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Healthcare Reform Repeal – Is the 37th Time a Charm?

Posted on May 17, 2013 by Linda Ringquist

Summary: Well here we are again – the 37th time to be exact. The House of Representatives is working diligently to healthcare reform 3repeal the PPACA in its entirety.

Well, you have to hand it to the House of Representatives. They are quite persistent. This is the 37th time an appeal of the Patient Protection Affordable Care Act (PPACA) aka Obama Care aka Healthcare Reform has gone before the House of Representatives. As of yesterday, yet another vote was held and the results were 229-195 in favor of the repeal.

In favor

House Speaker John Boehner was quoted “A full repeal is needed to keep this law from doing more damage to our economy and raising healthcare costs. It’s going to raise the price of health care, raise the cost of health insurance, reduce access to the American people and continues to get in the way of employers hiring new workers”.

Opposed

Opposition to the repeal comes from Representative Steny Hoyer “Apparently the Republicans are opposed to Obamacare. I know that comes as a shock to America, so we need to tell them one more time. Or 37 times, or maybe 38th or a 39th or a 40th or a 100th time”.

House Minority Leader Nancy Pelosi stated “Americans want Congress to focus on creating jobs. Instead we are wasting time once again on the healthcare reform 4Republican repeal of the patients’ rights”.

The White House has stated point blank that this will never pass.

Appeal #36

As you may recall, the PPACA repeal was last voted on in 2012. The crux of the issue was the mandate which required all Americans to carry health insurance. This is still a hot topic and one which continues to be debated.

Where do we go from here?

The PPACA is of major concern at this juncture as this will have a major effect on the next Presidential election. It seems to be more about which party has a majority in a tug of war than about the actual legislation itself. To move forward with an all or nothing motion seems time consuming and an expensive proposition. So, where do we go from here?  What if we took a few sections/related topics at a time and worked to repeal rather than the entire legislation? List out the topics which are of controversy, prioritize, and appeal in a structured logical fashion. This would provide an avenue to address the most important aspects and smaller wins might provide a sense of accomplishment.

What do you think?

Are you in favor of the PPACA? Do you think it should be repealed? Do you think it should be repealed in pieces? Do you think too much opiniontime, money, and effort are being dedicated to this cause?

About BHM Healthcare Solutions

BHM is a healthcare management consulting firm whose specialty is optimizing profitability while improving care in a variety of health care settings. BHM has worked both nationally and internationally with managed care organizations, providers, hospitals, and insurers. In addition to this BHM offers a wide breadth of services ranging including managed care consulting, strategic planning and organizational analysis, accreditation consulting, healthcare financial analysis, physician advisor/peer review, and organizational development.

Contact Us :  results@bhmpc.com, 1-888-831-1171

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Posted in Health Care Reform | Tagged BHM Healthcare Solutions, Healthcare Financial Analysis, Healthcare Management Consulting, Healthcare Reform, Obamacare, Physician Advisor, PPACA | Leave a comment

Giving Away Dollars, Does it Make Sense

Posted on May 16, 2013 by Danyell Jones

capital money

Obama Announces New Incentive Program for Healthcare Innovation

The Money Is On the Table

The Obama Administration announced yesterday that they will be kicking off an initiative to provide funding for “innovations” in federal healthcare programs which cut costs and improve patient outcomes.  As reported by Devin Dwyer the initiative will “reward the most “compelling new ideas” for lowering costs and improving care through the utilization of lucrative federal grants.  Specifically the money will be utilized to award projects that conduct testing and/or utilize new payment and delivery models.  The government is looking to discover programs which are able to quickly and effectively cut healthcare costs.  But many are questioning the efficacy and rationale behind this initiative.

