
Maryland in a Minute – September
September 22, 2026The Health Services Cost Review Commission (HSCRC) held their October meeting on October 21, 2026. The following statewide reports and recommendations were reviewed by the commission:
Assessment Changes Under Split Global Budgets – Draft Report
Beginning in January 2028, The Centers for Medicare and Medicaid Services (CMS) will assume hospital rate-setting for Medicare Fee-For-Service (FFS) payments, referred to as Medicare FFS hospital global budgets (Medicare HGBs). The HSCRC will maintain global budget revenue for all other payers (Multi-payer GBRs).
Commissioners reviewed a proposed plan by staff for determining assessments (e.g., HSCRC User Fees, Nurse Support Programs I & II, MHCC User Fees) under this new system. Staff noted that a portion of these assessments will be included in the Medicare HGBs under this new system. Their plan to determine assessments going forward will be:
- Determine the percent of FFS revenue associated with each assessment included in the base year for Medicare FFS.
- In the following year, take the FFS value from the previous year and inflate that value by the inflation applied to Medicare HGBs for a hospital.
- The value from #2 is then reduced from the total assessment value for the current year (as determined under the relevant process for that assessment) to determine the value to be assessed on the Multi-payer GBRs.
- Repeat the process every year thereafter to determine the appropriate FFS split.
Some future considerations noted for this process:
- Significant shifts in the multi-payer share versus Medicare FFS may require commission discussion. For example, if Medicare funding levels are growing slower than commercial payments, then steps must be taken to ensure fairness to commercial payers.
- Future Medicare Advantage and Medicaid growth is subject to certain limits in relation to Medicare and may also affect the overall Multi-payer GBR proportion.
- Any new assessments will have to be based on the Multi-payer GBRs, as the HSCRC will not have the authority to base new assessments on the Medicare FFS population.
- Medicare HGBs will operate on a calendar-year basis, so FY2028 will span two different rate payment systems (7/1/2027 to 12/31/2027 and 1/1/2028 to 6/30/2028).
Bridge Adjustment – Draft Recommendations
As part of the transition process to the Medicare HGBs and Multi-Payer GBRs in 2028, CMS approved a “bridge adjustment” for performance years three through five (2028-2030). During these years, the HSCRC can redistribute a portion of the Medicare HGB to other hospitals. The amounts decrease each year, with 30% in 2028, 20% in 2029, and 10% in 2030. The total redistributed amount must be net neutral.
One component of the Medicare Hospital Global Budget (HGB) policy is the “repricing adjustment,” which compares hospitals’ actual Medicare payments with what they would have received under national Medicare Fee-for-Service (FFS) rates. Hospitals in the highest quartile of this payment ratio receive a downward adjustment, while those in the lowest quartile receive an upward adjustment.
The staff asked the commissioners to consider two options:
Option 1: Apply a bridge adjustment to spread the aggregate difference between the current state GBR Medicare FFS payments and the Medicare GBRs across all hospitals as weighted by a factor such as overall state weighting of current Medicare FFS payments to Medicare GBRs. This would have the effect of redistributing the state-level difference between the two budgets proportionally.
Option 2: Create a pool of bridge funding from hospitals with a Medicare HGB higher than their current Medicare FFS revenue. A percentage with a threshold would be applied to move revenue from these hospitals to those with a lower Medicare HGB as compared to current Medicare FFS revenue.
Staff are now seeking this guidance from commissioners, as final guidance and budgets from CMS may not be available until late 2027. This will lead to a tight timeline for implementation for the second round of rate setting in FY2028.
Additionally, staff recommend:
- The bridge adjustment be applied to global budgets as a whole, or the repricing adjustment only, rather than identifying specific adjustments to which the bridge adjustment will be applied.
- The state weight be set as a range and the specific weight be determined when finalized Medicare HGBs are available. This state weight would be defined as the relative weight of the state-defined Medicare HGB and a corresponding weight on the CMS-defined Medicare HGB. This would need to decrease with each progressing year, with 2031 being 0%. Ranges would be 50% – 85% for 2028, 25%-65% for 2029, and 0% to 35% in 2030.
Final recommendations will be brought forward to the commission in February 2027.
Quality Based Reimbursement – Draft Recommendations
These rate year 2029 draft recommendations are minimally changed from the rate year 2028 final policy. That policy prioritized alignment of the state Quality-Based Reimbursement (QBR) program with the CMS Hospital Value-Based Purchasing (HVBP) program that will be applicable for patients of all other payers (Multi-payer GBR payers).
- Maintain domain weighting as follows for determining hospitals’ overall performance scores: Person and Community Engagement (PCE) – 38 percent, Safety (MHSN measures) – 31 percent, Clinical Care – 31 percent.
