HHSC has released the final, new UHRIP rules this week (now called CHIRP). The release also included projections based on data that was submitted last fall. These projections show that rural hospitals will lose about $150 million next year.
There are multiple issues and problems in this rule, but the biggest issue is that rural hospitals need to submit Average Commercial Rate (ACR) data for a computation of the Average Commercial Incentive Award (ACIA) component. We believe this will reduce the loss, but based on the rules, most rural hospitals will lose under CHIRP.
On March 15th, HHSC will release an ACR data request and an application that has a three-week (21 day) application period. This also coincides with the DSH/UC audit deadlines from Myers & Stauffer. Timing is critical, and we will be focusing on the ACR. The main data elements are the total commercial charges and payments (allowable amount) by inpatient and outpatient.
Additionally, the TIPPS enrollment process will also begin March 15th. We are coordinating with several entities to try to provide some relief in meeting all required timelines as they exist currently. HHSC was asked to extend the DSH / UC deadline. They will not extend the CHIRP or TIPPS deadline. We will keep you updated on any developments as they occur.
We have also included a link to more detailed information on the rules, as well as modeling and potential impact of this new program: https://app.box.com/s/dbfwt97qldghl2h4k8dadqb34dhre0d9
For more information, please contact us.
The following information provides some of the basic details:
CHIRP PROGRAM BASICS
The new adopted rule will replace Uniform Hospital Rate Increase Program (UHRIP) beginning on September 1, 2021. This new rule, which will be named, Comprehensive Hospital Increase Reimbursement Program (CHIRP) will be comprised of UHRIP and the Average Commercial Incentive Award (ACIA).
CHIRP is open to six classes of hospitals: children’s hospitals, rural hospitals, state-owned hospitals that are not institutions for mental diseases (IMDs), urban hospitals, non-state owned IMDs, and state owned IMDs. Eligibility for hospitals will now be based upon an individual hospital application, which will allow hospitals to participate even if other hospitals within the same class do not wish to participate. It is important to note that IGT is accumulated and based on each Service Delivery Area (SDA).
The CHIRP program will be made up of 2 Capitation Rate Components:
- The UHRIP Component will be equal to a percentage of the difference between what Medicare is estimated to pay and what Medicaid actually paid for the same services (Medicare gap) on a per class basis. UHRIP payments will be paid as a uniform rate increase per class within a SDA and will be distributed based upon actual paid claims.
- The ACIA Component will be equal to a percentage of the difference between what an average commercial payor is estimated to pay and what Medicaid actually paid for the same services (ACR gap) less payments received under UHRIP. ACIA payments will be paid as a uniform rate increase per class within a SDA and will be distributed based upon actual paid claims.