  • The Application period will run from June 14 to August 15
  • Projects must be able to be implemented within six months to qualify for funding
  • Special consideration will be given to project which generate jobs
  • Selected Projects will be announced in March 2013

This Isn’t the First Time, and the Results are Questionable

In fact this isn’t the first round of federal grants awarded for Healthcare Innovation.  A round one kick off of Health Care Innovation Awards occurred in May and June 2012 with 107 organizations receiving between $1 million dollars and $30 million dollars per “innovative” initiative.  But some of the initiatives, while aimed at improving healthcare, do not appear to be expected to yield savings.  Here is a snapshot of entities who received grants which are in excess of the expected savings they are going to produce

Organization Funding Received Estimated Savings
Christiania Care Health System $9.9 million $376,327
Denver Health and Hospital Authority $19.7 million $12.7 million
Family Service Agency of San Francisco $4.7 million $4.2 million
George Washington University $1.9 million $1.7 million
Lifelong Medical Care $1.1 million $1.1 million
YMCA $11.8 million $4.2 million
South County Community Health Center $7.3 million $6.2 million
Trustee of the University of PA $4.8 million $2.7 million
University of Arkansas $3.6 million $1.2 million

There are many projects which do anticipate yielding large savings vs. the amount invested, but an overall look at the viability of this largely experimental incentive plan warrants examination.  In fact, according to CMS in their project profile document “project data (e.g. gross savings estimates, population served, etc.) are three year estimates provided by each organization…[and] while all projects are expected to produce cost savings beyond the three year period, some may not achieve net cost savings until after the initial three year period..”

Though certainly the data does not reflect a net savings for each project vs. what the initial funding amount was (click here for the full CMS report) and some opponents of the initiative question the efficacy and the aims.

Is the Issue about Healthcare Innovation or Job Creation?

Some have questioned whether the incentives are around Healthcare Innovation, or a governmental push for job creation.  Indeed, those applicants who address job creation are favored during the submission phase for round two, but let’s take a look at the amount awarded and the jobs created.  In fact, the announcement of the upcoming initiative was couched as part of Obama’s “Can’t Wait” campaign, and slated an emphasis on job creation, though round one of the Innovations in Healthcare grants produced less than stellar results, and even these are tentative based on estimates.

Funding Granted in Round One: ~$893 Million Dollars

Estimated Jobs Created Through Funded Projects:  2,723.82 (thousand)

Cost per created job: $327,947

The verdict is out on whether this push for federal funds marked toward improving efficacy, efficiency, and care in the newly shaped healthcare arena will prove beneficial, or, is just as one republican critic called it, a “$1 billion dollar experiment”

We would love to hear what you think, send us an email at newideas@bhmpc.com or connect with us on Linked In!

 

 

 

 

 


Posted in Health Care Reform, News and Events | Tagged $1billion dollar grant, ACA, Affordable Care Act, Health care innovation award, Healthcare, healthcare innovation, healthcare innovation grant, Obamacare | Leave a comment

Why There Will Be A Shortage of Doctors With Obamacare Infographic

Posted on May 8, 2013 by Linda Ringquist

It is evident that there will be a shortage of physicians. We have a shortage now. So, we are going to expand Medicaid and potentially have an extremely large number of additional lives that could be covered. This new group, while not all of course, but a good number are going to visit a doctor for the first time or the first time in a long time. Additionally, the exchanges will be implemented in full force adding another group of eligible consumers. How are we going to be able to treat this huge influx? These are just the new issues. We still have an aging population who require additional care.

2014 is going to a very tenuous year for healthcare in terms of supply and demand.

 

Why There Will Be a Shortage of Doctors with ObamaCare

About BHM Healthcare Solutions

BHM is a healthcare management consulting firm whose specialty is optimizing profitability while improving care in a variety of health care settings. BHM has worked both nationally and internationally with managed care organizations, providers, hospitals, and insurers. In addition to this BHM offers a wide breadth of services ranging including managed care consulting, strategic planning and organizational analysis, accreditation consulting, healthcare financial analysis, physician advisor/peer review, and organizational development.

Contact Us :  results@bhmpc.com, 1-888-831-1171

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Posted in Financial, Health Care Reform, Health Insurance | Tagged BHM Healthcare Solutions, Healthcare Financial Analysis, Healthcare Management Consulting, Physician Advisor | 3 Comments

Preliminary Results As to the Effects of Medicaid Expansion Under the ACA

Posted on May 8, 2013 by Linda Ringquist

Summary: Preliminary studies show mixed results in terms of costs/usage and diagnosis/treatment as a result of Medicaid Medicaidexpansion.

