypt their data.
AHA’s National Advisor for Cybersecurity and Risk, John Riggi, stated, “It is strongly recommended that organizations continue to emphasize phishing email education for staff, exercise cyber incident response plans, and ensure the segregation and security of network and data backups, among the many helpful risk mitigation recommendations contained in the advisory.”
Indiana Lowers Thresholds for Blood Lead Levels in Children
On July 1, the Indiana Department of Health (IDOH)
adopted an emergency rule that lowers the level at which it determines a child has elevated blood lead levels to 3.5 micrograms per deciliter, in alignment
with the values set by the Centers for Disease Control and Prevention. IDOH is then expected to proceed with adopting final rules to make the emergency rules permanent as a part of continued statewide efforts to increase lead testing and reduce the risk of lead exposure.
Families of children who have a blood lead level between 3.5 and 4.9 micrograms per deciliter will receive education about lead risks and be advised to test siblings in the same household. Children with a confirmed level of 5 or above will be enrolled in case management, in which families are offered a home visit by trained case support personnel and a home risk assessment by a licensed assessor.
As a reminder, effective January 1, 2023, IDOH will also be requiring healthcare providers to offer universal screening for lead for all children under the age of 6 per
House Enrolled Act (HEA) 1313, enacted during the 2022 legislative session. IHA will keep you updated as further guidance related to HEA 1313 is developed this year.
IHA Weekly News - June 29, 2022
IN Missing Children's Clearinghouse Newsletter
The quarterly Missing Children & Endangered Adults directory has been published. This issue highlights the risks associated with children on the autism spectrum and ways to be prepared.
Children on the autism spectrum may exhibit behavioral character-istics that threaten their safety such as:
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Attractions to bodies of water, roadways/highways, trains, fire trucks, or traffic signals
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Being non-speaking/non- verbal or unable to respond to searchers when their name is called
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Experiencing sensory/stimuli overload and bolting from their environment
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Heightened risk for exploitation because of their disability
View the full newsletter.
IHA Weekly News - June 22, 2022
Update on 988 in Indiana
On July 16, 2022, 988 will go live as a new national three-digit dialing code for reaching the National Suicide Prevention Lifeline. The current long-form phone number of 800-273-TALK will also continue to be an option.
988 is more than just an easy-to-remember number—it will offer a direct connection to compassionate, accessible care and support for anyone experiencing mental health-related distress – whether that is thoughts of suicide, mental health or substance use crisis, or any other kind of emotional distress. People can also dial 9-8-8 if they are worried about a loved one who may need crisis support.
911 isn’t going away, this is just another option specifically for anyone experiencing mental health related distress. Call 9-1-1 for police, fire and medical emergencies. Call 988 for thoughts of suicide, mental health or substance use crises, or any other kind of emotional distress. If you are not sure, call 9-1-1.
Indiana is using the arrival of 988 to invest in a broader crisis response system to help all Hoosiers. This will ultimately include more than just someone to contact at a 988 center, but also someone to respond and a safe place to go for help, if needed.
View the full article here.
Monkeypox Case Counts
The Centers for Disease Control and Prevention (CDC) is tracking numerous cases of monkeypox that have been reported in countries where monkeypox is not endemic. As of June 17, 2022, there have been 113 confirmed cases of orthopox/monkeypox virus identified across the United States. Two probable cases of monkeypox have been identified in Indiana.
The Indiana Department of Health is updating testing authorization protocol, specimen collection and submission guidance, epidemiological criteria, treatment, and recommendations for post-exposure prophylaxis.
At 12:00 on Friday, June 24, a
webinar will be hosted by our Chief Medical Officer, Dr. Lindsay Weaver to discuss Monkeypox and COVID-19 vaccinations.
Hall Render Webinar: June 23
Join Hall Render attorneys Lori Wink and Joe Wolfe, along with Advisory Services advisor Delena Howard, for this webinar. Their team will provide their perspectives on staffing opportunities, compliance, billing and physician compensation issues and trends in care models where services or a portion of the services are performed by nonphysician practitioners (“NPPs”). The use of NPPs has gained renewed attention and importance since CMS implemented new requirements for split/shared billing in the 2022 Medicare Physician Fee Schedule (“MPFS”). Under the new MPFS, split/shared visits are billed under the physician or NPP who provided the “substantive portion” of the services.
Topics will include opportunities and guardrails on the use of NPPs in care delivery models, the new 2022 MPFS guidance on split/shared billing, common physician compensation models for NPP supervision and potential impacts on how compensation is calculated under productivity-based compensation models. Our panelists will also discuss what practical steps health care providers can take now to mitigate risk. Register here.
Content conveyed at, or in conjunction with, this event does not constitute the opinion or views of IHA.
IHA Weekly News - June 15, 2022
Versiti Issues Emergency Plea for Blood Donors, O Negative Supply Dangerously Low
Versiti Blood Center of Indiana has issued an emergency appeal for blood donations, pleading with Hoosiers to donate. Versiti has seen a drastic drop in scheduled appointments and the blood center anticipates the available inventory of blood to be at less than a one-day supply within the coming days. Versiti strives for at least a three-day supply of blood, so it can be ready to serve all patients, even during unexpected events.
While all blood types are needed, Type O Negative blood, used to treat trauma patients in emergencies, is the most at risk. Only about 7% of donors have Type O Negative blood, making it extremely important for those individuals to donate.
Versiti is urgently seeking donors for more than 2,500 open appointments available at community blood drives and donation centers throughout the state.
Platelet donors are also desperately needed. Platelets are a component of blood that promotes clotting and are a special type of blood donation. Platelet donations have a shelf life of less than one week, which means that donations will be used by a patient in a local hospital on average within five days. Platelets are incredibly important in a wide range of treatments for patients of all kinds, including premature babies, warriors fighting cancer, trauma victims, and those receiving organ or bone marrow transplants. Donors of all blood types are encouraged to donate platelets.
For those who do not know their specific blood type, the best way to find out is by signing up to donate blood. Donors can schedule an appointment to donate blood by calling 1-317-916-5150 or visit Versiti online at
www.versiti.org/indiana.
Versiti has extended hours at its donor center locations through June 21, 2022, to provide more flexibility for donors. Appointments are preferred, but walk-ins are welcome.
Donor center locations:
- INDIANAPOLIS: 3450 N. Meridian St.
- FISHERS: 11005 Allisonville Road
- CARMEL: 726 Adams St., Suite 150
- GREENWOOD: 8739 U.S. 31 South
- TERRE HAUTE: 2021 S. Third St.
- LAFAYETTE: 2200 Elmwood Ave., Suite D-16
PLA Updates Primary Source Documentation Requirements
The Indiana Professional Licensing Agency (PLA) recently changed its requirements regarding primary source documentation for the licensing of health care practitioners. An individual applying for a health care license may now upload an original school transcript or a copy of the original transcript.
If an original transcript is not available, the applicant must submit a copy of the original transcript, which must include the degree conferred and the date the degree was conferred, and a statement explaining why the original transcript is not available.
