Healthcare

We’re gearing up for what’s in store in the healthcare arena in 2017 by attending HFMA’s Mid-South Institute. Attendees from Missouri, Arkansas, Mississippi, and Tennessee have gathered to learn of updates in healthcare and how to embrace for the year ahead. Here are a couple of themes that were reinforced during the conference:

It is important to recognize that the road to long-term success does not end with the implementation of the Merit-based Incentive Payment System (MIPS). In CMS’ own words, MACRA’s final rule was established, in part, to incentivize and promote participation in Advanced Alternative Payment Models (APMs). These incentives include a 5% participation bonus from 2019 to 2024 and a 0.5% annual increase above the MIPS track beginning in 2026.

Like it or not, MACRA is here. MACRA created the new Quality Payment Program (QPP), comprised of two pathways to higher quality: the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs). MACRA changed the rules, leaving many to face an uncertain future. Amid the uncertainty, however, one thing is sure: passivity will be costly. Indecision will not prevent or delay physician’s placement into the quality and efficiency compensation measurements of MIPS.

Wait-and-see is no longer a viable strategy for payment reform—especially with regard to MACRA implementation.

In my 30 years serving healthcare practices, I have seen innovations come and go. I certainly understand the impulse to sit back and let the dust settle before rushing to implement a new regulation, and the steady Republican drumbeat of “repeal and replace” is enough to give any provider pause.

January 20 is a significant date for healthcare providers—but not necessarily for the reason you think.

Yes, there is the inauguration of the 45^th President of the United States, who has vowed to “repeal and replace” the most significant healthcare legislation in recent history.

But that date has even greater significance for the many providers across the country who are struggling to cover the cost of care of an increasingly high-risk, low-income population.

Living in interesting times may be a blessing or a curse, but 2016 proves that it certainly isn't boring. Healthcare in the United States continues to evolve—sometimes very rapidly—and those guiding healthcare organizations have particular challenges ahead of them in the coming years.

Last week, I had the privilege of attending the Health Care Advisory Board’s National Meeting in St. Louis, Missouri. One of the topics that really struck me was the last presentation about the importance of building a consumer-focused organization and increasing consumer loyalty.

I've just returned from the National MACRA MIPS/APM Summit in Washington, D.C., where the overarching discussion centered on how to create and implement strategies that pay physicians fairly, while controlling spending in the Medicare program. It's a question we've wrestled with for almost 20 years and a challenge we must solve.

We described in the previous installment in this series how recent case law and DOJ settlements provide clear evidence of the position of qui tam relators, prosecutors, and government experts that losses on hospital operation of physician practices are being targeted. Because evidence suggests that hospital losses on physician practices are common in many markets, the questions on everyone’s mind are whether health system losses on physician practices put the organization and key individuals at significant fraud and abuse compliance risk, to what degree can existing physician practice losses be justified through documentation, whether the health system has a functional Fair Market Value (FMV) and Commercial Reasonableness (CR) enterprise risk management process, and—the subject of this series--is a plan at the ready to begin mitigating practice losses?

Virtual healthcare is a godsend to struggling healthcare systems as they try to offer the right care in the right setting. Every day, these systems face enormous pressure to provide both high-quality and cost-effective healthcare to their communities. Their clinics are filled with scheduled patients, while others wait for a “work in.”

Recent DOJ settlements provide clear evidence of the position of qui tam relators, prosecutors, and government experts that hospital losses on physician practices are clearly targeted. For example, in U.S. ex rel. Parikh v. Citizens [No. 6:10-cv-00064 (S.D. Tex.)], the court denied the defendant hospital’s motion to dismiss in part because of an inference between the plaintiff’s allegations of practice losses and improper remuneration to induce referrals.

A big news item in healthcare is CMS’ recent release of the MACRA Final Rule, which articulates CMS’ future direction for Medicare Part B. With the Final Rule, CMS makes clear the following strategic objectives in developing MACRA’s new Quality Payment Program (QPP):

In our earlier blogs on the MACRA Final Rule with Comment Period (Final Rule), we have been discussing a series of topics from the Final Rule, especially those with changes since the Proposed Rule earlier this year.

MACRA created the new Quality Payment Program (QPP), comprised of two avenues to reward delivery of high quality care: the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs). After the May 9, 2016 release of the Proposed Rule, the feedback on the imminence of the MIPS implementation was less than fully supportive. On September 8, CMS’ Acting Administrator, Andy Slavitt blogged about the agency’s new flexibility with respect to the implementation of MIPS, and the “Pick Your Pace” moniker made it to the Final Rule, published earlier this month.