The Patient Protection and Affordable Care Act (PPACA) is a comprehensive healthcare reform act which provides regulation for items such as Medicaid expansion, the creation of health insurance exchanges (marketplaces), clarifying and simplifying health insurance claim denials processes, creating Accountable Care Organizations (ACO)s, removing health insurance barriers such as lifetime limits and pre-existing conditions, and restructuring the methods in which physicians are paid for their services. This is not an all-inclusive list but rather just a few examples as to the topics included in the PPACA.

As of January 1, 2014, Medicaid expansion will become effective. It is interesting to note that individual states have the option to elect to expand Medicaid or not, as each state operates its own Medicaid program. Those that elect to expand will have the federal government pick up the tab for the first 3 years at 100% of the costs incurred. After 3 years, the amount of the federal portion will drop to 90% and foreseeably continue to drop thereafter.  As of today, 18 states and the District of Columbia have elected for expansion, with a possibility of more in the coming months. The expansion involves increasing access to Medicaid for Americans who earn less than 133% of the poverty level which translates to about $15,000 for 2014. There are higher limits for families.

What is the outlook for Medicaid? Certainly more Americans will qualify for Medicaid, but will more Americans take advantage of their new medicaid3coverage options? Will there be an influx of newly eligible consumers rushing to setup doctor visits? Will there be a significant increase in healthcare spending? Will better data be available in terms of diagnosis and treatment of certain health issues?

A couple of studies have been conducted in Oregon which delve into some of these issues to arrive at results which may serve as predictors as to what we can expect. The study included a comparison of a select group of about 10,000 consumers who had access to Medicaid through a lottery system as compared to a select group who did not and was conducted over a 2 year period. The results indicated an increase in doctor’s visits, more money spent on healthcare, and more hospital visits. The health effects were mixed. No strides were made in terms of levels such as blood pressure and blood sugar, however this group did show reductions in the prevalence of depression and brought about feelings of increased financial security. Additionally, no significant changes to the diagnosis of hypertension or cholesterol were made. On the positive side, the probability that diabetes and depression would be detected were significant and noteworthy.

Is Medicaid expansion a good thing? Absolutely. Will there be higher healthcare costs incurred? Absolutely. Will the expansion begin with addressing healthcare issues and then lead to preventative in this group? More than likely. There will be significant costs occurred in the initial years following the expansion but should begin to decrease thereafter.

What are your thoughts on Medicaid expansion? Do you think these decisions should be decided upon by individual states? Do you think theremedicaid4 will be an influx of Americans taking advantage of their newly eligible status? Do you think the paperwork required will preclude many in this group from participating?

About BHM Healthcare Solutions

BHM is a healthcare management consulting firm whose specialty is optimizing profitability while improving care in a variety of health care settings. BHM has worked both nationally and internationally with managed care organizations, providers, hospitals, and insurers. In addition to this BHM offers a wide breadth of services ranging including managed care consulting, strategic planning and organizational analysis, accreditation consulting, healthcare financial analysis, physician advisor/peer review, and organizational development.

Contact Us :  results@bhmpc.com, 1-888-831-1171

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Posted in Financial, Health Care Reform, Health Insurance, Healthcare Prevention | Tagged BHM Healthcare Solutions, Health Insurance Claim Denials, Healthcare Financial Analysis, Healthcare Management Consulting, Physician Advisor | 1 Comment

So, How Is President Obama Doing on His Campaign Promises?

Posted on May 6, 2013 by Linda Ringquist

Summary: What promises were made during the Presidential campaigns? Which promises are falling by the waste side?obamameter

The thing about campaign promises are many of them are empty promises – promises either have no intention of being filled or are not able to be filled due to unforeseen circumstances. Sorting these situations out can be a daunting task. But in the end, does it really matter? The bottom line is the promises go unfulfilled. To fulfill one promise may mean breaking yet another.

Let’s start with healthcare affordability, one of the pillars of The Affordable Care Act “ACA”. The goal was to provide more affordable health insurance to more Americans. Everything that has come out recently regarding the health insurance exchanges points to a significant increase in premiums. Increases in premiums will cause more Americans to be uninsured not less. Additionally, you will be spending more to receive less. A higher premium price tag also equates to higher deductibles and higher out of pocket limits.

How about the national deficit which is now in the trillions? Promises were made to cut back spending and without affecting programs such as Social Security. It seems now that cost of living will be affected negatively.