If an individual attended multiple schools, a transcript from each is required. If the transcript is in a language other than English, it must be accompanied by a certified translation.
Updated application instructions are now on the PLA’s website, and individuals are encouraged to utilize the PLA’s online portal for submitting applications.
CMS Issues Guidance on Surveying for Staff Vaccinations
On June 14, the federal Centers for Medicare and Medicaid Services (CMS) issued QSO 22-17 regarding state surveys for compliance with CMS's Interim Final Rule requiring COVID-19 vaccination for health care staff.
QSO 22-17 provides that state survey agencies will now only be expected to perform compliance reviews of the staff vaccination requirement during initial and recertification surveys, and in response to specific complaint allegations that allege non-compliance with the staff vaccination requirement. State survey agencies are no longer expected to perform these reviews on every survey.
To date, 12,000 providers and suppliers have been surveyed for compliance, and 95% have been found to be in substantial compliance. The QSO provides that this reduction in survey frequency is in keeping with the normal process for oversight of any Medicare requirement and is supported by the high rates of compliance in initial surveys.
IHA Weekly News - June 8, 2022
IHA, IONL Lend Support for Bucshon Bill to Protect Health Care Employees
Indiana Congressman Rep. Larry Bucshon and Pennsylvania Congresswoman Madeleine Dean yesterday introduced the
Safety From Violence for Healthcare Employees (SAVE) Act, which would provide legal penalties for individuals who knowingly and intentionally assault or intimidate a hospital employee. IHA and IONL lent support for the bill.
“IHA and IONL mourn the loss of a growing number of victims of violence in medical facilities across our country, and we thank Rep. Bucshon and Rep. Dean for bringing this important legislation forward. We will continue to collaborate with our elected leaders and community partners on initiatives to improve safety in our hospitals to protect health care workers," Brian Tabor, president of the Indiana Hospital Association (IHA) and Mary Browning, CEO of the Indiana Organization for Nursing Leadership (IONL) said.
Last week, Tabor issued a media statement in response to shootings at medical facilities in Oklahoma and Ohio. You can read his comments
here.
IDOH COVID-19 Waivers Ending on July 1
As a reminder, on March 16, IDOH announced that the current Temporary Blanket Waivers for COVID-19 for hospitals and ambulatory surgical centers will expire on July 1, 2022. If a hospital has not been granted a facility-specific waiver, the flexibilities offered through the state's Temporary Blanket Waivers for COVID-19 may not be used after July 1. For your convenience, a chart outlining the state's Temporary Blanket Waivers for COVID-19 can be found here.
With regard to the federal waivers, CMS has not announced any changes to the current 1135 waivers for hospitals and critical access hospitals at this time, which remain in effect as a result of the ongoing federal public health emergency.
Indiana OSHA Announces Enforcement of Healthcare ETS Recordkeeping Provisions
On May 25, the Indiana Occupational Safety & Health Administration (OSHA) announced that beginning Aug. 14, 2022, Indiana OSHA will enforce the recordkeeping provisions still in effect as a result of the federal OSHA’s Healthcare Emergency Temporary Standard (ETS). The entirety of Indiana OSHA’s announcement can be found
here.
As a reminder, on Dec. 27, 2021, the federal OSHA
announced that the Healthcare ETS that was originally published on June 21, 2021, would expire until superseded by a permanent standard, except for the COVID-19 log and reporting provisions at 29 CFR 1910.502(q)(2)(ii), (q)(3)(ii)-(iv), and (r), which remain in effect. While the federal OSHA is considering adopting a final Healthcare ETS, the timeline for a final standard and whether a final standard will ultimately be adopted are unknown at this time. Both AHA and IHA submitted comments to ensure that if a final standard is adopted, it does not create conflicting requirements across federal regulatory agencies.
If you have any questions regarding Indiana OSHA’s enforcement of the recordkeeping provisions beginning Aug. 14, please contact IHA’s Vice President of Regulatory & Operations, Andy VanZee, at
avanzee@ihaconnect.org or IHA’s Deputy General Counsel, Laura Brown, at
lbrown@ihaconnect.org.
Medicaid COVID-19 Coverage Following the Federal PHE
On May 25, the Indiana Family & Social Services Administration (FSSA) announced that in compliance with the federal American Rescue Plan Act of 2021, Indiana Medicaid will provide the following, with no cost sharing to Medicaid beneficiaries, starting at the end of the federal public health emergency (PHE) through the end of the last day of the first calendar quarter that begins one year after the last day of the federal PHE:
- COVID-19 vaccines and their administration;
- COVID-19 vaccine counseling under the Early and Periodic Screening, Diagnostic, and Treatment benefit for individuals 21 years of age and under;
- COVID-19 testing; and
- COVID-related treatments.
The entirety of FSSA’s announcement can be found
here.
CMS Issues Revised QSO 20-41 on Emergency Preparedness Exercises
On May 26, the Centers for Medicare and Medicaid Services (CMS) issued
revised QSO 20-41, which originally provided guidance on exemptions for emergency preparedness exercises based on a facility’s activation of its emergency plan. The updated QSO makes it clear that the guidance also applies to outpatient providers that have activated or reactivated their emergency plan, in addition to inpatient providers. The updated QSO also clarifies when providers must conduct their next emergency preparedness exercise, based on when their emergency plan was last activated or reactivated.
The exemptions apply only for the next-full scale exercises, not exercises of choice. Additionally, while facilities may be continuing to operate under an activated emergency plan, CMS encourages facilities to consider conducting their individual facility-based exercises, if possible.
Quality Measures Table Includes Changes Proposed in CMS PPS Rules
The Centers for Medicare & Medicaid Services (CMS) issued proposed rules in April that affect acute care hospitals, inpatient rehabilitation facilities, inpatient psychiatric facilities, long-term care hospitals, and PPS-exempt cancer hospitals. IHA has updated the
quality measures table to reflect the proposed changes to quality measurement requirements announced in the rules.
For questions regarding the quality measures table, please contact Elaine Pittman at
epittman@IHAconnect.org or 317-423-7735.
IHA Weekly News - May 25, 2022
Medical Exemption Guidance for CMS Interim Final Rule
The Joint Commission recently received guidance from the Centers for Medicare & Medicaid Services (CMS) that organizations that accepted medical exemption documentation for an eligible individual prior to the CMS Interim Final Rule being published are required to retrospectively obtain any of the required missing documentation. More information can be found on the Joint Commission’s website
here, and examples of required documentation include:
- Documentation signed and dated by a licensed practitioner;
- Information specifying which of the vaccines are clinically contraindicated;
- The recognized clinical reasons for the contraindication; and
- A statement recommending the staff member be exempt.
If you have any questions, please contact IHA’s Deputy General Counsel Laura Brown at Lbrown@ihaconnect.org.
Monkeypox Virus Infection in the United States and Other Non-endemic Countries
The Indiana Department of Health has distributed the attached CDC Health Advisory for monkeypox. Please see key highlights below and read the full advisory
here.
