Need another resolution for 2019? Probably not, but we have one for you anyway, and it’s important. We’re counseling our safety-net clients to pay closer attention to what’s going on with CMS.
Here’s why: The agency has been making regulatory changes, from efforts to reduce the paperwork burden on providers to improving patient access to health data. Some of these could have an impact on both workflow and revenue.
In addition to the specific changes we’ll discuss in a moment, we’re seeing some concerning trends. For example--are you keeping an eye on MACRA? FQHCs, of course, are not (yet) required to follow MACRA. This could change: Altruis monitors regulatory developments, and we’ve seen a gradual convergence of HRSA and MACRA standards. This suggests a desire on the part of CMS to move all providers to the same standard.
Obviously, FQHCs have been resisting this because of the added regulatory and reporting burden, but it’s not something they can ignore. No one knows how it will play out.
What follows is a brief overview of some changes underway at CMS and how they could--or will--affect your practice and your revenues.
Patients Over Paperwork
In late 2017, CMS launched the Patients Over Paperwork(POP) initiative to reduce paperwork and red tape, giving physicians more time to spend with patients.
If it succeeds at its goal, it will be a much-needed reform. Each year, the agency releases roughly 11,000 pages of regulations. Hospitals, health systems and post-acute care providers spend nearly $39 billion annually on administrative activities related to regulatory compliance, according to an American Hospital Association study.
The POP initiative incorporates an array of projects and changes, some of which will likely reduce provider burden. For instance, a rule issued in September would eliminate several monitoring and reporting requirements. Some of the changes are relevant to safety net providers. It would:
- Remove the duplicative CAH ownership disclosure requirement;
- Require only biennial (vs. annual) review of policies and procedures for CAHs, RHCs and FQHCs;
- Relax the 30-day assessment requirements for those Community Mental Health Centerclients who receive partial hospitalization program services.
A Renewed Rural Focus
An initiative closely related to POP, Meaningful Measures, is designed to reduce the administrative burden of reporting requirements across all CMS programs. It plans to do this by focusing on only 19 that it deems “core issues that are the most critical to providing high-quality care and improving individual outcomes.”
It’s guided by six criterial, including eliminating disparities and improving access for rural communities. CMS is tying this into its Rural Health Strategy, announced in May 2018. Among other things, it promises to a “rural lens” to programs and policies and improve access to care through provider engagement and support.
Medicare Fee Schedule--Some Good News
POP’s impact can also be seen in the new Medicare Fee Schedule, released Nov. 1. It sets forth how Medicare Part B practitioners will be paid, and it will affect FQHCs in several ways. In particular, it has the potential to enhance FQHCs’ ability to provide comprehensive services and care management to their Medicare patients.
For example, CMS will recognize and pay two newly defined physician services: virtual check-in and remote evaluation of recorded video or images submitted by an established patient. “Patient access to care will improve as a result,” AAFP President John Cullen, MD, said in a prepared statement. “This will enhance access to timely patient care, particularly for those who struggle with transportation barriers.”
We see this as part of a recent trend of Medicare paying FQHCs for certain new types of care through discrete payments--similar to what physicians would receive outside of the FQHC PPS rate.
The fee schedule was to include changes to E/M documentation, but--after criticism from some physicians and provider groups--CMS has delayed implementation until 2021.
That’s really just around the corner, and it makes sense to start preparing in 2019. Few FQHCs review their E/M coding, and many don’t code encounters correctly--totally understandable, given the different reimbursement model, but risky nonetheless. But as HRSA increases its focus on self-sustainingrevenuegeneration, clinics may be forced to change.
Even today, proper documentation makes sense. Grants are based largely on visit type. Failing to code correctly could lead to lost money.
Patient Access to Data: Not Just Nice to Have
Another initiative, unveiled at HIMSS 2018, is called MyHealthEData. Among its goals:
- Give patients control of their medical information and
- Give physicians visibility into a patient’s complete medical record.
CMS proposes plans to use MACRA incentives to reward the sharing of healthcare data securely with patients and their providers.The initial focus is on hospitals, but we expect that to expand.
Eventually, it may become an issue for FQHCs and other safety net providers. Given the variety of services FQHCs and CAHs offer, supporting appropriate documentation--not to mention workflow requirements--would be a challenge even with the best EHR system. But that’s not what most safety net providers have.
Health centers often have patient portals that don’t work adequately or are under-utilized by patients. But giving patients access to their health records continues to be an HHS priority, one from which FQHCs will not be exempt. Those portals need to be up to speed: Centers could eventually face penalties if they’re not.
A Renewed Focus on RCM
In this changing landscape, safety net providers need revenue-cycle management (RCM) services that fit their specific situations. The best RCM services involve an active collaboration between the care provider and the service provider.
Centers, practices and CAHs will also need resources that understand the requirements of both HRSA and MACRA to optimize RCM strategies. They need a partner who understands the nuances of what should be billed and how.