Let’s talk about the sequestration for just a moment. It was supposed to be a cross the board spending cut. Medicaid was supposed to be exempt from the cuts but certain Medicaid indices are tied to Medicare rates which were part of the sequestration. So, perhaps Medicaid wasn’t directly affected but it was certainly indirectly impacted. Some of these broken promises are masked or hidden to the extent that it isn’t apparent to the average American. Keep in mind that programs such as Medicare, Medicaid and Social Security were not supposed to be affected

Tax increases were originally promised for primarily the wealthier Americans – singles earning in excess of $200,000 and families earning in presidential campaignexcess of $250,000. The income levels which were affected were singles earning in excess of $400,000 and families in excess of $450,000. It now appears that other levels of income will be affected with tax hikes as inflation measures are being examined.  Undoubtedly, tax increases are coming which will affect most if not all Americans either directly or indirectly.

A promise was made to create over 1 million manufacturing jobs by 2016. If the current pace continues, we will have created less than 500,000 manufacturing jobs. This one I think was more of an exaggeration than anything. When making a promise, it is more powerful to use a “1 million” number rather than a mere half a million. Nonetheless, it is another promise that will in all probability go unfulfilled.

How about education? Promises were made to increase graduation rates for both high school and college. However, one of the areas cut through the sequestration was education and funding to teaching hospitals and medical schools. How do you promote education and cut funding at the same time?

The campaign process is a game. Tell the people what they want to hear and not necessarily that which is possible to deliver. Times do change, the economy changes, and unforeseen issues do arise which require additional assistance from the government such as Hurricane Sandy and the bombing in Boston. This is when we need the government to roll up their shirt sleeves and assist anyway possible. The government has done a great job in states of emergency such as these.  There are funds set aside for these emergencies and natural disasters. Wouldn’t it be nice in any political campaign to be honest and set forth measurable and attainable goals and then set courses of action to attain? It would provide a feeling obama promises madeof trust and loyalty and unity among Americans.

About BHM Healthcare Solutions

BHM is a healthcare management consulting firm whose specialty is optimizing profitability while improving care in a variety of health care settings. BHM has worked both nationally and internationally with managed care organizations, providers, hospitals, and insurers. In addition to this BHM offers a wide breadth of services ranging including managed care consulting, strategic planning and organizational analysis, accreditation consulting, healthcare financial analysis, physician advisor/peer review, and organizational development.

Contact Us :  results@bhmpc.com, 1-888-831-1171

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Posted in Financial, Health Care Reform, Health Insurance | Tagged BHM Healthcare Solutions, Healthcare Financial Analysis, Healthcare Management Consulting, Physician Advisor | Leave a comment

5 Ways That Our Healthcare System Is Broken Infographic

Posted on May 1, 2013 by Linda Ringquist

How is our healthcare system doing? What changes need to be made? Is the Affordable Care Act the answer? What suggestions do you have to help fix our healthcare system? What are you doing to help reduce healthcare costs? How are you offsetting Medicare cutbacks?

 

Five Ways That Our Healthcare System is Broken

Five Ways That Our Healthcare System is Broken infographic by NowSourcing.

About BHM Healthcare Solutions

BHM is a healthcare management consulting firm whose specialty is optimizing profitability while improving care in a variety of health care settings. BHM has worked both nationally and internationally with managed care organizations, providers, hospitals, and insurers. In addition to this BHM offers a wide breadth of services ranging including managed care consulting, strategic planning and organizational analysis, accreditation consulting, healthcare financial analysis, physician advisor/peer review, and organizational development.

Contact Us :  results@bhmpc.com, 1-888-831-1171

Follow us on Facebook:

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Posted in Financial, Health Care Reform | Tagged BHM Healthcare Solutions, Healthcare Financial Analysis, Healthcare Management Consulting, Physician Advisor | 2 Comments

Obamacare Simplification – Is That Like Jumbo Shrimp?

Posted on April 30, 2013 by Linda Ringquist

Summary: A new and improved simplified version of the application for health insurance benefits under Obamacare akahealthcare reform Healthcare Reform is due to be released. Obamacare simplification – is that an oxymoron like jumbo shrimp?