- Continue to hold two percent of inpatient revenue at-risk (rewards and penalties) and set the revenue adjustment scale from 0 to 80 percent with a preset cut-point at 32 percent. Retrospectively evaluate the preset cut-point using more recent data to calculate national average score for rate years 2027 and 2028.
- Continue collaboration with CRISP and other partners on infrastructure to collect hospital Electronic Clinical Quality Measures (eCQM) and Core Clinical Data Elements (CCDE) for hybrid measures. Add a bonus incentive of $150,000 in hospital rates for hospitals that fully meet the state-specified expedited reporting timeline, provided that all required measures are reported.
- Transition the ED and Hospital Throughput Policy to a Learning Collaborative designed to engage stakeholders to identify best practices to address emergency department and hospital throughput, care transitions, and capacity alignment across the care continuum.
Final recommendations will be brought to the commission in December 9, 2026.
Past and upcoming HSCRC meeting information can be found here. Next meeting of the HSCRC will be held on November 10, 2026. Note this is on a Tuesday since the second Wednesday of the month is Veteran’s Day.
Maryland Agencies Coordinate Efforts to Address Medicaid and SNAP Changes
Maryland health and human services agencies are collaborating with community partners to help residents navigate federal Medicaid and SNAP eligibility changes under H.R. 1. Beginning January 1, 2027, approximately 320,000 Maryland Medicaid recipients will face new work and community engagement requirements and twice-annual eligibility renewals. State officials estimate that up to 152,000 residents could lose coverage. Coordinated outreach, streamlined renewal processes, and expanded educational resources are among the initiatives underway to help eligible Marylanders maintain benefits.
Maryland Announces $25 Million to Expand Health Care Access for Uninsured Residents
Governor Wes Moore announced $25 million in Uncompensated Care Grants to support community-based health care services for uninsured Marylanders. Administered by the Maryland Health Care Commission, the one-year grants will support federally qualified health centers and eligible local health departments in providing primary care, chronic disease management, acute care, and behavioral health services. The initiative aims to improve access to essential health services and reduce avoidable emergency department utilization.
Upcoming Events – Register Here!
- 11/4-11/6/2026 2026 Women in Healthcare LeadHERship Summit, Executive Panelists, President, Charlotte L. Kohler, [RN], CPA, CVA, CRCE, CPC, CPCO, CEMC, speaking on 11/5/26, Hotel ZaZa Museum District, Houston, TX 77005
- 12/9/26 12:00 – 1:00 pm 2027 CPT Updates: Putting the Pieces Together, Manager, Heather Dunlap, CPC, CDEO, CEMC, CRC, CHONC, Webinar, Register Here!
MD HFMA Calendar – Maryland Healthcare Financial Management Association
- 11/16/2026 10:00 – 11:00 pm Region 4 HFMA Webinar – 340B Program Updates, Register Here!
- 11/17/2026 5:00 – 8:30 pm Maryland HFMA Women in Leadership Annual Fall Dinner 2026, The Center Club 100 Light Street Baltimore, MD 21202, Register Here!
MAHQ Calendar – Maryland Association for Healthcare Quality
- 11/20/26 12:00 -1:00 pm From Insight to Impact, using Data Analysis to Improve Patient Experience, Cheri Hahn, RN, MS, CPHQ, CPPS, Director of Quality and Patient Safety, Register Here!
- 12/8-12/10/26 9:00 – 1:30 pm, Build Your Healthcare Quality Expertise: CPHQ Review Course, Register Here!
- 12/18/26 12:00 -1:00 pm Leveraging Your Influence, Katrina Coleman, BSN, MSN, Leadership & Engagement Strategist, MHEI, Register Here!
MHA Calendar – Maryland Hospital Association
- 11/10/26 1:00- 4:30 pm HSCRC Commission Meeting Public Meeting
MHEI Calendar – Maryland Healthcare Education Institute
- 11/05/26 8:30 – 12:30 pm Virtual Training – Maryland OHCQ Update, Register Here!
- 11/12/26 11:00 – 12:30 pm Virtual Training – Coaching Staff, Register Here!
- 11/19/26 12:00 – 1:00 pm Virtual Training – Legacy Mapping Workshop, Register Here!
Connect With Us
We’re committed to supporting your success. If you have any questions or need guidance, don’t hesitate to contact us at re******@******hc.com. Learn more about our healthcare consulting, interim support, regulatory readiness, workflow optimization, risk management, and advisory services.
Need Expert Healthcare Guidance, Without a Large Consulting Engagement? Kohler HealthCare Consulting’s Advisory Assistance Program provides on-demand access to experienced healthcare consultants for compliance, coding, regulatory, operational, quality, and accreditation questions. Get timely, expert guidance to support informed decision-making, reduce risk, and address complex challenges, without the commitment of a large consulting engagement. As********@******hc.com