- The Massachusetts Department of Public Health and CDC are investigating a confirmed case of monkeypox in an adult male Massachusetts resident with history of travel to Canada.
- CDC is also tracking multiple confirmed and suspected clusters of monkeypox reported in early- to mid-May in several non-endemic countries, including in Europe and North America. Providers are encouraged to visit CDC's website for updates on affected countries.
- Monkeypox should be considered as a possible diagnosis for patients presenting with clinically compatible illness, especially those with a recent travel history to a country where monkeypox has been reported.
- A high index of suspicion for monkeypox is warranted when evaluating people with the characteristic rash, particularly for the following groups:
- Men who report sexual contact with other men and who present with lesions in the genital/perianal area.
- People reporting a significant travel history in the month before illness onset.
- People reporting contact with people who have a similar rash or have received a diagnosis of suspected or confirmed monkeypox
- If you suspect monkeypox in a patient:
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Immediately contact the Indiana Department of Health at 317-233-1325. After business hours, follow the prompts in the automated menu to be connected with the epidemiologist on call.
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If the Indiana Department of Health cannot be reached, CDC can be contacted through the CDC Emergency Operations Center (770-488-7100).
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All diagnostic specimens must be sent through the Indiana Department of Health. Specimens may not be sent directly to CDC without prior authorization.
Read the full CDC Health Advisory
here.
2022 Indiana School Health Network Conference
The Indiana School Health Network is holding their annual conference June 20-21 at the Indianapolis Marriott East Hotel. This year’s theme of Celebrating School Health Successes is especially relevant as schools and communities continue to recover and succeed in the current COVID environment. Dynamic speakers, subject matter experts, exhibitors and networking opportunities will provide valuable information, resources, and inspiration to move initiatives forward. This is an opportunity to attend stimulating breakout sessions and connect with like-minded folks across the state.
IHA Weekly News - May 18, 2022
Indiana Hospital Association Awards
The Indiana Hospital Association recognizes outstanding personal achievement in support of the humanitarian and management goals of Indiana health care institutions, and honors outstanding leadership and delivery of health care.
Various awards include the Distinguished Service Award, Award of Merit, Douglas J. Leonard Caregiver of the Year Award, Administrative Professional Excellence Award, and many more.
If you know an individual who would be fitting for an award, please consider nominating them. Awards will be presented at this year's Annual Meeting in November. Submissions are due September 1.
New Resources to Keep Hoosiers Covered after Federal Public Health Emergency Ends
The federal public health emergency will likely be extended through the fall of 2022 after a deadline came and went Monday without an announcement. HHS Secretary Xavier Becerra promised to give 60 days’ notice before the emergency expires, signaling the likely extension. The move would keep intact Medicaid coverage and a plethora of other policies enacted at the beginning of the pandemic — giving state officials, industry leaders and health care advocates more time to prepare for the public health emergency’s end.
During the COVID-19 federal public health emergency, Indiana Medicaid members have been able to keep their coverage without interruption. However, when the federal public health emergency ends, Indiana Medicaid will begin to return to normal operations. IHA's Senior Vice President of Finance Terry Cole co-chairs the state’s Medicaid Advisory Committee with Indiana Medicaid Director Allison Taylor and has been working closely with the administration on this process to ensure a smooth transition. FSSA previewed a new website yesterday that is now live to assist people and offer health coverage options. IHA is encouraging hospital members to review these materials and use them in your communications with patients who are enrolled in Indiana Health Coverage Programs (IHCP) to help them stay covered.
May 19 Webinar: Navigating HIPAA’s Right of Access
Join Hall Render attorneys Stephane Fabus and Patricia Connelly to learn how to distinguish patient access requests from other requests for information, compare the requirements of the Information Blocking Rule versus HIPAA’s right of access, discuss the challenges with defining the designated record set and assess common scenarios that may give rise to liability.
Register here.
Content conveyed at, or in conjunction with, this event does not constitute the opinion or views of IHA.
June 9 Webinar: Stark Law Back to Basics
Join Hall Render attorneys Keith Dugger, Kerry Dutra, Alyssa James and Katherine Schwartz for a webinar on the basics of the Stark Law, including key definitions, exceptions, penalties for non-compliance, developments and trends, and compliance strategies for health care organizations. This presentation is Part 1 of their 2-part Stark Law and Anti-Kickback Statute Primer Series.
Register here.
Content conveyed at, or in conjunction with, this event does not constitute the opinion or views of
A.
IHA Weekly News - May 11, 2022
National Nurses and Hospital Week
This week is National Nurses and Hospital week, and we are thrilled to celebrate them for all the hard work and love they pour into patients every day. We want to empower nurses and healthcare workers so they can best tailor clinical care for patients.
It's no secret COVID-19 was extremely tough on all our nurses and hospital staff. To mitigate and respond to the psychological toll of cries such as the pandemic, it is critical that health care organizations have systems in place that support institutional an individual resilience. Statewide, many Indiana hospitals are implementing resiliency strategies, such as Resilience and Emotional Support Teams (REST) program, to provide health care workers with facilitated debriefing sessions that increase individual resiliency and self-efficacy.
Along with caring for our hospital employees' mental health, it is also important they feel safe in the workplace. Hospitals and health care systems have long had robust protocols in place to detect and deter violence against their staff. Since the onset of the pandemic, violence against hospital employees has increased — and there is no sign it is receding. The hospital industry has urged the U.S. Attorney General to support legislation that would increase protections for health care workers from assault and intimidation. While we may never reduce violence in our hospitals to zero – because we are there to serve in the most challenging settings and circumstances – we can insist on zero tolerance for abusive behavior.
Join Your Peers in Supporting the Friends PAC
THANK YOU to the following hospitals who have met their Friends of Indiana Hospitals PAC goals for 2022:
- Adams Memorial Hospital
- Baptist Health Floyd
- Beacon Health System
- Cameron Memorial Community Hospital
- Clark Memorial Hospital
- Columbus Regional Hospital
- Community Health Network
- Deaconess Health
- Goshen Health
- Greene County Memorial Hospital
- Hancock Regional Hospital
- Harsha Behavioral Center
- Hendricks Regional Health
- King’s Daughters’ Health
- Lutheran Health Network
- Northwest Health
- OrthoIndy Hospital
- Perry County Memorial Hospital
- Pulaski Memorial Hospital
- River Bend Hospital
- Rush Memorial Hospital
- Schneck Medical Center
- Scott Memorial Hospital
- St. Elizabeth Dearborn
- Terre Haute Regional Hospital
- Wellstone Regional Hospital
SUNRx 340B Webinar Series: 340B Regulatory Brief
Live Webcast Date/Time: Tuesday, 6/14/22 - 2 PM ET
The regulatory environment for 340B pharmacy is in a constant state of change, requiring eligible entities to be nimble and disciplined in the management of their program. Navigating the current ecosystem of 340B pricing limitations created by Big Pharma requires an understanding of the current regulatory environment. This webinar will provide insights that will support decisions that position your entity to maintain a compliant and optimized 340B pharmacy program.