The original version of the application for health insurance benefits under Healthcare Reform was so long (21 pages) and so complex, the average American would have had an extremely difficult time completing the form. The original application had been compared to completing annual tax forms or the Healthcare Reform itself (900 + page document with provisions becoming effective from 2010 through 2015). The form is being shortened and simplified down to 3 pages. Finally there is a document the average American may be able to understand.

It is important to tailor documentation to the audience of highest majority.  Those applying for insurance through the health insurance exchanges are likely to be unemployed and/or from lower income brackets and/or with less education.   The health insurance exchanges will provide marketplaces in which to purchase insurance. Simplifying the application form is a wonderful step in the right direction. If the forms are too complex, many Americans will just opt not to complete or at least weigh the option of not completing and taking the penalty or trying to muster their way through the form.

There still will be complexities with the forms. Whereas previous applications were more heavily weighted toward health questions, the new applications will have a large financial component. Applicants will have to provide proof of income in the form of tax returns, pay stubs and other financial validation. These financial means will be used to determine whether the applicant qualifies for government subsidies. Individuals who earn less than four times the federal poverty level will be eligible for financial assistance. A caveat should be inserted here. If you underestimate your income, you may have to pay back a portion of the subsidy. The overages/shortages will become part of the annual tax return process.

The simplification process is definitely a step in the right direction. While no document or process is perfect, hopefully, this will provide more healthcare reform 2opportunity for individuals to be covered for health insurance. Another hurdle which may come to light is the application process itself. The plan is to have applications online. While online is a terrific time saver and reduces physical paperwork, not all Americans are computer savvy and/or can afford computers. Hopefully, there will be either a paper process to encourage those who aren’t comfortable with computers or, at a bare minimum, access to assistance via physical kiosks or phone.

About BHM Healthcare Solutions

BHM is a healthcare management consulting firm whose specialty is optimizing profitability while improving care in a variety of health care settings. BHM has worked both nationally and internationally with managed care organizations, providers, hospitals, and insurers. In addition to this BHM offers a wide breadth of services ranging including managed care consulting, strategic planning and organizational analysis, accreditation consulting, healthcare financial analysis, physician advisor/peer review, and organizational development.

Contact Us :  results@bhmpc.com, 1-888-831-1171

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Posted in Health Care Reform, Health Insurance | Tagged BHM Healthcare Solutions, Healthcare Financial Analysis, Healthcare Management Consulting, Healthcare Reform, Obamacare, Physician Advisor | 3 Comments

Top 5 Healthcare Consulting Issues as a Result of the ACA

Posted on April 29, 2013 by Linda Ringquist

Summary: The Affordable Care Act and all of its complexities have given rise to several areas in which healthcare providers healthcare 2may need additional assistance.

Healthcare is changing faster than the blink of an eye.  Healthcare providers are finding it more and more cumbersome and in some instances impossible to keep up with all the new legislation. The Patient Protection Affordable Care Act (PPACA) alone is enough to drive a provider mad. The PPACA is a 900+ page document filled with provisions becoming effective from 2010 to 2015. It is difficult to understand all of the provisions let alone know how to properly comply with them. The PPACA touches many different subjects in the healthcare realm.

In order to properly adhere to the PPACA, healthcare providers must have expertise in:

Financial Aspects

  • Reducing health insurance claim denials to offset some of the reductions in Medicare reimbursement
  • Reducing hospital readmissions to a level to avoid penalties and further reduction in Medicare reimbursement
  • Value based payment programs for physicians as opposed to the traditional volume based payment
  • Bundled payments for groups of services as opposed to the traditional pay for each individual service
  • Tax credits for small businesses
  • Additional fraud and abuse penalties

Have you had your healthcare financial analysis lately?Healthcare Financial Analysis

Health Insurance

  • As mentioned above, cutbacks in Medicare reimbursement
  • Covering children longer
  • Not being able to use pre-existing conditions as a basis for non-coverage
  • Expanding Medicaid to cover more consumers
  • Health Insurance Exchanges/Marketplaces
  • Preventative care and what that entails
  • Limits on administrative costs as a percentage of total cost

Health insurance appeals for denied claims

Do you find it difficult to manage the appeals process? Wouldn’t it be great to have a healthcare management consulting firm relieve this burden for you. Wouldn’t it be nice to utilize physician advisor services that is fully automated with medical necessity criteria built in and deadlines automated to comply with accreditation requirements? Visit our physician advisor services pages for more details.

