Revenue cycle leaders are concerned about the efficacy of the regulation and the resources required to implement it.
Many revenue cycle leaders believe the price transparency rule is too confusing and expensive to achieve its intended purpose, according to a KLAS report.
While the respondents in [[{"fid":"12585","view_mode":"default","fields":{"format":"default"},"link_text":"the report","type":"media","field_deltas":{"1":{"format":"default"}},"attributes":{"class":"file-default media-element","data-delta":"1"}}]] feel price transparency allows for more patient empowerment and fights the consumerization of healthcare, they doubt the efficacy of the regulation.
CMS' price transparency rule went into effect January 1, 2021, and requires each hospital to provide pricing information online for at least 300 different shoppable services.
To gauge how hospitals are responding to the regulation and their plans with price transparency, KLAS interviewed 66 revenue cycle leaders over the past year.
Though nearly half of the respondents say that price transparency will significantly or moderately improve patient financial outcomes, over half who answered moderate improvement believe the existing regulation needs additional clarification and federal guidance.
"There are concerns about cost, data accuracy, and patient adoption of pricing tools; some respondents worry about patients’ ability to understand the displayed pricing data, and today, most patients are unaware online pricing information exists or are unsure of how to interpret it," the authors of the report state.
Meanwhile, 26 respondents believe the rule will have no improvement on patient financial outcomes, and seven feel it will cause moderate or significant deterioration.
The two aspects of the regulation that many respondents are highly dissatisfied with are the requirement to use machine-readable files containing pricing information, and the requirement to broadly publish online a master list of rates.
To implement and sustain price transparency compliance, most respondents say significant resource investment is necessary. However, finding resources can be difficult as organizations weigh the financial burden of investing in a regulation that doesn't provide a return on investment, according to the report.
"This lack of investment can be problematic since knowledgeable and experienced resources are required to keep the pricing information accurate and compliant," the authors say. "Over the next year, respondents expect they will need to continually invest in people, processes, and technology to meet price transparency mandates."
The report states that hospitals are more likely to use third-party solutions rather than their electronic medical record (EMR) vendor, with 36% of respondents saying third-party vendors are best positioned to lead in price transparency.
Though satisfaction rates are higher with third parties, some respondents who currently use a third party say they will consider moving to their EMR vendor's platform to consolidate systems.
Ultimately, the report states that CMS' regulation is confusing and organizations are unclear on how to approach it. While some respondents say their organizations have brought in consulting groups, and other say they have educated their employees about the rule, the number and types of resources required is still uncertain.
"Many organizations are not investing beyond the bare minimum requirements, and they don't plan to do more until there is further clarity around the regulations and the expectations going forward," the authors conclude.
The lawsuit was filed in the U.S. District Court of the Central District of California against HHS and HHS secretary Xavier Becerra, who are alleged of using different definitions for "entitled" in the "days entitled to benefits under part A"—one of the factors included in the DSH payment adjustment calculation.
According to the lawsuit, this results in lower payments to the hospitals, and "is the epitome of arbitrary and capricious agency action and must be reversed."
The disproportionate patient percentage is calculated as the sum of two fractions, the social security income (SSI) fraction and the Medicaid fraction, according to the lawsuit.
The numerator of the Medicaid fraction consists of days of patients who were both eligible for medical assistance or Medicaid, and not entitled to benefits under Part A or Medicare. The denominator for the Medicaid fraction is the hospital's total patient days for the period.
The SSI fraction consists of the days for patients who were entitled to benefits under Part A of Medicare. The denominator includes all Part A days, and the numerator includes only those Part A days for patients who are also entitled to SSI benefits.
The hospitals allege HHS used different definitions of "entitled" depending on which side of the fraction was being considered.
Along with invalidating HHS' policy, the hospitals want the department to recalculate the DSH and make prompt payment of any additional amount owed, plus interest.
The lawsuit concludes that "because the purpose of the DSH adjustment is to provide additional payment to hospitals that incur higher costs in treating low-income patients, an agency interpretation that does not take into account SSI payment status codes associated with eligible SSI individuals is also unreasonably and impermissibly inconsistent with the legislative history and purpose of the Medicare DSH Statute."
ASA, ACEP, and ACR are aiming to protect patients' choices of providers and avoid the delay of diagnosis and treatment by targeting the narrowing of medical networks, potentially resulting in out-of-network bills.
Their case had been stayed while the government decided whether it would appeal the Texas court ruling. The Department of Health and Humans Services (HHS) will now pursue an appeal, according to filings from the Department of Justice.
The February ruling sided with the Texas Medical Association, which filed a lawsuit challenging how the HHS created an arbitration process for hospitals, doctors, and insurers to settle disputes over out-of-network bills under the No Surprises Act.
