Part B News – 2016 predictions: Use of ACP codes lags, docs struggle with quality reporting and more
Part B News asked several industry sources including MSOC Health’s Jeanne Chamberlin to predict 2016 trends on a variety of topics. Prepare your practice for the new year with these insights. Read the entire article here. For a full debrief of Jeanne’s predictions, see her responses below.
PART B NEWS: Will practices bill the new advance care planning codes? Why or why not?
MSOC HEALTH: It will take some time for practices to start using this code. For one reason, many physicians are not comfortable having these discussions with patients. It’s more likely that larger healthcare systems, particularly those that are Medicare ACOs will encourage providers in order to try to reduce costs during the last year of life. They seem more likely to provide training to physicians or set up a process where the patient is passed off to a mid-level or LCSW to provide this counseling. Since there aren’t national coverage determinations, it will be up to each MAC to set up their own requirements and this will likely make it more difficult for specialty associations to provide advice and training on how to bill.
PART B NEWS : Penalties – and potential revenue – for the value-based modifier (VBM) are ramping up. How prepared are practices in 2016? What percentage will receive a maximum 4% penalty in 2018 based on their 2016 reporting? What should practices be doing in 2016 to avoid penalties or achieve bonuses?
MSOC HEALTH: Practices are not well informed about this program. Large healthcare systems have now had several years of experience (practices with 100+ started with the 2013 program year) and have dedicated staff focused on Quality Initiatives. Small and mid-sized independent practices will be surprised when they get penalties; their administrators don’t have the luxury of focusing just on these programs but have to fit it into an already full schedule of activities. For these practices, the VBM program really feels like a black box where the practice gets dinged for something you did or did not do 2 years ago, and on the cost side where you have very little that you can do to impact the results. Programs like this will drive some practices to join larger health systems that have staffs to deal with them.
Practices need to take the quality side of VBM very seriously. They need to identify the best measures to reflect the quality of care they provide and then focus on the processes and systems that allows them to document (and improve on) their performance on these measures. The providers have to be involved in selecting the measures and have to care about their performance. Many of the measures are less than perfect, but they are what we have and like it or not, CMS and other payers are going to use them. CMS will be publishing the quality measures reported on the Physician Compare website. With so little other information available about the quality of care provided by individual physicians, this will become the go-to site, not just for Medicare beneficiaries (or their adult children/caregivers) but for patients of all ages. Commercial payers are likely to use negative quality scores (or the fact that none are reported) as one of the key ways they determine which will be invited into their narrow network products. Savvy administrators won’t wait for payers and patients to find the Physician Compare website, they will market their high scores to patients and payers on their own websites and in contract negotiations.
PART B NEWS : What developments related to MIPS do you see CMS unveiling in 2016? What should practices be doing now to prepare?
MSOC HEALTH: The first reporting period under MIPS is 2017, so the details will have to be unveiled in 2016. We will see the proposed rules in the summer and the final rules in November with the publishing of the 2017 Physician Fee Schedule Rule. Because this doesn’t provide a lot of time for practices to adapt, the program will not be very different than the current Modified Stage 2 MU and VBM programs. The Quality Improvement component will likely be based on attaining recognition or certification by an outside organization (NCQA’s PCMH or PCSP program, Specialty Board MOC programs, etc.).
MACRA legislation is designed to reward providers who are willing to take on financial risk. Fear, uncertainty and doubt will drive smaller practices toward joining larger health systems or forming supergroups. In the short-term, we’ll see an increase in participants in Alternative Payment Models but many of these will not have the expertise to manage the financial risk and will not be able to influence patient behavior sufficiently to be successful long-term. As APMs fail or become too dictatorial, entrepreneurial providers will split back out and create cash-only practices similar to dentists and private-market psychiatrists. They’ll be out-of-network with all commercial plans and will be non-participating with Medicare; their marketing focus will be to differentiate themselves on quality and service at a reasonable, transparent price.
PART B NEWS : Is 2016 the year that will see momentous transition to advanced payment models (APMs)? If so, what models will lead the way (e.g., medical home, ACO, etc.)?
MSOC HEALTH: There will be movement of some practices to ACOs and other Alternative Payment Models, but not ‘momentous’. Rural areas will be largely left out of the transition all together. Outside Medicare, APMs will focus more on bundled payments.
PART B NEWS : Will the trend of hospitals acquiring physician practices continue? Why or why not? What effect will that have on practices that stay independent?
MSOC HEALTH: It will get harder and harder for physicians to ‘sell’ their practice. It’s easier and cheaper for hospitals to grow their own medical practices by recruiting new providers and then driving the independents out of business. Medical schools are starting to make fundamental changes in how they train physicians with a focus on team-based care rather than a rugged individualism culture. Along with a growing desire of graduates for work-life balance, this will encourage new physicians to seek employment rather than becoming a small-business owner. Those that are entrepreneurial will look closely at specialty specific for-profit franchises, rather than setting up their own independent practice.
PART B NEWS : Can practices expect more or less audit activity next year? What codes or services do you think auditors will target in 2014?
MSOC HEALTH: We’ll start to see an increase in audits focused on data submitted for quality measures through PQRS/VBM.
PART B NEWS : What are new revenue streams that you expect practices to tap into to make up for reimbursement cuts?
MSOC HEALTH: Becoming a cash-based business. Improved collections prior to service, for example through credit-card-on-file programs. Selling products (vitamins, health aids). Virtual office visits using smartphone technology to connect to patients to provide reimbursable services or as self-pay. More focus on understanding true cost of specific services in order to calculate profit and determine which ancillary services to stop providing (one likely candidate is in-office labs beyond the basics). Using technology to eliminate labor costs (for example, let patients schedule their own appointments on-line or use kiosks for check-in).
PART B NEWS : What will the biggest hurdles for achieving meaningful use attestation in 2016? What % of practices do you predict will achieve stage 2 in 2016? When providers can voluntarily move to stage 3 in 2017, will it be smooth sailing or a rough ride?
MSOC HEALTH: The Modified Stage 2 Rules and higher penalties will pull many that were on the edge, back on track. Stage 2 was a step too far, but the Modified Stage 2 seems more attainable. Some practices will still struggle with the 10% electronic summary of care requirement because not enough providers in their local market are ready to accept the referrals electronically. For specialty practices, the public health registry requirement will be difficult due to lack of information about ‘specialized registries’ and the requirement that the provider be registered by March 1, 2016 for the 2016 reporting year. As currently configured the Stage 3 rules will move us back to the crisis zone with vendors and providers dropping out and giving up. The Meaningful Use program provided an important stimulus to move the healthcare system forward into the electronic age. Once you shock the patient to get their heart started, you don’t keep shocking them. Providers and vendors need time to take a breath and settle into new routines, then allow the market forces to drive the next steps forward.
PART B NEWS : What other trends do you see for 2016?
MSOC HEALTH: Telehealth/Virtual Office Visits. Retail Medicine (in drug stores, Wal-marts, etc.). Move toward more price transparency. Fitbits and smart-phone apps geared toward patient self-management. Insurance industry consolidation which will limit the potential for any negotiations on contract terms/reimbursement rates. CMS will limit narrow networks due to consumer demand, but it may cause ACA initiatives to begin unraveling.