In this session, we will share valuable insights for consideration in the management of your 340B pharmacy strategy. We will cover:
- How did we get here?
- Current regulatory environment
- Implications moving forward
Content conveyed at, or in conjunction with, this event does not constitute the opinion or views of IHA.
DMHA RFI on Pediatric Health Network Mental Health Partnerships
On May 4, FSSA’s Division of Mental Health and Addiction (DMHA) released a Request for Information (RFI) regarding partnerships to place mental health professionals in existing pediatric health systems. The RFI can be found here, and responses are due by June 3 at 3 PM ET.
As stated in the RFI, DMHA is interested in learning about existing, large pediatric providers interested in partnership with the State to integrate mental health professionals into their networks. In order to maximize the impact of this partnership, the State is soliciting proposals from respondents who:
- Have existing, pediatric provider networks serving children who reside in seven (7) or more counties in the State; and
- Will commit to matching State investment on a one-to-one basis with cash (no in-kind matches will be permitted).
This RFI is an opportunity for DMHA to explore future grant making.
IHCP Bulletin
As a result of the Centers for Medicare & Medicaid Services (CMS) Update to COVID-19 Emergency Declaration Blanket Waivers for Specific Providers memorandum released on April 7, 2022, the Indiana Health Coverage Programs (IHCP) rescinds the provision of services in alternative settings granted by the CMS-approved 1135 waiver as a result of the coronavirus disease 2019 (COVID-19) public health emergency.
Effective for dates of service on or after June 6, 2022, the IHCP will reinstate the federal requirement that all facility providers must render services in a licensed facility to be fully reimbursed. This requirement includes the following facilities:
-
Nursing facilities (NFs)
- Intermediate care facilities for individuals with intellectual disabilities (ICFs/IID)
- Psychiatric residential treatment facilities (PRTFs)
- Hospital NFs
FDA Limits Use Of J&J COVID-19 Vaccine
The FDA has
limited the authorized use for the Johnson & Johnson/Janssen COVID-19 vaccine to individuals who are ages 18 and older for whom other authorized or approved COVID-19 vaccines are not accessible or clinically appropriate, and to individuals ages 18 and older who elect to receive the Janssen COVID-19 vaccine because they otherwise would not receive a COVID-19 vaccine. This change in authorization is due to the risk of thrombosis with thrombocytopenia syndrome.
IHCP COVID-19 Response
In response to the national public health emergency due to the coronavirus 2019 (COVID-19), the Indiana Health Coverage Programs (IHCP) is offering financial relief to Indiana units of local government and independent ambulance operators. The purpose of these grants is to improve transportation services to members residing in their home and needing nonemergent care and services within their community that requires the use of an ambulance.
The IHCP is making available a one-time, federally funded grant opportunity to cover the cost to purchase bariatric ambulances at $180,000 per vehicle, and up to two vehicles per applicant, aimed at increasing nonemergency medical transportation (NEMT) services.
To be eligible for an HCBS ambulance grant, providers must meet the following criteria as of the date of attestation submission:
- Appropriately licensed to operate ambulances and be an actively enrolled IHCP provider as a transportation provider contracted with the state’s fee-for-service NEMT program, currently administered by Southeastrans, Inc.
- Willing to pick up members at their own residence, such as house, condo or apartment. Separate funding is available to assist members in addressing structural accessibility issues that may reduce/limit the ability of the Emergency Medical Services (EMS) to enter the residence with the necessary equipment.
- Able to submit a quarterly usage report and an annual impact report to the Office of Medicaid Policy and Planning (OMPP).
- Agree to schedule and bill for services according to the state and NEMT broker policies.
- Comply with the requirements of Code of Federal Regulations 2 CFR 200.313 – Equipment upon receipt of grant funds and cooperate with the appropriate state or federal agencies to verify ongoing compliance.
Drug Shortage Of Iohexol And Related Mitigation Strategies
Nationwide shortage of the GE contrast product Iohexol (Omnipaque) is causing some concerns. This shortage is expected to be resolved by the end of June. Facilities experiencing shortages are encouraged to explore use of contingency contrast agents that remain available on the market. As this is a global issue for GE, it is unlikely that other facilities would have sufficient supplies on hand. Facilities also can explore if the supplier has an identical product in different volumes than typically ordered.
Below are potential conservation strategies to consider:
- Evaluate the amount of on-hand inventory
- Seek other means of securing contrast media including alternate wholesalers and distributors
- Evaluate incoming CT and x-ray orders to determine if an alternate imaging modality can be utilized
- Discuss protocol options with radiology leadership, radiology staff, and ordering physicians including Emergency Department physicians, cardiologists, and outpatient imaging providers to ensure protocols are evaluated for the appropriate use of contrast
- media
- e
- Communicate opportunities for conservation and awareness of wasted contrast media to CT, x-ray, interventional, and catheterization lab technologists
- Develop a communication plan for referring physicians and all imaging departments; leverage appropriate use criteria for when to utilize contrast-based CT examinations
IHA Weekly News - May 4, 2022
Reminder: Certain Waivers for Nursing Facilities to End
As a reminder, on Apr. 7, CMS issued QSO 22-15, announcing the end of certain waivers for skilled nursing facilities (SNF), inpatient hospices, intermediate care facilities for individuals with intellectual disabilities (ICF/IIDs), and end-stage renal disease (ESRD) facilities within 30 to 60 days from the publication of the QSO, as outlined below. QSO 22-15 did not impact the SNF waivers related to the three (3) day prior hospitalization stay and pre-admission screening (PASARR), and at this time, CMS has not announced any changes to the current 1135 waivers for hospitals and critical access hospitals.
On May 7, the following waivers will expire for SNFs:
- Resident Groups - 42 CFR §483.10(f)(5)
- Physician Delegation of Tasks in SNFs - 42 CFR §483.30(e)(4)
- Physician Visits - 42 CFR §483.30(c)
- Quality Assurance and Performance Improvement - 42 CFR §483.75(b)–(d) and (e)(3)
- Detailed Information Sharing for Discharge Planning - 42 CFR §483.21(c)(1)(viii)
- Clinical Records - 42 CFR §483.10(g)(2)(ii)
On June 7, the following waivers will expire for various facilities:
- Physical Environment for SNFs - 42 CFR §483.90
- Equipment Maintenance & Fire Safety Inspections for ESRD facilities - 42 CFR §494.60(b) and(d)
- Facility and Medical Equipment Inspection, Testing & Maintenance (ITM) for Inpatient Hospice, ICF/IIDs and SNFs - 42 CFR §§418.110(c)(2)(iv), 483.470(j), and 483.90
- Life Safety Code and Health Care Facilities Code ITM for Inpatient Hospice, ICF/IIDs and SNFs - 42 CFR §§ 418.110(d)(1)(i) and (e), 483.470(j)(1)(i) and (5)(v), and 483.90(a)(1)(i) and (b)
- Outside Windows and Doors for Inpatient Hospice, ICF/IIDs and SFNs – 42 CFR §§418.110(d)(6), 483.470(e)(1)(i), and 483.90(a)(7)
- Life Safety Code for Inpatient Hospice, ICF/IIDs, and SNFs - 42 CFR §§418.110(d), 483.470(j), and 483.90(a)
- Paid Feeding Assistants for LTC facilities: 42 CFR §§483.60(h)(1)(i) and 483.160(a)
- In-Service Training for LTC facilities – 42 CFR §483.95(g)(1)
- Training and Certification of Nurse Aides for SNFs - 42 CFR §483.35(d)
CDC Health Alert Network
The
CDC HAN (health alert network) issued an alert describing an individual who tested positive for avian influenza A(H5) virus (H5 bird flu) in the US. Based on current CDC guidance for a confirmed case who is hospitalized, facilities should plan to follow standard contact and airborne precautions, which is a higher level than seasonal influenza. These precautions should be within the capabilities and scope of a traditional hospital setting.