The court decided that HHS was mistaken in its decision to instruct mediators to give past contracted rates between insurers and providers extra weight compared to other factors during the IDR process.
Both the Texas case and the ASA, ACEP, ACR suitimpact the IDR process to determine provider reimbursement for out-of-network care. Neither case affects patient protections against out-of-network bills.
"ACEP, ACR and ASA will work with legal partners and patient advocates to ensure that the Surprise Billing Interim Final Rule ultimately complies with the text and spirit of the No Surprises Act as passed by Congress," the associations stated in a release.
A KLAS survey found that dissatisfaction with electronic health records (EHR) is more likely to result in clinician resignations.
EHR satisfaction plays a significant role in clinicians' decision to continue at their organization, according to a report by KLAS.
Based on 59,000 clinicians surveyed, the research found that providers who are very dissatisfied with their organization's EHR are nearly three times more likely to leave in the next two years compared to those who are very satisfied with the EHR.
The report also highlighted the importance of EHR training, finding that clinicians who strongly disagree their training was specific to their workflow are more than twice as likely to leave their organization compared to those who strongly agree.
Additionally, EHR vendor satisfaction can influence clinicians' decision to leave. According to the survey, 32% of clinicians who strongly disagree that their vendor has designed a high-quality EHR are likely to leave their organization compared to 12% who strongly agree.
One strategy that can improve EHR satisfaction is reducing providers' afterhours charting time, the report stated. Clinicians who spend zero to five hours per week charting afterhours are likely to leave 16% of the time compared to 24% for those who chart more than 25 hours per week.
Charting burden also affects nurses, with the study finding that 30% of nurses who report spending five or more hours doing duplicative or unproductive charting per week are likely to leave their organization.
"While some clinicians chart after hours by choice, those who are efficient enough in the EHR to complete most of their charting during business hours tend to be more satisfied with the EHR and less burned out," the authors of the report wrote. "Charting efficiency can also be improved by implementing personalizations that are the most appropriate for each clinician's workflow."
EHR experience is far from the only factor causing clinician burnout, but it is an area hospitals and health systems have some control over to make the process easier for their providers.
"Healthcare leaders should focus on improving the areas of EHR satisfaction with the most room to improve," the authors wrote. "At a foundational level, organizations need to ensure their EHR has solid reliability (i.e., uptime) and quick response time, as these issues can overshadow even an otherwise good EHR experience."
The health system is off to a slower than expected start to the year despite an increase in revenue.
HCA Healthcare's first quarter financial and operating results fell short of projections as increased labor costs weighed down a rise in revenue, the company announced today.
Revenue for HCA in the first quarter was $14.94 billion, compared to $13.97 billion in the first quarter of 2021. However, the Nashville-based health system dealt with labor shortage challenges, as many hospitals and health systems across the country have, which meant higher expenses to keep and attract workers.
The result is a drop in expected revenue for the year, with the updated projection of $59.5 billion to $61.5 billion—nearly $500 million below the earlier forecast. HCA's adjusted EBITDA, meanwhile, totaled $2.94 billion for the first quarter, compared to $3.05 billion in the first quarter of 2021.
"As always, our colleagues and physicians continued to show-up and deliver on our promise to provide high quality care to our patients," Sam Hazen, CEO of HCA Healthcare, said in a release. "I want to thank them for their commitment and hard work as we hopefully exit the COVID-19 pandemic. In the first quarter, we had a number of positive volume and revenue indicators. Unfortunately, they were offset by higher-than-expected inflationary pressures on labor costs."
Approximately $244 million of the revenue in the first quarter was due to the proposed directed payment program by CMS from September to December 2021.
Other factors that played a role in revenue included the following increases compared to the first quarter of 2021:
Same facility admissions increased 2.1% and same facility equivalent admissions increased 5%
Same facility emergency room visits increased 14.6%
Same facility inpatient surgeries increased 0.8% and same facility outpatient surgeries increased 6.8%
Same facility revenue per equivalent admission increased 2.7%
HCA operates 182 hospitals and approximately 2,300 ambulatory sites of care, including surgery centers, freestanding emergency rooms, urgent care centers, and physician clinics in 20 states and the United Kingdom.
New medical debt reforms have been announced, which include holding providers and debt collectors accountable.
The Biden-Harris administration is targeting billing practices by providers and collectors with new reforms designed to ease the burden of patient medical debt.
As part of an initiative to combat high medical costs, Vice President Kamala Harris announced actions across four areas to help protect American families from harmful practices.
Central to the reform is holding providers and collectors accountable by opposing non-predatory payment plans and aggressive collection methods.
To better understand how to discourage these approaches, the Department of Health and Human Services will request data from more than 2,000 providers on medical bill collection practices, lawsuits against patients, financial assistance, financial product offerings, and third-party contracting or debt buying practices. That information will then be considered for grantmaking decisions, policy recommendations, and potential violations.
