With attention on population health and quality initiatives, rev cycle leaders have turned their focus on how capturing SDOH impacts patients.
Social determinants of health (SDOH) are social factors, such as homelessness, illiteracy, a history of childhood trauma, and joblessness or underemployment, that can affect a person’s health.
With increasing attention on population health and quality initiatives, organizations have turned their focus on SDOH and how capturing those ICD-10-CM codes impacts their patient population and their success in caring for that population. Experts have been urging hospitals to capture the codes for SDOH for years, but the message still doesn’t appear to be resonating.
Because of staffing shortages and financial losses as the result of COVID-19, revenue cycle leaders such as coding and CDI directors have been focusing their efforts elsewhere, especially since the capture of SDOH doesn't have an impact on reimbursement.
Adoption of SDOH capture is still only 1.59%, Tiffany Ferguson, LMSW, CMAC, ACM, CEO of Phoenix Medical Management, told the Revenue Cycle Advisor. The time is now for organizations to ensure that these codes are captured, she says.
The main reasons why hospitals aren’t capturing SDOH codes aren’t difficult to understand—there is no reimbursement for them, and their capture is not required, says Ferguson. Organizations also need to focus on medical diagnoses.
“Thus, [SDOH codes are] always going to fall to the bottom of the list or off the list,” she says.
But, as organizations start to place more of an emphasis on patient experience and population health, revenue cycle leaders have started baking in SDOH capture to improve patient outcomes.
Current electronic health record (EHR) systems may contribute to the lack of capture as these systems are often not automated for these codes, and the information is not always easy to find in the record.
A Florida health system found the same to be true and has started putting SDOH right into the EHR problem list, where doctors can see and act on them.
Jennifer Goldman, DO, chief of Memorial Primary Care at the six-hospital Memorial Healthcare System, based in Hollywood, Florida, recently explained to HealthLeaders how it embedded SDOH right into the EHR and how it uses that information to improve patient outcomes.
HealthLeaders: A JAMIA report from 2021 found there is no consensus on which SDOH measures should be captured in the EHR. How do you decide which ones to add?
Goldman: That's an ongoing discussion in our system. We utilize Epic, which has a social determinants of health wheel, which is just a graphic representation of the varieties of determinants of health that somebody is dealing with. And the major challenge for us in our organization was to determine which ones we were going to prioritize and start with.
We don't know if all of them truly impact health equally, but we do know that there are three that are a priority not only for us, but for Medicaid. If we can do something about these, we can probably impact more in a person's health than if we address resources elsewhere. Those are food, housing, and transportation. Substance abuse is a huge social determinant of health, but we already have a process for that, where we already screen everybody for that when they come in. The three social determinants of health we focus on are traditionally outside the wheelhouse of any physician. Those are things that we just did not ask people.
HL: How do you capture the data about the need, and how do you match the need with the actual service?
Goldman: We utilize the Epic release social determinants of health wheel. And we ask first our health coaches, our nurse navigators, and in some cases our social workers to review these determinants for the patients that were on their high-risk panel, patients that have significant ER visits or who are ill with multiple different chronic conditions.
We focused first on that population. Case managers were asking some of those questions anyway, but they were asking them in a non-capturable, non-standardized way. We standardized the way that we were capturing that data so that we could run analytics on it and show that information in the EHR to physicians. If our providers don't know that the patient they're treating right now is homeless or doesn't have access to healthy food or doesn't have access to transportation, that would probably impact their decision-making in terms of what treatment they were going to prescribe for that person.
We built something called an alert or a best practice advisory, where if somebody screened positive for homelessness, food insecurity, or transportation need, that would pop up [in front of] the clinician. And we took that a step further, because sometimes pop-ups in the EHR are negatively looked at. I never wanted to have an empty best practice advisory, where the doctor would have to do five more clicks to document that in the EHR. We drop the code for that specific social determinant of health into the problem list and into what we call a visit diagnosis.
We also included documentation that the patient was going to be automatically sent to our care team for follow-up in terms of how to access resources. We did that by having an automated in-basket so that it didn't hinge on a physician or a nurse practitioner or PA remembering to involve a social worker. This would happen automatically. We work with our community resources, such as the Broward County Task Force on Homelessness, and many other housing resources, as well as transportation assistance. With food, we work with multiple local food banks. We do direct connections with people we call and get those resources for them, instead of just handing a piece of paper to a patient.