Currently, the risk of transmission from birds to humans is low. The potential risk of human-to-human transmission is extremely low. Local health departments (LHDs), hospitals, and local healthcare providers should continue to coordinate regarding the potential, although low, risk of having a patient with avian influenza within their jurisdiction.
If you have any questions, please contact the Indiana Department of Health, Epidemiology Resource Center at 317-233-1325.
IHA Weekly News - April 27, 2022
AHA Annual Meeting 2022
After not taking place in 2020 and 2021, the American Hospital Association (AHA) held their Annual Meeting this week in Washington, DC. Brian Tabor, Trent Fox, and Kristin Schwartz joined IHA members and hosted meetings with Indiana legislators at the Capitol. As the first meeting since the COVID-19 pandemic, this year’s meeting was critical to reinvigorating relationships at the federal level.
Thank you to Senator Young and Senator Braun for meeting with Indiana constituents to discuss issues facing the health care industry.
May 13 Deadline: IHA Compensation Survey
The deadline for the compensation section of the 2022 Indiana Healthcare Compensation and Benefits Survey is May 13.
Time is running out to participate in the compensation portion of the 2022 Indiana Healthcare Compensation and Benefits Survey, presented by Indiana Hospital Association and Gallagher Surveys. Please download the compensation survey template and upload to the portal by May 13. The survey is the premier source of compensation data for healthcare organizations across the state. Your organization's participation will grant you access to an indispensable planning tool while also helping build a resource used by your peers.
The reporting process is simple.
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Download the compensation questionnaire and populate it with your organization's information. Complete instructions are included on the first tab of the worksheet.
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Upload your completed compensation spreadsheet to Gallagher’s secure server.
Important: If you are reporting for multiple hospitals/locations, you may include all of them on one compensation submission.
DMHA Request for Funding
The Division of Mental Health and Addiction has recently released RFF-2022-009 with the intent of increasing the number of low-barrier shelters for unhoused individuals in Indiana. You can find more information here: https://www.in.gov/fssa/dmha/funding-information/
There will be an information Webinar on May 3rd, 2022 at 2pm EST for opportunity to learn more and ask questions.
IHA Provides Tools to Promote Workforce Wellbeing
Promoting workforce wellbeing and resiliency has been a priority for IHA both before and during the pandemic and will continue to be a priority going forward. Check out this Workforce Wellbeing video from Laurie Gerdt, Patient & Quality Safety Advisor here.
Indiana Department of Health Advisory
The Indiana Department of Health (IDOH) is working with the Centers for Disease Control and Prevention (CDC) and health care providers who may have identified any individual cases or increase of acute hepatitis of unknown etiology in children in Indiana. Based on a case timeline from other states, the IDOH is conducting a review of potential cases back to October 2021 via medical record search, and we will issue syndromic alerts moving forward. The IDOH wishes to coordinate with any clinicians who identify cases, and we will provide more details as this investigation continues across the United States and Europe.
Healthcare providers who suspect they have identified a case or increase in pediatric acute hepatitis of unknown etiology matching the description provided in the attached CDC HAN, are urged to notify the IDOH and provide the pertinent clinical details, including liver function testing, viral hepatitis testing, liver transplant status, adenovirus testing, and epidemiologic details of importance for the patient (such as travel status). Hospital laboratories may be asked to hold specimens for additional adenovirus testing, including whole blood specimens. Read the full
CDC Health Advisory.
For consultation or to report suspected cases to the IDOH Epidemiology Resource Center, please contact Nicole Stone, Senior Enteric Epidemiologist, at 317-234-2898 or
nstone2@isdh.in.gov.
Upcoming Gallagher Events for IHA Members
Gallagher is offering a couple May events for IHA members:
May 4, Town Hall: Inflation Frustration: Internal communication for high stress times
Persistent inflation, a volatile economy and high competition for talent are top challenges for organizations today. Employers are looking for ways to create loyalty while engaging and retaining talent. Gallagher's May 4 town hall, “ Inflation Frustration: Internal communication for high stress times," will outline trends, challenge assumptions and encourage strategic internal communication, all with the goal of helping employers maximize the impact of their messaging to support their workforce during these stressful times. This session is also pending approval for 1 hour of HRCI and SHRM accreditation.
Register: https://event.on24.com/wcc/r/3727793/EF051125CEDC9395557E5E60E851E321?partnerref=AssociationIHA
May 18: The Women's Leadership Series
Join Gallagher's Virtual Women's Leadership Series event, Advocate For Your Time, on Wednesday, May 18. Given the blurred lines between work and home and the constant glamorization of busyness, it's no surprise that many working women feel overextended. Our panel will discuss strategies to counteract overwork culture and ways to get intentional about your time, both personally and professionally.
Register: https://event.on24.com/wcc/r/3677216/7FBB746E34054389E58AB9238FBAC5CB?partnerref=AssociationIHA
IHA Weekly News - April 13, 2022
Black Maternal Health Week
This year marks the fifth-year anniversary of the Black Maternal Health Week campaign that takes place every year from April 11 - 17 and was officially recognized by the White House on April 13th, 2021. IHA recognizes that health disparities exist in the state of Indiana. We are committed and prioritize health equity by asking Indiana birthing hospitals to begin screening for social determinants of health in the maternal-infant health population through our Safety PIN C efforts.
IHA is committed to reduce health disparities in the maternal-infant population so that all Hoosiers and infants receive an equal opportunity to achieve optimal health and well-being.
IHA is partnering with the community and hospital members to implement an innovative health disparities framework. It is our goal to engage the community by transforming individual social determinants of health screening data into local population health data, where we will then target health disparities through analysis and visual presentation of maternal-infant data. This will allow Indiana birthing hospitals to better serve the patients in their communities and act on identified health disparities through local and statewide interventions.
Please join us in commemorating the 5th anniversary of Black Maternal Health Week and take part in unforgettable activities & conversations aimed at shifting the state of Black Maternal Health in the U.S. Learn more:
https://blackmamasmatter.org/bmhw/
Moving Forward: A New Focus On Patient Care Webinar Series
The Indiana Hospital Association, in partnership with 19 other state hospital associations, is pleased to bring an energizing, virtual engagement opportunity to our members.