Do you know all of the ins and outs of insurance from private to commercial and from medicare to medicaid?

Care Models

  • Patient Centered Medical Homes (PCMH) or Patient Centered Health Care Home (PCHCH)medical home 6
  • Accountable Care Organizations (ACOs)/integrated health

Do you know all of the advantages of becoming a PCMH? Will you be left behind by not being armed with information as to how to implement? Are you interested in becoming a part of an ACO? Do you know how to start the process?

Accreditation

In order to be recognized as a PCMH, an organization must go through the accreditation process. The following organizations currently offer PCMH/PCHCH accreditation:

  • URAC accreditation
  • NCQA accreditation
  • CARF accreditation
  • TJC accreditation
  • AAAHC accreditation

Generally what differentiates these organizations is the type of organizations they accredit as well as the accreditations offered. Additionally, aco 3ACOs must be accredited.  Currently only NCQA offers ACO accreditation. Look for details in the future to see if any of the other national accreditation organizations begin to offer this type of accreditation as well.

Do you need assistance with your accreditation needs?

Healthcare has become extremely complex and it is difficult for healthcare organizations to be experts on every aspect. Healthcare management consulting has expanded with the enactment of the PPACA especially. You don’t have to do everything on your own. You don’t have to reinvent the wheel. Turn to the experts who have already been through and established protocols for the healthcare issues you are experiencing.

 

About BHM Healthcare Solutions

BHM is a healthcare management consulting firm whose specialty is optimizing profitability while improving care in a variety of health care BHM Healthcare Solutionssettings. BHM has worked both nationally and internationally with managed care organizations, providers, hospitals, and insurers. In addition to this BHM offers a wide breadth of services ranging including managed care consulting, strategic planning and organizational analysis, accreditation consulting, financial consulting for healthcare, physician advisor/peer review, and organizational development.

Contact Us :  results@bhmpc.com, 1-888-831-1171

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Posted in Accreditation, Financial, Health Care Reform, Health Insurance, Healthcare Fraud and Abuse, Healthcare Prevention, PCHCH Accreditation, Services | Tagged BHM Healthcare Solutions, Health Insurance Claim Denials, Healthcare Financial Analysis, PCHCH Accreditation, Physician Advisor Services, URAC Accreditation | Leave a comment

The ABCs of the Physician Payments Sunshine Act

Posted on April 26, 2013 by Linda Ringquist

Summary: The Physician Payments Sunshine Act final rule was announced by CMS in February 2013 and requires public cms announcementdisclosure of transfers in value by manufacturers of medical devices and drugs.

The Physician Payments Sunshine Act (The Act) is a provision of the Patient Protection and Affordable Care Act (PPACA) – aka Obamacare or Healthcare Reform. The PPACA was enacted in 2010 with provisions becoming effective through 2014. The basic premise of the act is to discourage fraud and anti-kickcback issues affiliated with relationships between drug and medical device manufacturers and physicians and to encourage and promote transparency. Transfer of value cannot negatively affect the healthcare of patients and the decisions surrounding their care. The Act charges CMS with creating a searchable database to report transfer of value information, relationships between companies/physicians, ownership interest of physicians and these companies, and penalties issued as a result of noncompliance.

Who has to report?

  • Group purchasing organizations (GPOs)
  • Manufacturers of drugs
  • Manufacturers of devices
  • Manufacturers of biological
  • Manufacturers of medical supplies
  • All of which payment is available under Medicare, Medicaid or the Children’s Health Program (CHIP)

Physician – include medical doctors, doctors of osteopathy, dentists, optometrists, chiropractors, and podiatrists.

Types of transactions deemed “transfer of value”federal legislation

  • Consulting fees
  • Compensation for services other than consulting
  • Honoraria
  • Gifts
  • Food and beverage
  • Entertainment
  • Travel and lodging
  • Education
  • Research
  • Charitable contributions
  • Royalty or license payments
  • Compensation for serving as faculty or as speaker for an unaccredited and non-certified continuing education program as well as an accredited and certified continuing education program
  • Grants
  • Space rental or facility fees
  • Ownership or investment interests

What is excluded from The Act?