HL: When did these processes go live, and what are the outcomes like so far?
Goldman: These alerts went live six months ago, and the outcomes have been significant. We've tripled the number of ICD-10 codes in the EHR for social determinants of health. That means that our physicians are documenting three times more on homelessness and food insecurity and transportation than they were previously. So we know that it's being captured.
We know that interventions are being done because we can track that as well. And we know that all those social determinants of health that we're screening for, all those patients ended up getting a referral to the care team and the care team contacted them and gave them the resources that they need. We're in the process of measuring outcomes, which ultimately is the most important thing. We're looking at data for no-show rates for appointments.
HHS released a proposed rule outlining changes it wishes to make to the 340B administrative dispute resolution process.
HHS issued a new proposed rule revising the 2020 final rule that established the 340B administrative dispute resolution (ADR) process to better align with requirements found within the Affordable Care Act.
For background, the 340B program requires drug manufacturers to provide outpatient drugs to eligible healthcare organizations and other covered entities at significantly reduced prices. The ADR process is an administrative process designed to assist these organizations and manufacturers in resolving disputes regarding overcharging, duplicate discounts, or diversion.
340B payments are a lifeline for some organizations, making the ADR process that much more important as hospitals need to ensure fair and accurate payment.
"Henry Ford Health system and a lot of folks rely on 340B discounts and other mechanisms like disproportionate share payments. We're a big teaching institution, so a lot of these special payments that we do in order to teach the healthcare leaders of the future or make sure that we can take care of vulnerable patients are extremely important," Damschroder said.
"So that is an area that we and others are actively—in our advocacy—ensuring that these programs stay intact or evolve to a place that enhances the programs for the people that were trying to care for," said Damschroder.
According to the proposed rule, there are a few major proposed changes to the ADR process:
Establish a more conventional administrative process for disputes and move away from the current “trial-like” proceedings
Include 340B program subject matter experts from the Health Resources and Services Administration’s Office of Pharmacy Affairs on the ADR panel
Align the ADR process to statutory provisions on overcharges, duplicate discounts, and diversion
Offer a reconsideration process for parties dissatisfied with the 340B ADR panel decision
Historically, HHS has encouraged manufacturers and covered entities to work with each other to attempt to resolve disputes in good faith, it said in the proposed rule. The ADR process is not intended to replace these good faith efforts, HHS says, and the ADR process should be considered only when good faith efforts to resolve disputes have been exhausted and failed.
This proposed rule comes on the heels of a troublesome year for the 340B program.
In the recent OPPS final rule, CMS solidified the payment policy for 2023 of average sales price of 6% for drugs and biologicals acquired through the 340B program because of that unanimous Supreme Court decision.
Hospitals and health systems can send comments on the rule to HHS by January 30, 2023.
As financial pressures put a strain on revenue cycle operations, many leaders are looking toward their revenue integrity departments for help protecting their bottom line.
As the revenue cycle continues to be an area of focus for organizations, revenue cycle leaders have turned to streamlining (and even creating) revenue integrity departments to reduce the risk of noncompliance, optimize payment, and minimize the expense of fixing problems downstream with claim edits.
Healthcare organizations are expected to end the year in the red, so now is the time to optimize all revenue cycle functions.
Although the complexity of revenue integrity functions can be daunting to measure, the relative newness of many revenue integrity departments is another reason productivity metrics might not be used or streamlined yet, Kim Yelton, RHIA, CCS, CDIP, CHRI, revenue integrity director at WakeMed Health and Hospitals in Raleigh, North Carolina, told NAHRI.
When a revenue integrity department is first established, the primary focus is often dealing with immediate charging, billing, or compliance issues and defining the new department’s responsibilities.
Read on for more advice from NAHRI on productivity measures.
As a revenue integrity program becomes more established and clarifies its functions, revenue cycle leaders switch their attention to metrics for process improvement, and that’s when productivity starts to come into focus, Yelton says. The same metrics that are analyzed for process improvement, such as how to reduce touches on accounts, manage work queues, or reduce denials, can yield data for productivity metrics.
