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HFMA Comments on the Proposed Rule on the Medicare Shared Savings Program
HFMA commended CMS for its efforts to modify the Medicare Shared Savings Program (MSSP) to ensure its sustainability. However, HFMA had specific recommendations for improvement.
Determining Your Options: Educating Your Board
It is essential to keep your organization's board of directors up to date on your organization's current situation, capabilities and needs, and potential options for acquisition or affiliation. As you narrow in on the most viable options and partners for your organization, the PowerPoint template tools below outline key elements of your proposed course of action that should be shared with the board. Options are provided for proposals involving both less than fully integrated and fully integrated acquisition and affiliation models. Tool: Educating Your Board: Less than Fully Integrated Models Tool: Educating Your Board: Fully Integrated Models Go to Next Page Home
Medicare Shared Savings Program Proposed Rule Fact Sheet
This fact sheet summarizes proposed changes by CMS that would update policies governing the Medicare Shared Savings Program.
Price Transparency for Health Plans
Because health plans will in most instances have the most accurate data on prices for their members, HFMA’s Price Transparency Task Force recommends that health plans serve as the principal source of price information for their members. Many health plans have already developed or are in the process of developing web-based or telephonic transparency tools for their members. There are also a growing number of independent vendors that use data from health plans and/or employers in web-based tools and telephonic products to inform employees about price.
HFMA Summary of IRS 501(r) Final Rule
This summary outlines the provisions of the IRS final rule providing requirements for charitable hospital organizations added by the Affordable Care Act.
Value-Based Reimbursement Resource
This too contains useful information on CMS's Value-Based Purchasing Program and other initiatives that will help improve the quality of care in hospitals.
CY15 OPPS Final Rule Fact Sheet
This fact sheet highlights payment rate updates under the OPPS for CY15.
A Closer Look at a Health System’s Strategic Options
An example of the evolving physician strategy of a health system with a clinically integrated network is shown below: Manage the mix of independent and employed relationships. Rationale: The right mix varies depending on the hospital, market and service, even within a highly aligned, integrated system. Failure to balance and coordinate incentive structures and approaches between independent and employed physicians is a threat to the system. Create financial and non-financial incentives for independent and employed practices to reduce leakage out of the system. Rationale: Keep all elements of the CIN moving forward at roughly the same pace with respect to the journey from fee-for-service to value-based payment. Accept specialty facilities and specialists back into the system. Rationale: It is becoming less attractive for specialty centers to remain independent, and it behooves the system to work out a path for them to move from competitor to ally. Some of these specialists are particularly good, and the system does not want them going to a competitor. Also, since the system’s payments are still significantly fee-for-service, these specialists create profits that can be re-directed to strengthen the financial base. Use changes in physician relationships to manage the physician/patient ratio. Rationale: The greatest cause of “excessive” investments in employed physician practices is a shortage of patients per physician. For example, some employed physicians place restrictions on their schedules that hinder filling them with patients. Also some employed specialists have too few patients because they don’t have enough referrals from independent physicians in their service area. Continue to adjust employed physicians’ compensation packages as the ratio of value-based to fee-for-service revenues changes. Rationale: Relying on leadership is not enough; compensation has to remain aligned.
A Closer Look at a Medical Group’s Strategic Options
The independent medical group has several options regarding its future strategy. Indeed, many groups pursue more than one strategy at once. Here is an example of a single specialty orthopedic group’s strategy: Merge with a (formerly) competing orthopedic group. Rationale: cover more geography, enable the group to support a sports medicine practice, enable the group to have its own rehabilitation group, support more hospitals more effectively, support a stronger professional management team, and support additional orthopedic sub-specialization. Initiate a bundled payment initiative. Rationale: learn (along with a partner health system) to manage all elements of the care process in a value-based payment environment, and gain additional revenues once successful. Integrate IT approaches with as much as possible of the referral base (including EHR, decision-support, and other elements). Rationale: an essential step in accomplishing the other elements of the group’s strategy, with the potential to reduce the group’s total IT costs. Provide leadership in developing a CIN. Rationale: expand and shore up key parts of the group’s referral network, lead the development of an integrated approach to care management for the group’s patients (including total joints, trauma, and other areas), influence the development of the CIN’s funds flow and compensation models, and influence the alliances and other relationships developed by the CIN. Together, the orthopedic group’s strategies seek to make the transition from fee-for-service to value-based payments, to enhance short-term revenues and market position, and to make the group more successful in recruiting.
Clinically Integrated Networks
Overview. The clinically integrated network (CIN) is an increasingly preferred alignment option. First, it allows employed and independent physicians to develop and implement a full range of coordinated approaches. Second, it allows combinations into larger groups—for example, one health system’s CIN can work with another system’s CIN, or with a larger independent CIN—creating a still larger group that will be more cost effective in achieving population health management. The underlying principle of the CIN is that it enables more effective, coordinated care, and that this is better for the patient. One of the strongest appeals of the CIN is its flexibility. CINs can include many forms of hospital-physician models—academic practice plans, employed physician groups, independent physician groups—as long as they adhere to legal requirements of a CIN. CINs increasingly include the full range of care options, including pre- and post-acute services. In order to fulfill the legal requirements of a CIN, the network must develop and follow common approaches to delivering care (for example, for chronically ill patient populations). A discussion of the legal requirements for CINs is available in HFMA’s Acquisition and Affiliation Strategies Value Project report. Need to insert graphic Organizing services within a CIN. Many CINs begin by organizing care into major service areas. Teams are organized under the CIN’s governing body. These are typically comprised primarily of physicians and advanced practice clinicians, but also may also include the broader care continuum (including pre-and post-acute care services). They are often under the management of a dyad leadership—the chief medical officer for the CIN, for example, will be paired with an administrative leader. Tool: Organizing a CIN by Service Area Common quality and cost emphases for CINs. High cost points in care transitions include readmissions to hospitals and leakage from the CIN. Special task forces or teams are often assigned to address these issues. After the CIN has been in place for a time, the network often identifies selected populations that are disproportionately expensive and could benefit from targeted approaches. Example segments that are being targeted for special approaches include: Chronic or intensive care groups, such as cancer and cardiac patients that benefit from targeted multi-disciplinary teams in a specialized setting The sickest of the sick, who can benefit from targeted care through specialized extensivist or ambulatory intensivist services that provide better care and help avoid inappropriate hospitalization Multiple diagnosis patients, such as patients with six or more diagnoses who also may be treated best by a multidisciplinary team in an ambulatory setting Homebound and nursing home patients, who may benefit from mobile care. The precision with which these populations are identified and cared for on an ongoing basis is improving through techniques such as predictive modeling.