  • OTC drugs and class I and II medical devices
  • Gifts/payments/incidentals valued at less than $10
  • Educational materials and items specifically created for patients and their familiessunshine act
  • Discounts, rebates, and contractual warranties issued by a manufacturer
  • Samples for patient use
  • Certain indirect payments transferred by a third party
  • Payments or other transfers of value to residents
  • Existing personal relationships
  • In kind items for the provision of charity care
  • Short term loans of covered devices

Critical dates

  • Initial final rule due date was December 31, 2012 but was delayed due to negative responses by such agencies as the AAFP. The issue was the potential cumbersome and complicated reporting aspects.
  • Initial collection period will be August 1 through December 31, 2013
  • Reporting is due to CMS by March 31, 2014
  • CMS will publish the initial period data by September 30, 2014
  • CMS will publish subsequent year’s data by June 30.
  • Physicians and teaching hospitals will have 45 days to review and dispute (if applicable) the reported information
  • Manufacturers will have 15 days following the physician and teaching hospital review period correct and re-submit the data.

Penalties for non-compliance

  • Between $1,000 and $10,000 for each transfer of value not reported for a maximum of $150,000 if deemed unintentional
  • Up to $100,000 for each transfer of value not reported that the company intentionally failed to report with a maximum of $1,000,000.

Reporting requirementssunshine

  • Who is the recipient
  • What was the transfer of value item?
  • What was the amount of the transfer of value?
  • Were there any third party transactions? Who was the third party?
  • What ownership relationships exist between the physician and his/her family and the manufacturer?
  • Any additional information regarding the transfer of value

August 1, 2013 is right around the corner. How do you start to prepare for the reporting requirements?

  • Determine which entities qualify as GPO or manufacturer under the definition for The Act
  • Determine which transactions qualify as transfer of value
  • Review the reporting requirements and templates as referenced below on the CMS website
  • Update applicable company policies and procedures to comply with The Act
  • Review existing arrangements with teaching hospitals and physicians.

Issues and concerns regarding The Act:

  • Information may be misinterpreted or taken out of context
  • Physicians may scale back on new research and education due to the reporting requriements
  • Hospitals and other providers may review this data when evaluating pursuing relationships with physicians
  • Competition issues could arise as a result of having to report these transfer of value issues. This is potentially an issue with research.
  • The government has designed this public data for the purpose of transparency, but information may be requested by the Department of Justice and the Food and Drug Administration. What will these organizations use this information for?
  • Plaintiff attorneys may use this information in a new way of ambulance chasing.

Additional informationcms

For the official information on the Physician Payment Sunshine Act, please visit http://www.cms.gov/Regulations-and-Guidance/Legislation/National-Physician-Payment-Transparency-Program/index.html. The information found at this site includes:

  • General information
  • Fact sheets
  • Tools and instructions
  • Resources
  • Dates of webinars, calls and meetings
  • Frequently asked questions

Additionally, CMS has created a website for the templates required for reporting. Templates may be downloaded at: http://www.cms.gov/Regulations-and-Guidance/Legislation/PaperworkReductionActof1995/PRA-Listing-Items/CMS-10419.html

About BHM Healthcare SolutionsBHM Healthcare Solutions

BHM is a healthcare management consulting firm whose specialty is optimizing profitability while improving care in a variety of health care settings. BHM has worked both nationally and internationally with managed care organizations, providers, hospitals, and insurers. In addition to this BHM offers a wide breadth of services ranging including managed care consulting, strategic planning and organizational analysis, accreditation consulting, healthcare financial analysis, physician advisor/peer review, and organizational development.

Contact Us :  results@bhmpc.com, 1-888-831-1171

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Posted in Compliance, Financial, Health Care Reform, Healthcare Fraud and Abuse | Tagged BHM Healthcare Solutions, Healthcare Financial Analysis, Healthcare Management Consulting, Physician Advisor | 2 Comments

What Are the Current Trends in Accountable Care Organizations (ACOs)?

Posted on April 25, 2013 by Linda Ringquist

ACOSummary: What can we expect in 2013 in terms of Accountable Care Organizations (ACOs)? Where are we headed? What considerations need to be taken into account?