Additionally, the Consumer Financial Protection Bureau (CFPB) will investigate credit reporting companies and debt collectors that violate patients' rights to uncover coercive credit reporting and determine whether unpaid medical billing data should be included in credit reports.
The CFPB previously released a bulletin in January reminding debt collectors and credit bureaus of their legal obligations following the implementation of the No Surprises Act.
Medical debt is a wide-ranging issue, with nearly one in 10 American adults (23 million people) owing more than $250 in unpaid bills as of December 2019.
How those bills are collected can be potentially damaging for patients, especially those who are most vulnerable.
"Our administration is also taking action against the bad actors—the folks who violate consumers' rights," Harris said. "To force people to pay medical debt, some debt collection companies harass consumers with dozens of phone calls a week."
Harris continued: "That sort of harassment and intimidation is unethical and often it is illegal. And that is why the CFPB has made it a priority to hold debt collectors accountable."
All facilities and assets of the Iowa-based health system will transfer to Trinity Health, which had been operating MercyOne alongside Catholic Health Initiatives, now CommonSpirit, under a joint agreement since 1998.
The move allows Trinity Health to unify MercyOne's 16 medical centers, 27 affiliate organizations, and more than 420 care sites under one umbrella with the aim of improving patient access.
"True to our shared Catholic mission, our goal is to provide high-quality, compassionate care with the best patient/member experience possible," Mike Slubowski, president and CEO at Trinity Health, said in a statement. "We will accomplish that goal through a holistic approach, with a range of health services and technologies that are fully connected and coordinated. This agreement creates a fully integrated MercyOne to care for more people in a unified way."
Trinity Health, which spans 25 states, will transition MercyOne's common platforms into its own, including a single electronic health record, according to the news release. The result should allow the 3.3 million patients MercyOne serves each year to manage their care more easily and conveniently.
"We strongly believe this transition to become a full member of the Trinity Health family will result in a stronger, more cohesive health system better able to offer a convenient and personalized circle of care for all we serve," said Bob Ritz, president and chief executive officer at MercyOne.
Marvin O'Quinn, president and COO at CommonSpirit Health, said of the move: "While the current structure has been instrumental in growing our health care services in Iowa, we believe this decision is ultimately what is best for our patients, colleagues, and our communities."
The acquisition is subject to regulatory filings, with the transaction expected to be finalized by the summer.
The organization wants to improve on administrative process delays often caused by payers.
The Association of American Medical Colleges (AAMC) has joined other groups in supporting electronic prior authorization reform with the aim of alleviating the burden on patients and providers.
The ONC released arequest for information in January to seek comment on electronic prior authorization standards, implementation specifications, and certification criteria to help potential future rulemaking.
Similarly, the AAMC encourages solutions that have been fully developed and tested prior to industry rollout, stating "ONC and CMS should approach potential changes to regulatory schemes judiciously to effectively update and create standard transactions without unduly burdening health care payment processes."
As it relates, prior authorization can have the unintended consequence of negatively affecting patient outcomes. The AAMC points to a recent physician survey conducted by the American Medical Association (AMA) in which 80% of respondents said that patients abandon treatment due to authorization struggles with their health insurer.
"The AAMC recommends that any regulation standardizing prior authorization processing include requirements that health plans issue prior authorization determinations in a timely manner to ensure that patients benefit from process improvements," the group said.
The same AMA survey also found that 88% of responding physicians describe the burden of completing prior authorization as high or extremely high. Streamlining the process has the potential to significantly reduce provider burnout, according to the AAMC.
While the AAMC is mindful of the resources required to implement changes, it believes reform would be beneficial in the long run if insurers did their part and followed suit.
"Provider up-front investment to adopt and implement electronic prior authorization standards is worthwhile to improve care delivery so long as payers and health plans broadly adopt policies to support the use of electronic prior authorization to improve processing and approving requests," the AAMC concluded.
The Lown Institute found that nearly 83% of health systems spent less on charity than the value of their tax breaks, resulting in an $18.4 billion total 'fair share deficit.'
Several of the biggest nonprofit health systems in the country are also among the primary offenders in the failure to invest significant tax breaks into charitable contributions, according to a new study by the Lown Institute.
The healthcare think tank found $18.4 billion in total unrealized community investment between the systems, which could have instead been allocated for housing, food, and furthering health equity.
Using the Lown Institute Hospitals Index, the study compared more than 1,800 hospitals across 275 nonprofit hospital systems to calculate "fair share spending"—how much each system spent on charity in relation to the value of its tax exemption. The data was pulled from hospital tax filings from the fiscal year ending 2019, the most recent year available for most hospitals.
Of the 275 nonprofit systems examined, 227 spent less on charity than the value of their tax breaks. Community investment in the study included community health improvement activities, contributions to community groups, community building activities, and subsidized healthcare services.