The systems and data that revenue integrity departments already use are valuable sources of productivity information, agrees Paula Twiss, MBA, CRCS-P, CRCS-I, supervisor of revenue integrity at Monument Health in Rapid City, South Dakota. Twiss has been experimenting with different data sets pulled from Epic to develop productivity metrics for implementation at the start of the next fiscal year.
Currently, Twiss uses a productivity report in Epic that monitors her teams’ activity in accounts. She runs the report weekly and reports on it monthly during one-on-one meetings with her team. However, the report is only as good as the data Epic captures, she says. In addition, her team works on a variety of projects and meetings outside of Epic. To fill those gaps, Twiss created a document that’s updated during weekly huddles and covers the previous week’s work.
“Every Monday we spend an hour with the team and fill out this huddle document that goes through what their goals were for the week, what work they’ve done, what meetings they were at, what work queues they were able to get into and complete, and the status of those,” Twiss told NAHRI.
To fill out potential productivity metrics, consider what already exists for at least some revenue integrity functions. For example, if revenue integrity staff are involved in denials management, some existing metrics, such as denial rate or completed appeals, can demonstrate productivity, according to Twiss.
Ideally, as much productivity data as possible should be gathered from existing systems, Yelton says. Although currently some manual data collection is unavoidable, best practice should aim toward finding ways to improve data collection through systems to reduce the need for manual collection.
An expert shares tips for revenue cycle leaders looking to streamline automation.
Revenue cycle leaders have been tasked with helping to tighten the belt of hospitals as rising expenses continue to wreak havoc on hospitals and health systems across the country.
When looking to cut costs and streamline processes, many revenue cycle leaders are turning to automating mundane administrative tasks. For years studies have shown that a large amount of health expenditures go toward administrative costs. Ranging from billing and coding to insurance, these costs can negatively impact an organization’s bottom line.
From patient access to account resolution, automating routine processes gives providers the opportunity they need to cut down on administrative costs. To learn more, HealthLeaders touched base with Teri Schmidt, vice president of consulting and business development at SYNERGEN Health, to see how revenue cycle leaders can best leverage automation and cut these costs.
HealthLeaders: In which area of the revenue cycle are leaders seeing the most challenges, and how can these challenges be remedied with automation?
Teri Schmidt: One of the biggest challenges that revenue cycle leaders face is a lack of resources to manage workloads. We still face a nationwide workforce shortage in our industry, the same issue we have been plagued with since even before the COVID-19 outbreak. Whatever the reason for leaving may be, this exodus has put a massive strain on healthcare organizations revenue cycles. By automating workflows within the revenue cycle, we can streamline repetitive manual efforts that otherwise would have inundated the staff. By automating tasks such as claim review, claim follow up, and denial management, healthcare organizations enable staff to focus on more important, qualitative tasks.
The other most impactful challenge revenue cycle leaders face today is an increase in aged receivables. With greater financial responsibility being placed on the patient, healthcare organizations are seeing the average number of days it takes to collect payments due increase. Automated solutions help implement a patient-centric outreach strategy to assist patients in making informed cost decisions pre-visit and simplify post-care billing processes. This reduces the chances of surprise billing as well as an increase in aged receivables.
HealthLeaders: How can a streamlined revenue cycle strategy improve work efficiency for an organization?
Schmidt: We’re seeing more and more health organizations exploring and adopting automation solutions to drive their revenue cycle management transformation. These innovations can help them improve the efficiency and effectiveness of their operations by combining the power of machine learning and robotic process automation. Ultimately, by digitizing and automating their most repetitive end-to-end processes and functions, organizations are more empowered to drive value to the bottom-line while scaling resources to focus on complex, value-added activities. Automation powered by artificial intelligence and machine learning can even predict, prevent, and detect denials before the claims are submitted to the payer.
HealthLeaders: How can an automated revenue cycle help providers cut down on administrative costs?
Schmidt: Healthcare organizations can reduce their costs by investing in the right technology. From billing inefficiencies and payer-provider alignment to an increasing demand for resources, and inefficient manual workflows, automated revenue cycle tools can help address the plethora of issues that add to the cost to collect.