The series, led by national speakers from Huron Consulting (formerly Studer Group), looks to the future by moving forward from the COVID-19 pandemic and turning the focus to patient care. The series is designed for all health care managers and supervisors, including those in the nursing and allied health professions, who would like to fine-tune their management skills.
Registration is limited to the first 250 people, so please secure your spot by registering today. Registration will automatically close when the registration limit has been reached. Sessions take place from 1 – 2 p.m. ET. Register for this free series today:
https://cvent.me/XD7KL1
May 3: Everyday Habits to Create a Culture of Innovation - Natalie Painchaud, Director of Learning, Innosight
June 14: Creating an Environment of Trust through Compassion - Karen Cook, RN, Coach & National Speaker, Huron
July 12: The Patient as a Consumer: How to Create Experiences Patients Value - David Duncan, PhD, Managing Director, Innosight
August 16: Leading a Change-Ready, Inclusive Environment - Kristie Tobias, Director, National Speaker & Author, Huron
Additional information, including full session descriptions and objectives, can be found
here.
CMS Issues Revised QSO 22-09 on Interim Final Rule
On Apr. 5, CMS issued revised QSO 22-09, which originally provided survey guidance on CMS’s Interim Final Rule (IFR) regarding COVID-19 vaccination of health care staff.
The revised QSO clarifies and provides the following:
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Surveying for staff vaccination requirements is not required on Life Safety Code (LSC)-only complaints or LSC-only follow-up surveys.
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Surveyors may modify their staff vaccination compliance review if a provider was determined to be in substantial compliance with the requirement within the previous six (6) weeks.
CMS also issued a revised Attachment D, which accompanies the revised QSO 22-09 for hospitals. The revised Attachment D clarifies and provides the following:
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The term “temporarily delayed vaccination” now includes “known COVID-19 infection until recovery from the acute illness (if symptoms were present) and criteria to discontinue isolation have been met.”
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With regard to the requirement that mitigation measures be taken for unvaccinated staff, Attachment D clarifies that the examples included are not all inclusive and only represent actions that can be implemented.
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During the entrance conference to determine compliance with the CMS IFR, a hospital will be asked to provide its process for how the hospital ensures that its contracted staff are compliant with the vaccination requirement.
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During the record review, interview, and observations portion to determine compliance with the CMS IFR, there should be a minimum sample of six (6) direct care/patient engagement staff. Of this sample, four (4) should include vaccinated staff/contractors, and two (2) unvaccinated staff/contractors (one (1) who is not fully vaccinated and one (1) with a medical exemption or temporary delay). Two (2) of the direct care staff sampled should be contractors.
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Surveyors should also choose a sample of at least of two (2) contracted staff (one (1) vaccinated and one (1) unvaccinated or exempt) who are not included in those direct care contracted staff outlined above.
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Failure of contract staff to provide evidence of vaccination status reflects noncompliance and should be cited under the requirement to have policies and procedures for ensuring that all staff are fully vaccinated, except for those staff who have been granted exemptions or a temporary delay.
CMS Announces End of Certain Waivers for Nursing Facilities
On Apr. 7, CMS issued
QSO 22-15, announcing the end of certain waivers for skilled nursing facilities (SNF), inpatient hospices, intermediate care facilities for individuals with intellectual disabilities (ICF/IIDs), and end-stage renal disease (ESRD) facilities in the next 30 to 60 days, as outlined below.
QSO 22-15 does not impact the SNF waivers related to the three (3) day prior hospitalization stay and pre-admission screening (PASARR), and at this time, CMS has not announced any changes to the current 1135 waivers for hospitals and critical access hospitals.
Thirty (30) days from the publication of QSO 22-15, the following waivers will expire for SNFs:
- Resident Groups - 42 CFR §483.10(f)(5)
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Physician Delegation of Tasks in SNFs - 42 CFR §483.30(e)(4)
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Physician Visits - 42 CFR §483.30(c)
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Quality Assurance and Performance Improvement - 42 CFR §483.75(b)–(d) and (e)(3)
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Detailed Information Sharing for Discharge Planning - 42 CFR §483.21(c)(1)(viii)
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Clinical Records - 42 CFR §483.10(g)(2)(ii)
Sixty (60) days from the publication of QSO 22-15, the following waivers will expire for various facilities:
- Physical Environment for SNFs - 42 CFR §483.90
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Equipment Maintenance & Fire Safety Inspections for ESRD facilities - 42 CFR §494.60(b) and(d)
- Facility and Medical Equipment Inspection, Testing & Maintenance (ITM) for Inpatient Hospice, ICF/IIDs and SNFs - 42 CFR §§418.110(c)(2)(iv), 483.470(j), and 483.90
- Life Safety Code and Health Care Facilities Code ITM for Inpatient Hospice, ICF/IIDs and SNFs - 42 CFR §§ 418.110(d)(1)(i) and (e), 483.470(j)(1)(i) and (5)(v), and 483.90(a)(1)(i) and (b)
- Outside Windows and Doors for Inpatient Hospice, ICF/IIDs and SFNs – 42 CFR §§418.110(d)(6), 483.470(e)(1)(i), and 483.90(a)(7)
- Life Safety Code for Inpatient Hospice, ICF/IIDs, and SNFs - 42 CFR §§418.110(d), 483.470(j), and 483.90(a)
- Paid Feeding Assistants for LTC facilities: 42 CFR §§483.60(h)(1)(i) and 483.160(a)
- In-Service Training for LTC facilities – 42 CFR §483.95(g)(1)
- Training and Certification of Nurse Aides for SNFs - 42 CFR §483.35(d)
IHA Counsel Listserv
If you or a member of your team is interested in receiving relevant legal memorandums and updates, please contact IHA’s Deputy General Counsel, Laura Brown, at
Lbrown@ihaconnect.org to be added to IHA’s counsel listserv.
HHS Distributing $1.75 Billion in Provider Relief Fund Payments
On Apr. 13, the Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), announced more than $1.75 billion in Provider Relief Fund payments will be distributed to 3,680 providers across the country.
With this latest round of payments, nearly $21 billion of the $25.5 billion in funding has been distributed. Phase 4 payments reimburse smaller providers for a higher percentage of losses during the pandemic and include bonus payments for providers who serve Medicaid, Children's Health Insurance Program, and Medicare beneficiaries.
Providers can use Provider Relief Fund payments received in the first half of 2022 to cover losses and expenses until June 30, 2023. With these latest payments, approximately 92% of all Phase 4 applications have been processed. IHA is learning to what extent Phase 4 funds were received by hospitals and will keep members updated accordingly.
IHA COVID-19 Operations Transition Resource
The goal to ensure the safety of patients, visitors, and staff against COVID-19 and all infectious diseases remains paramount for Indiana hospitals. As COVID-19 cases decline in communities, policies and procedures for managing operations may be adjusted. As organizations consider these adjustments, it may benefit establishing thresholds to determine how screening, masking, and visitation will be impacted during low and high periods of high hospitalizations and community spread. The IHA team has developed COVID-19 Operations Transitions Resource.