Several of the hospitals that had the largest fair share deficits from last year are also part of the systems that appear on this year's list.
Biggest offenders
The 10 systems with the largest deficits accounted for $5.6 billion of the total fair share deficit (30%).
According to the study, many of these systems also received hundreds of millions from the 2020 CARES Act—meant to provide financial relief during the COVID-19 pandemic—and ended the year with excessive revenue.
The total fair share deficit was concentrated in certain regions, with seven states accounting for over $1 billion—California, Massachusetts, Pennsylvania, Ohio, Illinois, New York, and Michigan.
RANK
HOSPITAL SYSTEM
FAIR SHARE DEFICIT
1
Providence Saint Joseph Health
-$705 M
2
Trinity Health
-$671 M
3
Mass General Brigham*
-$625 M
4
The Cleveland Clinic Health System
-$611 M
5
UPMC
-$601 M
6
University of Pennsylvania Health System
-$571 M
7
Catholic Health Initiatives
-$515 M
8
Advocate Aurora Health
-$498 M
9
Dignity Health
-$456 M
10
Ascension Health
-$388 M
*Used FYE 2018 data
When reached for comment, Providence Saint Joseph Health said in a statement: "The Lown report paints an incomplete picture of the Providence family of organizations' community investments. The methodology used falls short by failing to account for all forms of community benefit, including the unpaid costs of Medicaid and other means-tested government programs.
"For example, uncompensated care as a portion of community benefit is considerable and without it, the numbers in the report are incomplete. Providence organizations serve a large proportion of patients who rely on government programs for health insurance or are uninsured. In 2019, Providence organizations provided $816M in uncompensated costs of Medicaid, alone.
"In 2019, our total community benefit investments totaled $1.5B. Included was free or low-cost care (charity care) and the costs of uncompensated care for government-funded programs, along with proactive investments such as community health improvement programs and services and subsidized health services."
The American Hospital Association (AHA) released their own statement criticizing the Lown Institute's report and defending hospitals' use of financial resources.
"The Lown Institute’s latest report on hospital community benefits is an obvious example of relying on pre-conceived notions and faulty methodology to draw inaccurate conclusions," the AHA stated. "The report cherry-picks categories of community investment while simply ignoring others, such as researching life-saving treatments and cures and training and educating the next generation of caregivers. It overlooks many of the essential contributions hospitals make to their communities that are critically important, especially during the pandemic."
Best performers
Hospitals that were considered to have paid their fair share committed at least 5.9% of their overall expenditures to charity and community investment.
RANK
HOSPITAL SYSTEM
FAIR SHARE SURPLUS
1
Memorial Hermann Healthcare System
$147 M
2
Wellstar Health System
$144 M
3
The Nebraska Medical Center
$108 M
4
Christus Health
$93 M
5
Houston Methodist
$80 M
6
Hackensack Meridian Health
$74 M
7
Baptist Memorial Health Care Corporation
$64 M
8
UCHealth
$62 M
9
Yale New Haven Health System
$56 M
10
Methodist Health System
$53 M
While there are systems that do their part by putting money back into the community, the discrepancy between the systems' fair share surplus and fair share deficits is significant.
"Would half a billion in taxpayer dollars be better spent by directly funding addiction, food insecurity, or homelessness efforts?" Dr. Vikas Saini, president of the Lown Institute, said in a statement. "We should all be asking those types of questions given the vastness of these sums and the significant public health crises many communities are facing."
The full 2022 Lown Institute Hospitals Index, with rankings across more than 50 metrics, is expected to be released in late June.
Since taking effect on January 1, the No Surprises Act protects patients from unexpected medical charges after scheduled items or services are completed.
This affects the front-end revenue cycle, which must be adjusted to effectively implement requirements for both providers and patients.
To ensure compliance with the No Surprises Act, CMS has continued to release resources outlining answers to common questions. After recently providing updates on good faith estimate requirements, CMS has now published two more sources of material on implementation.
According to the newly published guidance, CMS outlines that providers and healthcare facilities must publicly disclose patient protections against balance billing. Providers must also give a good faith estimate of expected charges to uninsured or self-pay patients at least three business days before a scheduled service (or upon request), according to the new guidance.
Some of the other topics covered in the guidance includes:
Additional new surprise billing requirements and prohibitions
Provider and facility requirements
What types of patients are covered
What types of providers the requirements apply to
What waiving surprise billing protections entails for patients
Administrative and entity fees for the Federal Independent Dispute Resolution process
Meanwhile, highlights from the FAQs on good faith estimates for uninsured and self-pay patients include:
When providers are required to provide a diagnosis code
If good faith estimates need to be provided after an initial visit
How a change in insurance status from the time of scheduling to the time of service affects a good faith estimate