For example, when implementing robotic process automation into the appeals process, providers could have an increase in revenue and minimized administrative burden. Time consuming tasks preparing for the appeal and providing supporting documentation can be completed quickly with an increased level of accuracy by an RPA bot.
HealthLeaders: Why has automation been essential to organizations’ revenue cycles and how has it helped drive proper reimbursement?
Schmidt: Timely payments are the lifeblood to keeping your practice running. The revenue cycle process is complex with many opportunities for breakdowns in efficiencies and revenue leakage across the life cycle of a claim. By managing revenue cycle processes through automated solutions, healthcare organizations can improve results across the back end while decreasing labor-intensive tasks.
For example, by implementing automated insurance eligibility checks, patients understand their financial liability before receiving care and work with the provider to set up financial plans. This promotes financial transparency and streamlines the reimbursement for the provider.
HealthLeaders: With the current financial state, what can revenue cycle leaders expect in the coming year?
Schmidt: We have witnessed some of the toughest years the American health system has ever faced, but we still aren’t out of the shadow of the pandemic. Healthcare organizations have still not returned to pre-pandemic levels, and the coming year will likely feature trying economic battles as we approach a potential recession. While healthcare systems have witnessed an increase in patient volume, most likely due to elective procedures and COVID-19 surges, margin fluctuations denote a lack of stability.
Revenue cycle leaders can also expect a continued rise in expenses and administrative costs paired with a decline in staffing numbers to force health systems to find new alternatives. For example, introducing new hybrid staffing models could be a potential solution.
HealthLeaders: What tips do you have for revenue cycle leaders who are unsure if they should implement new technology or solutions?
Schmidt: To them, I have to say that transitioning and adopting any new technologies will always be daunting. It also goes without saying that choosing the right partner to streamline revenue cycle management is not easy, and any healthcare organization doing so should properly vet any potential candidate. The biggest tip I have is always to ask questions and always consider your team. From revenue cycle expertise to ease of integration, finding the right revenue cycle partner requires you asking the right questions about what’s best for your organization.
Deploying automation to broken workflows will not always produce an improved result. Some workflows just need re-engineered processes. It’s important to find an experienced revenue cycle partner that can identify where automation can truly drive an improved result. Some questions to keep in mind:
Do I know where the breakdowns are currently across revenue cycle?
The 2023 OPPS and Medicare physician fee schedule final rules were top of mind in the revenue cycle this month.
Look at the top trending revenue cycle stories from HealthLeaders this month, both of which cover recent payment rate updates to hospitals and physicians.
CMS released the 2023 OPPS final rule that includes increased Medicare reimbursement and the establishment of a new provider type, but hospital groups say it's not enough.
CMS recently released the 2023 OPPS final rule, which brought increased hospital outpatient payment rates, the establishment of a new provider type, and 340B payment finalization.
According to the final rule, CMS has increased Medicare reimbursement for hospital outpatient departments by 3.8%, reflecting a hospital market basket increase of 4.1 percent and a 0.3 percentage point decrease for productivity. This is higher than the 2.7% update included in the proposed rule earlier this year.
Blow-back from the proposed payment rate increase of 2.7% may have played a role in the finalized amount of 3.8%.
Ninety percent of medical practices reported that the payment cuts found in the 2023 Medicare physician fee schedule would reduce access to care, the MGMA says.
Physician payment cuts are coming, significant changes to E/M services are finalized, and key reporting revisions are hitting telehealth and audio-only services, according to the final 2023 Medicare physician fee schedule.
Proposed payment cuts that drew vocal criticism from physician advocacy groups will move forward as planned, as CMS announced a 4.5% reduction to the 2023 Medicare Part B conversion factor (CF), effective January 1.
The CF will fall to $33.0607 in 2023, down from $34.6062 in 2022, largely due to budget neutrality adjustments. The final CF for 2023 is two cents lower than the rate CMS first proposed in July, according to Part B News.
The anesthesia conversion factor will also take a hit next year, down 4.4% as proposed.
CMS finalized new procedures that will be subject to prior authorization in 2023.
Earlier this year in the 2023 OPPS proposed rule, CMS brought forward a proposal to require prior authorization for an additional service category: facet joint injection procedures.