While we are seeing this period of decline, as health care providers, we must keep in mind that the prospect of new variants remain a concern. To ensure Indiana is prepared for a next surge of COVID-19, the Indiana Department of Health asks that its partners have updated their emergency plans in place. State Health Commissioner Kristina Box encourages everyone to maintain support capabilities developed during the COVID-19 pandemic to best prepare for future surges.
State Lawmakers Review Feedback from Hospitals, Insurers
Senator Bray and Speaker Huston released a statement on their receipt of the responses submitted to them based on their December letter to certain hospitals and insurers. In their response, they released the response letters submitted to them.
Prior to their statement, IHA released a statement reaffirming Indiana hospitals’ commitment to affordability and our willingness to continue working with stakeholders and policy makers to further advance the momentum our members have generated to ensure Hoosiers receive the best value when seeking and receiving health care services.
In the next few weeks, IHA will meet with the legislative leaders to further discuss their feedback and determine next steps. For more information, the full article can be found here.
Important: Updated No Surprises Act Toolkit
IHA worked with our partners at Hall Render to update the No Surprises Act Toolkit and model forms to reflect two recent changes. Specifically, the recent Texas Medical Association v. HHS decision, which invalidated the presumption that the qualifying payment amount is the appropriate in-network rate, and House Enrolled Act (“HEA") 1238 from the 2022 legislative session, which helped align state and federal law.
Please note, while the impact of the Texas Medical Association v. HHS decision is effective immediately, the changes as a result of HEA 1238 are not effective until July 1, 2022. Accordingly, the updated model forms should not be utilized until July 1, 2022.
Thank you to Angela Smith and Matt Reed for their work on the updated toolkit, and please contact Laura Brown at Lbrown@ihaconnect.org with any questions.
Indiana’s Hospital Systems Stand Committed to Affordability
Indiana’s health care heroes stood at the bedside of those battling COVID-19 for the last two years. As we emerge from the pandemic, hospitals continue to stand with Hoosiers, united in our commitment to high-quality care and affordability. Despite the unprecedented strain of the pandemic, we have implemented new tools that provide an unprecedented level of price transparency.
This new era of transparency has fueled rapid change in the marketplace, and lower costs will come from the fundamental change in the way health care is delivered in Indiana. Learn more about CEO committment to healthcare affordability.
Deadline Extended to Submit Speaker Proposals for IHMPRS Conference
The Indiana Healthcare Marketing & Public Relations Society (IHMPRS) Board of Directors invites individuals and organizations to submit proposals to present at our annual Strategic Communications Summit to be held July 21-22, 2022 at Good Samaritan in Vincennes, Indiana. We are looking for presenters with innovative topics addressing the advancement of healthcare-related marketing.
Topics include: Strategic Planning, Marketing, Communications / Public Relations, Digital Engagement, Diversity Equity and Inclusion, Pandemic Recovery, Crisis Communication, Career and Leadership Development, Artificial Intelligence.
The deadline to submit a proposal has been extended to April 15. Submit a proposal.
IHCP Extends Medicaid Postpartum Coverage to 12 Months
On March 31, the Indiana Health Coverage Programs issued Bulletin BT202226, announcing that effective April 1, the postpartum coverage period for Healthy Indiana Plan Maternity and Hoosier Healthwise members will be extended from 60 days to 12 months of continuous eligibility, regardless of change in circumstance that would otherwise result in loss of eligibility.
There are no changes to the benefits covered, and members will continue to be exempt from cost-sharing during pregnancy and the postpartum coverage period.
IHA Weekly News - March 30, 2022
OSHA Seeking Comments on Final Healthcare ETS Standard – Feedback Requested
On Mar. 22, the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) announced that it has reopened the rulemaking record to seek comments on the development of a final standard to protect healthcare workers from workplace exposure to COVID-19. OSHA is therefore seeking feedback as it works toward making the Healthcare ETS, originally issued on June 21, 2022, a permanent rule (as a reminder, the COVID-19 log and reporting provisions of the Healthcare ETS at 29 CFR 1910.502(q)(2)(ii), (q)(3)(ii)-(iv), and (r) remain in effect per OSHA's announcement here).
A list of those specific items OSHA is seeking feedback on as it considers a final standard can be found here. IHA intends to submit comments by the Apr. 22 deadline. Please contact Laura Brown at Lbrown@ihaconnect.org by Apr. 8 if you have any feedback on those items listed.
IHA Invites You to Attend AHA's Annual Meeting on April 25-26
After not taking place in 2020 and 2021, the American Hospital Association (AHA) will hold an in-person Annual Meeting April 25-26 at the Marriott Marquis in Washington, D.C. IHA will attend along with hospital and health systems leaders and trustees. If you plan to attend, please read the memo and complete the form by April 15 so that we can include you in our events. We will host a dinner on Monday night for IHA members and are arranging Capitol Hill visits with our Congressional delegation on Tuesday, April 26.
Visit the AHA's Annual Meeting webpage for more details and registration information for AHA-specific programming.
IHA Weekly News - March 23, 2022
Health care was a major focus for lawmakers during the 2022 session of the Indiana General Assembly and IHA successfully passed important legislation impacting hospitals, including addressing Indiana's health care workforce shortage, exempting health care facilities from conflicting state and federal COVID-19 vaccine requirements, streamlining Indiana's good faith estimate law with the federal No Surprises Act, extending Medicaid coverage for pregnant women, and more. In addition, IHA successfully defeated numerous harmful proposals, including those that would have prohibited physician non-compete contracts, cut hospital reimbursement for worker's compensation claims, made changes to Indiana's public forum law, and more.
Some of these proposals will be back under consideration next session as special interest groups continue to attack hospitals to advance their own agendas. We cannot afford to fall short next session – there is simply too much at stake.
So far, we have raised $21,000 of our $215,000 goal for 2022. Please consider raising your donation to Friends and contributing today to help us jump-start the campaign. You can find your hospital's goal here and you can donate online here. In addition, please find information on how to run a campaign at your facility here. Please contact Laura McCaffrey to begin that process.
IHA Weekly News - March 9, 2022
IDOH to Reissue COVID-19 Waivers through June
The Indiana Department of Health (IDOH) has communicated with IHA its intention to reissue all of its current COVID-19 Waivers through June.
The Waivers currently in effect are linked below and are effective for 45 days following the end of the state's Public Health Emergency declaration, which was withdrawn on Mar. 3, 2022, per IDOH's Order issued on Aug. 9, 2021. IDOH then intends to reissue the Waivers once again through June. IHA will distribute the renewed Waivers as soon as they are available.
