T. Giovanis & Company has pursued a wide variety of engagements on behalf of clients in the following areas:

Legislative

Regulatory

Policy/Design



T. Giovanis & Company, LLC
Health Policy and
Regulatory Consultants

PO Box 130
Highland, Maryland 20777
Telephone: 301.854.2496
Facsimile: 301.854.2248
Email Us

Engagements

EngagementsWe have pursued a wide variety of engagements on behalf of clients.  Examples of these engagements can be categorized into three areas:

 


Legislative

Area Wage Index Strategy

Challenge:

The hospitals in a county were faced with competition for labor from an adjacent Metropolitan Statistical Area (MSA) aggravated by a significant Medicare payment differential.

Result:

We developed and deployed a legislative and regulatory strategy, which resulted in the county’s hospitals receiving $20.0 million per year in increased Medicare payments.

Area Wage Index

Challenge:

Several hospitals were competing for labor with hospitals in an adjacent MSA while receiving substantially less per Medicare discharge due to the use of MSAs that were not modified for changing labor markets.

Result:

When Medicare denied that they had statutory authority, we pursued a legislative change resulting in the creation of a separate Medicare Appeals Board to review such appeals.  We filed an appeal on behalf of the hospitals resulting in an increase in Medicare payments in excess of $1,000 per Medicare discharge.

Special Hospital Status (Medicare Dependent Hospital)

Challenge:

A small rural heavily Medicare dependent hospital was faced with shrinking Medicare payments and non-Medicare volumes with no apparent regulatory remedy.

Result:

We successfully advocated legislation, creating a provision for rate relief.  We then filed the regulatory appeal on behalf of the provider, which resulted in a $1.7 million annual increase in their Medicare payments.


Regulatory

Area Wage Index Strategy

Challenge:

All of the acute care hospitals in a state were faced with a precipitous systematic decrease in their Medicare payments due to the implementation of changes to the hospital labor market areas that affected the hospital wage adjustment.

Result:

We analyzed multiple years of wage data and related that data to emerging Medicare policies. We then crafted and implemented a strategy which significantly increased Medicare payments for all the hospitals in the state while simultaneously developing fallback strategies for 70.0% of the hospitals.  The resultant payments were actually greater than the payments they received before the proposed change.

Wage Data Error Correction

Challenge:

A group of hospitals in a MSA were faced with a decrease in Medicare payments caused by errors in the data used to calculate Medicare’s area wage index.

Result:

We analyzed the data and interviewed the hospitals to ascertain the facts in the situation.  Through research, dialogue with Medicare, and other activities, we were able to develop an approach that resulted in the hospitals getting an appropriate level of payments in a manner that was acceptable to the hospitals and the Medicare program.

Disproportionate Share Hospital

Challenge:

A health system of multiple hospitals was concerned that it was not receiving the appropriate level of its Medicare Disproportionate Share Hospital (DSH) payments and feared that proposed changes would have an adverse effect.

Result:

We analyzed all aspects of the DSH payment at the system hospitals already qualified for DSH, developed a request for increased payments yielding $700,000 for multiple fiscal years, and demonstrated to the providers how to continue developing data needed for future periods.

Special Hospital Status (Sole Community Hospital)

Challenge:

A small hospital was placed at a disadvantage when a hospital located 30 minutes away received Sole Community Hospital (SCH) status.

Result:

We developed a regulatory strategy and related analyses, which was used to pursue SCH status for the target hospital using a unique approach.  This resulted in the hospital being designated a SCH with a significant increase in Medicare payments.

Special Hospital Status (Critical Access Hospital)

Challenge:

A small hospital was faced with decreasing Medicare payments and increasing cost per stay, which threatened the hospital’s existence.

Result:

We performed a review and identified that with only minimal operational changes the hospital would qualify as a Critical Access Hospital (CAH).  We assisted the hospital in applying for and obtaining CAH status with its related increase in Medicare payments and operational flexibility.

Cost Structure Strategy

Challenge:

The Interim CEO of a hospital was faced with cost overruns, the threat of insolvency, concerned employees and medical staff, and the threat of violating the hospital’s bond covenants.

Result:

We advised the Interim CEO on the departments where costs could be cut, implemented ways to improve cash flow, and negotiated with the state agencies and bond rating authorities.  The hospital sufficiently increased its cash flow to meet its bond covenants; the medical staff was co-opted into the process; and the hospital established a long-term strategy towards stability.


Policy/Design

Policy Development/Analysis

Challenge:

All of the specialty hospitals and distinct part units of acute care hospitals were faced with the Medicare program’s development of a new payment methodology that posed the threat of redistributing payments across all industry providers. The national association for the providers engaged us to assist them during this process.

Result:

We analyzed the existing data for all hospitals/units nationally, identified a more rationale payment methodology than the Medicare program was proposing, and advised the association on how best to advocate for provisions in the newly proposed payment methodology, which resulted in the adoption of a more rational payment methodology. We then worked with the association to educate their members about the new system, assisted providers in evaluating how the new system would impact their facilities, and identified the changes to which the providers needed to respond.

Payment System Design

Challenge:

A major professional association was faced with Medicare reform of its payments from a unit rate to a relative value basis, involving $1.5 billion in annual Medicare outlays.

Result:

We successfully developed and advocated a payment methodology with the Medicare program in conjunction with the association’s counsel.

Medicaid Plan Changes

Challenge:

All county owned and operated nursing facilities in a state were faced with reduced Medicaid payments in the wake of a payment system reform.

Result:

We evaluated the structure of the Medicaid plan and county expenditures and then developed a payment system change and corresponding Medicaid plan amendment that created $200.0 million in additional federal matching dollars for the state which were in turn used to support payments to nursing facilities.