At the time, CMS said this would ensure Medicare beneficiaries receive medically necessary care while protecting the Medicare Trust Funds from unnecessary increases in volume by virtue of improper payments. This would happen without adding new documentation requirements for providers, CMS said.
Now, CMS finalized adding facet joint interventions to its hospital outpatient department prior authorization list in the recently released 2023 OPPS final rule, but with one change: In response to feedback, CMS scrapped its proposed March 1, 2023, effective date for this proposal. Instead, facet joint injection procedures will be subject to prior authorization starting July 1, 2023.
“Prior authorizations for joint injections will potentially affect providers not affected by the prior cosmetic or major back procedure requirements,” says Kimberly A. Hoy, JC, CPC, director of Medicare and compliance at HCPro. “CMS’ delay until July 1, 2023, in line with prior delays, rather than going forward March 1, 2023, will give providers needed time to prepare.”
CMS continues to cite the need to control unnecessary increases in volume as the deciding factor behind added prior authorizations each year.
CMS has seen a marked increase in the volume of facet joint injection procedures, so it’s not unreasonable for it to take steps to ensure they’re medically necessary, Ronald Hirsch, MD, FACP, CHCQM, CHRI, vice president of regulations and education at R1 RCM, told NAHRI.
Although prior authorization can be burdensome to the front-end revenue cycle, it can help avoid at least some denials on the back-end.
“From the provider side, it seems better to have assurance of payment prior to performing the procedure instead of incurring the costs of performing the procedure and then being denied payment afterwards,” Hirsch says.
While CMS agrees with that statement and says it will ensure that this measure will not burden patients or providers, many providers are not so sure. For example, as the American Medical Association previously found, prior authorizations of medical treatments and services has a negative impact on both patients and providers.
The American Medical Associations survey found that 93% of physicians reported that prior authorization led to delays of necessary care (14% always, 42% often, and 38% sometimes), and that 82% of physicians reported that the prior authorization process leads patients to abandon treatment (3% always, 24% often, 55% sometimes).
More than 1,000 practicing physicians participated in the American Medical Association survey, with 40% working as primary care physicians and 60% working as specialists.
As CMS is bound to add more procedures to the prior authorization list moving forward, time will tell of the effect on the front-end revenue cycle.
CMS recently released sample formats for hospital price transparency files to help revenue cycle leaders comply with the requirement.
As price transparency requirements push forward and with a wide lack of adoption from hospitals, CMS is trying to help revenue cycle leaders streamline their processes by offering sample formats.
CMS is offering three voluntary sample formats (wide, tall, and plain) that hospitals may use to meet the federal requirement to make certain standard charges publicly available through a machine-readable file.
At the same time, CMS also posted a sample data dictionary for the wide and tall formats.
While some organizations already have systems in place to adhere to price transparency requirements, opportunities still exist to adjust outdated revenue cycle processes, including creating the necessary machine-readable file.
"Revenue cycle leaders need to first make sure they are following CMS' guidelines to complete a comprehensive, machine-readable file of all services and items," Connie Lockhart, director of strategy and operations at Impact Advisors, said.
"Ensure all requirements are met—like how a separate file must be posted for each hospital. And be cognizant of multiple hospitals operating under a single hospital license with different sets of standard charges."
Also, ensure that list is posted on a publicly available website.
Once completed, make sure to post a display in a publicly available website of 300 shoppable services in a consumer-friendly format. This should include the 70 CMS-specified, shoppable services, Lockhart says. Revenue cycle leaders should also establish a cadence to ensure both displays are updated annually, Lockhart says.
Once the basics of price transparency are in place, like creating a machine-readable file, revenue cycle leaders can then move to streamlining other areas of the requirement.
A Pennsylvania doctor, Muhamad Aly Rifai, was indicted with four counts of healthcare fraud for fraudulently billing Medicare for services not provided, or not provided at the level which was claimed, the Department of Justice (DOJ) recently announced.
According to the indictment, the defendant was a licensed psychiatrist, that for several years, routinely and improperly billed Medicare for services which he did not provide to Medicare beneficiaries and nursing home patients.