- COVID-19 NATIONAL/STATE EMERGENCY HOSPITAL BLANKET WAIVER: CONVERSION OF STANDARD PATIENT ROOMS TO NEGATIVE PRESSURE ISOLATION ROOMS: Link HERE
- SECOND COVID‐19 NATIONAL/STATE EMERGENCY HOSPITAL BLANKET WAIVER: PATIENT ROOMS: Link HERE
- THIRD EMERGENCY ORDER GRANTING TEMPORARY BLANKET WAIVERS FOR HOSPITALS: Link HERE
- EMERGENCY ORDER GRANTING TEMPORARY BLANKET WAIVERS FOR AMBULATORY OUTPATIENT SURGICAL CENTERS: Link HERE
IHA Weekly News - March 2, 2022
IDOI Releases 2022 Patient’s Compensation Fund Surcharges
On February 22, 2022, the Indiana Department of Insurance (IDOI) published Bulletin 263 outlining the surcharges for physicians and hospitals for the Patient’s Compensation Fund (PCF) effective July 1, 2022. Notably, Bulletin 263 provides that the 2022 PCF surcharges for physicians and hospitals will remain flat and will not change from the current effective rates as outlined in the Bulletin.
For more information, please access IHA’s Memorandum on the 2022 PCF Surcharges here.
IDOI’s Bulletin 263 can be accessed here.
IDOH Issues Engineering Standards Update
The Indiana Department of Health recently issued the following letter regarding the engineering standards for hospitals and ambulatory surgical centers.
As outlined in the letter, the COVID-19 pandemic has delayed IDOH from adopting formal rules to update the constructure standards per Senate Enrolled Act 575 from the 2019 legislative session. However, IDOH’s letter clarifies that notwithstanding the current administrative code, the following apply to a publication that is referred to in 410 IAC 15 (Hospital Licensure Rules):
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The Guidelines for Construction and Equipment of Hospital and Medical Facilities refers to the following:
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The 2018 edition or most recent publication of the Guidelines for Design and Construction of Hospitals.
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The 2018 edition or most recent publication of the Guidelines for Design and Construction of Outpatient Facilities.
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The National Fire Protection Association (NFPA) 101, Life Safety Code publication refers to the 2012 edition as adopted by CMS.
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The National Fire Protection Association 99, Health Care Facilities Code publication refers to the 2012 edition as adopted by CMS, excluding chapters 7, 8, 12, and 13.
IDOH will seek to update its administrative code to reflect the above changes.
Surprise Billing Litigation
On February 23, 2022, the U.S. District Court for the Eastern District of Texas struck down the following provisions of the federal regulations implementing the No Surprises Act (NSA), finding the regulations conflicted with the statutory text of the NSA, as a result of the lawsuit brought by the Texas Medical Association:
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The requirement that the Independent Dispute Resolution (IDR) entity select the offer closest to the Qualified Payment Amount (QPA) unless there is credible information to demonstrate that the QPA is not the appropriate rate;
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The requirement that “additional information” clearly demonstrate that the QPA is materially different from the out-of-network rate;
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The definition of “material difference” at 45 C.F.R. § 149.510(a)(2)(viii);
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All four examples on how IDR entities should choose between competing offers at 45 C.F.R. § 149.510(c)(4)(iv); and
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The requirement that the IDR entity explain why it chose an offer not closest to the QPA.
At this time, HHS/CMS have not indicated whether they will update the regulations accordingly, and HHS/CMS are expected to appeal the Texas District Court decision. A similar lawsuit filed by AHA and AMA is currently pending in the U.S. District Court for the District of Columbia. IHA will continue to keep you updated on this front.
IHCP Rescinds Certain Temporary COVID-19 Policy Changes
On Mar. 1, the Indiana Health Coverage Programs issued Bulletin 202215, announcing that certain temporary policy changes that were enacted in response to the public health emergency will expire as of Mar. 31. Those temporary policy changes include those outlined in the following bulletins:
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BT202174: IHCP temporarily reinstates revisions to PA process for acute care hospital non-elective inpatient admissions
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BT202178: IHCP temporarily revises time frames for certain PA approvals
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BT202179: IHCP reinstates inpatient SUD and psychiatric admission policy changes
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BT202180: PA changes temporarily reinstated for some DME/HME supplies and services
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BT202181: IHCP reinstates temporary PA changes for managed care SNF admissions
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BT202182: IHCP temporarily reinstates PA policy for LTAC and AIR facility admissions
IHA Announces Friends PAC Award Winners for 2021
IHA is pleased to announce that Community Health Network, Rush Memorial Hospital, and Cameron Memorial Hospital have been recognized by IHA for their exceptional contributions to the 2021 Friends Political Action Committee (PAC) campaign. IHA will formally recognize these members at the 2022 Annual Awards Luncheon as part of our Annual Meeting on November 2, 2022. Community Health Network will be recognized for contributing the greatest total amount to Friends, raising $13,350 in 2021. Rush Memorial Hospital will be recognized for contributing the highest percentage of their individual goal, raising 286% of their goal last year. Cameron Memorial Hospital will be recognized for most improved, raising 160% of their goal in 2021 compared to 7% of their goal the year before. IHA wants to thank all members who donated to the Friends campaign last year – we successfully increased donations by 30%. With much at stake in the year ahead, your donations make a real impact. While the 2022 Friends campaign does not formally launch until March, members can get a head start by donating online and contacting Melissa Vise to begin running a campaign. Find your hospital/system’s individual goal here.
IHA Weekly News - February 23, 2022
FSSA: Changes to Postpartum Coverage
On Feb. 16, the Family and Social Services Administration published a notice of changes to postpartum coverage for Indiana Medicaid recipients. The changes include:
- Expanding the eligibility group to pregnant women whose income level does not exceed two hundred eight percent (208%) of the federal poverty level for the same family size;
- Removing Medicaid limitations for eligible pregnant women seeking medical assistance coverage for only pregnancy-related services; and
- Extending postpartum coverage for eligible women from sixty (60) days to twelve (12) months.
These changes will be effective April 1, 2022. Access the full notice here.
IDOH: Updated Abortion Reporting Forms
The Indiana Department of Health (IDOH) recently released updates to three (3) abortion reporting forms to include notarization changes in Indiana Code. Hospitals should ensure they are using the most updated versions of the following forms found below, and all forms can be found on IDOH’s website here.
IHA Distributes COVID-19 HRSA Funds to Participating Indiana Hospitals
The Indiana Hospital Association team distributed the Health Resources and Services Administration’s (HRSA) Federal Office of Rural Health Policy (FORHP) funding through the American Rescue Plan (ARP) for COVID -19 testing and mitigation initiatives. Last week, checks were mailed to the contacts provided by each of the 40 hospitals. If participating hospitals have not received their checks by Feb, 28, please contact Becky Royer.
HRSA awarded the funding to existing Small Rural Hospital Improvement Program (SHIP) grantees. In Indiana, the grantee is the Indiana Department of Health’s State Office of Rural Health (SORH). SORH partnered with IHA to assist with the fund distribution for eligible Indiana rural hospitals and the reporting requirements back to HRSA. The grant is intended to help rural hospitals in increasing COVID–19 testing efforts, expand access to testing in rural communities and expand the range of mitigation activities to meet community needs within the Centers for Disease Control and Prevention (CDC) Community Mitigation Framework. Eligible rural hospitals included those with fewer than 50 beds and critical access hospitals.