ACOs are continuations to the Patient Centered Medical Home (PCMH) model. PCMH places the patient at the center of all decisions regarding his health care and assigns responsibility to the primary care physician to coordinate care with all other care givers involved with the patient. These might include specialists, laboratories, imaging centers, etc.  If a PCMH is like a home, an ACO is more like a neighborhood. It is a group of PCMHs working together in an accountable manner which is nationally recognized through organizations such as the Centers for Medicare and Medicaid Services (CMS).

ACOs began formally being recognized in 2012. As of January 2013, there are approximately 300 ACOs. They are really taking off – leaps and bounds.

So what are some of the trends we are seeing?

  • We would expect the Medicare Shared Savings Plan (MSSP) to nearly double in 2013 and continue the trend of expansion.
  • We would expect Medicaid ACOs to slow in growth a bit due to the impending healthcare exchanges and Medicaid expansion which are results of the Patient Protection Affordable Care Act (PPACA). We are in a holding pattern waiting to see what is going to happen with these. 2014 will probably provide more growth for Medicaid ACOs. Medicaid also has additional challenges of instability of the population and a large emphasis on long-term care which adds to the slower growth in Medicaid ACOs as compared to Medicare ACOs.
  • For states that decide to expand Medicaid, ACOs can provide additional monetary incentives which may encourage ACO expansion as well. States that have currently opted to expand Medicaid are: Arkansas, California, Connecticut, Delaware, the District of Columbia, Hawaii, Illinois, Maryland, Massachusetts, Minnesota, Missouri, Nevada, Rhode Island, Vermont, and Washington.
  • We would expect a growth in the number of patient centered medical homes (PCMH). 2012 was a big year for PCMH and really was the ACO 2turning point for health care and the focus on the patient.
  • States will begin to move dual eligible populations toward managed care and toward ACOs.
  • Beginning in perhaps 2015 or 2016, we may see ACOs as part of the exchanges.
  • We will begin to see the expansion of commercial ACOs.
  • Mergers and acquisitions should rise in 2013 with the cutbacks from Medicare and the move to accountable care.
  • NCQA accreditation in particular will take off in 2013. They will be accrediting ACOs and exchanges. The number of accredited organizations will grow in leaps and bounds this year.
  • One can hope with all of the emphasis on primary care that more physicians will begin to choose primary care as their profession. This still remains to be seen.

What are some particular organizations doing?

  • Crystal Run is glad that reimbursement has finally become a focal point when using patient centered care models. They have been practicing patient centered strategies since the 1990s and have had an EMR since 1999. They were just waiting for the rest of the country to catch up. Crystal Run just thought it was the right thing to do and didn’t do it for any other reason.
  • Colorado ACO program saved $20 million in unnecessary care, of which after expenses, they were able to give $3 million back. Colorado ACO program also saw a reduction in emergency room visits and hospital readmissions. A true success story.
  • North Carolina has had great success with their medical home model within Medicaid which of course is the prelude to any successful ACO.
  • Aetna is on the move expanding their ACO kingdom both through partnerships with providers as well as a data analytics subsidiary.
  • Kelsey-Seybold was named the first accredited ACO through NCQA

2013 and going forward are going to be very interesting and an opportunity for tremendous growth. Keeping up with all of the changes is a daunting task. What are your thoughts on ACO? Do you think they are a good concept? Do you think there are flaws? Do you think there are areas of improvement?

About BHM Healthcare SolutionsBHM Healthcare Solutions

BHM is a healthcare management consulting firm whose specialty is optimizing profitability while improving care in a variety of health care settings. BHM has worked both nationally and internationally with managed care organizations, providers, hospitals, and insurers. In addition to this BHM offers a wide breadth of services ranging including managed care consulting, strategic planning and organizational analysis, accreditation consulting, healthcare financial analysis, physician advisor/peer review, and organizational development.

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Posted in Accreditation, Financial, Health Care Reform, Health Insurance, PCHCH Accreditation, Services | Tagged BHM Healthcare Solutions, Healthcare Financial Analysis, NCQA Accreditation, Patient Centered Health Care Home Accreditation, PCHCH Accreditation | 5 Comments

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