The DOJ said his fraud included the following:
Billing for treating dead beneficiaries
Billing for treating the same patient at the same time at different nursing homes
Billing for providing more than 24 hours’ worth of services to patients on a single day
The indictment further alleges that the defendant routinely billed for higher levels of care than he or his staff provided to nursing home patients. According to the Indictment, despite not having actually seen the patient, Rifai added a pre-printed stamp to medical progress notes to support billing for psychological and add-on services which were not provided by his staff.
From about January 2015 until October 2022, Rifai obtained Medicare payments of at least approximately $1.36 million based on fraudulent claims, the DOJ said. If convicted, the defendant faces a maximum possible sentence of 40 years in prison and a fine of up to $1 million.
The MGMA recently detailed five ways the government can help alleviate burdens from certain requirements under the No Surprises Act.
The Medical Group Management Association (MGMA) recently provided written comments to the HHS, the Department of the Treasury, and the Department of Labor regarding rulemaking for the advanced explanation of benefits (AEOB) and good faith estimate (GFE) requirements of the No Surprises Act.
The No Surprises Act, which became effective January 1, contains provisions that protect patients from surprise medical billing and out-of-network emergency care costs not reimbursed by insurance. And as we have seenfrom other letters penned to the departments, many medical associations are finding the AEOB and GFE requirements to be the most burdensome right now.
According to the MGMA, to address ongoing concerns regarding the GFE and AEOB requirements, the departments should:
Not enforce AEOB requirements until there are workable solutions that are developed, tested, and implemented.
The departments stated they would delay implementation of the AEOB policies until rulemaking has occurred, but the MGMA says this is not enough time for the industry to roll out and deploy the necessary standards needed to implement these requirements.
Allow for patients to opt-in to receiving AEOBs and GFEs.
At a minimum, the MGMA says the departments should allow for practices to apply for a hardship exemption, which would give them additional time to apply.
Not yet rely on new, fast healthcare interoperability resources-based standards to implement AEOB requirements.
Whichever standard the departments support should take into consideration medical practices of all sizes and regions, as well as those who are under-resourced, the MGMA said. In addition, the MGMA says a standard must be developed, tested, and readily available to medical groups before the AEOB requirements are implemented and enforced.
Extend the enforcement discretion for the convening provider/facility and co-provider/facility provisions for GFEs.
The MGMA says enforcement discretion should continue until appropriate standards have been developed, tested, and implemented by group practices.
Continue soliciting input and working with stakeholders, such as medical groups, to implement workable policies that empower patients, but not at the expense of delivering care.
A new study says drug companies reduce access to care by limiting 340B community pharmacies.
As 340B payments remain in the spotlight, a new study says drug companies are limiting 340B pricing with community and specialty pharmacies which in turn is having an adverse impact on access to care for patients and communities across the country.
In July, the Supreme Court unanimously ruled that cuts to hospital reimbursement under the 340B drug discount program were unlawful. At the time, the justices said that HHS' failure to survey hospital costs before enacting the cuts exceed the agency's authority under the Medicare statute, making the decision to reduce 340B reimbursement unlawful.
The ruling was the culmination of a court battle stretching back to 2017, when CMS finalized cuts to hospital reimbursement under the 340B program in the 2018 outpatient prospective payment system final rule.
According to the study, the average 340B critical access hospital (CAH) reported annualized losses of approximately $507,000, and the average disproportionate share hospital reported annualized losses of nearly $3 million.
On average, CAHs reported 44% of their total 340B savings coming from community and specialty pharmacies, with several CAHs reporting that their entire 340B savings come from these arrangements, the AHA study said.
“Overall, 10% of responding hospitals reported average annualized losses of $10 million or more, illustrating the magnitude of the harm that drug companies’ actions have on 340B hospitals and their ability to care for their patients,” the study said.
“This important new report shows how unlawful actions by drug companies to restrict 340B discounts to community and specialty pharmacies are directly reducing access to care and services for patients and communities, especially those in rural areas,” AHA Executive Vice President Stacey Hughes said in a statement.
“Drug companies are limiting discounts that help hospitals provide free care for uninsured patients, services in mental health clinics and many community health programs. To protect access to care, we continue to urge the Department of Health and Human Services to aggressively use all tools available to stop these harmful tactics from drug companies,” Hughes said.
The report is based on a survey of more than 300 hospitals and health systems participating in the 340B program conducted earlier this year by the AHA.