Category Archives: CMS

CMS Greenlights Outpatient Total Knee Replacement: What it Could Mean for Medical Travel

According to an article in MedCityNews.com, the Center for Medicare and Medicaid Services (CMS) removed total knee arthroplasty (TKA) from the Inpatient-only list in November.

This will effectively allow eligible Medicare patients to have the surgery in outpatient departments of local hospitals beginning this month.

The article also mentioned that CMS did not add TKA’s to its list of payable procedures at ambulatory surgical centers (ASCs).

This will give hospitals an important head start on a growing outpatient competitor lobbying hard for the agency’s blessing, the article stated.

CMS will continue to review ASCs safety and feasibility of total joint replacement, which is a signal that change is coming. If it does so, it will pose a threat to hospital revenue.

What this may mean for medical travel is that if the cost savings are significant from allowing outpatient, and eventually ASC total knee replacement, then outbound medical travel facilities catering to such clients will see a drop in patients choosing to go abroad for such surgeries.

To that end, the industry must monitor CMS’ position on ASCs and knee replacement, as well as determine if domestic hospitals are drawing away customers because the procedure can be done on an outpatient basis.

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Models: Here We Go Again

My readers will remember that I have been critical of CMS’ multitude of models for health care payments and such from my articles, Models, Models, Have We Got Models!, Illogical!, or Regulation Strangulation.

So it comes as no surprise that CMS is unveiling another model for a voluntary bundled payment program.

The unveiling was reported today in FierceHealthcare. com. Called the Bundled Payments for Care Improvement (BCPI) Advanced model, it is the first model launched by CMS under the current political regime now occupying the White House.

As I have always maintained, the more models, the more complex, confusing and dysfunctional the health care system gets in the US. But it seems CMS never learns, and until the American people stand up to the medical-industrial complex and demand single-payer, damned the torpedoes to their profits and bottom-lines, the better our health care system will get.

Today, someone posted an article about single-payer on LinkedIn and most of the folks who responded did so with negative views about single-payer that indicated that they had drunk the kool-aid fed to them by the medical-industrial complex and their political allies.

They made the claim that countries that have single-payer have seen a decline in care, and that people hate it. So I asked the question, if it is so bad, why aren’t they adopting our system? It is because theirs works.

They don’t have too many models and regulations, and they get great quality of care. Yes, there are problems and they are not perfect systems, but nothing ever is. The truth is we are still the only Western country without single-payer, and CMS’ models are one reason why.

Here is the link to the article.

Illogical!

Picking up where I left off last week with my post, Regulation Strangulation, regarding too much regulation, a series of articles from earlier this week, published in various health care journals and magazines, discussed a new scheme the good folks at CMS have cooked up to make our health care “system” better. (Or worse, depending on whether you have drunk the kool-aid yet)

You may recall my post from late last year, Models, Models, Have We Got Models!, that reported that CMS was launching three new policies to continue the push toward value-based care, rewarding hospitals that work with physicians and other providers to avoid complications, prevent readmissions and speed recovery.

In that article, I mentioned the various models CMS was implementing. My view then, as it remains today, is that these models have not worked, and have only made matters worse, not better.

So when CMS unveiled their latest scheme recently when Administrator Seema Verma spoke at the Health Care Payment Learning and Action Network (LAN) Fall Summit, this is what she said:

The LAN offers a unique and important opportunity for payors, providers, and other stakeholders to work with CMS , in partnership, to develop innovative approaches to improving our health care system. Since 2015, the LAN has focused on working to shift away from a fee-for-service system that rewards volume instead of quality…We all agree that quality measures are a critical component of paying for value. But we also understand that there is a financial cost as well as an opportunity cost to reporting measures…That’s why we’re revising current quality measures across all programs to ensure that measure sets are streamlined, outcomes-based, and meaningful to doctors and patients…And, we’re announcing today our new comprehensive initiative, “Meaningful Measures.”

Let’s dissect her comments so we can understand just how complicated this so-called system has become.

  1. Develop innovative approaches? How’s that working for you?
  2. Improving our health care system? Really? What planet are you living on?
  3. Financial cost? Yeah, for those who can afford it.
  4. Revising current quality measures? Haven’t you done that already after all these years?
  5. “Meaningful Measures”. Now there’s a catchy phrase if I ever heard one. You mean they weren’t meaningful before?

You have to wonder what they are doing in Washington if this is the level of insanity and inanity coming out of the bureaucracy on top of our health care system.

In an article in Health Data Management, Jeff Smith, vice president of public policy for the American Medical Informatics Association stated the following regarding the new CMS initiative.

According to Smith, “the goals are laudable, but the talking points have been with us for several years’ now…measurement depends on agreed-upon definitions of quality, and in an electronic environment, it requires access to and use of computable data. If CMS is going to turn these talking points into reality, it will need to put forth far more resources and commit additional experts to a complete overhaul of electronic quality measures for value-based payments.”

Mr. Smith’s comments are at least an indication that not everyone goes along with CMS every time they unveil some new initiative, model, or program, but again we see the words associated with the consuming of health care being used in discussing the current state of affairs. Terms like “value-based payments”, and “quality measures”, and “financial/opportunity cost”, etc., only obscure the real problem with our health care system. It is a profit-driven system and not a patient-driven system.

Let’s push on.

A report mentioned Monday in Markets Insider showed that 29% of total US health care payments were tied to alternative payment models (APMs) in 2016, compared to 23% in 2015, an increase of six percentage points. These APMs were discussed previously in Models, Models, Have We Got Models!,

The report was issued by the LAN, and is the second year of the LAN APM Measurement Effort (try saying that three times fast). They captured actual health care spending in 2016 from four data sources, the LAN, America’s Health Insurance Plans (AHIP), the Blue Cross Blue Shield Association (BCBSA), and CMS across all segments, and categorized them to four categories of the original LAN APM Framework. (Boy, you must be tired trying to remember all these acronyms and titles!)

Here are their results:

  • 43% of health care dollars in Category 1 (traditional FFS or other legacy payments)
  • 28 % of health care dollars in Category 2 (pay-for-performance or care coordination fees)
  • 29% of health care dollars in a composite of Categories 3 and 4 (shared savings, shared risk, bundled payments, or population-based)

Speaking of shared savings, an article in Modern Healthcare reported that CMS’ Medicare shared savings program paid out more in bonuses to ACO’s than the savings those participants generated.

As per the report, about 56% of the 432 Medicare ACOs generated a total of $652 million in savings in 2016. CMS paid $691 million in bonuses to ACOs, resulting in a loss of $39 million from the program.

Chief Research Officer at Leavitt Partners, David Muhlestein said, “Medicare isn’t saving money.”

This is attributed to the fact that 95% of the Medicare ACOs (410) participated in Track 1 of the Medicare Shared Savings Program. Only 22% participated in tracks 2 and 3.

Two more articles go on to discuss a Medicare bundled-pay initiative and the Medicare Merit-based Payment System (MIPS) .

What does this all mean?

It has been long apparent to this observer that the American health care system is a failure through and through. Sure, there are great strides being made daily in new technology and therapies. A member of my family just benefited from one such innovation in cardiac care. But luckily, they have insurance from Medicare and a secondary payor.

But many do not, and not many can afford the second level of insurance. From my studies and my writing, I have seen a system that is totally out of whack due to the commercialization and commodification of health care services.

And knowing a little of other Western nations’ health care systems, I find it hard to believe that they are like this as well. We must change this and change this now.

If Medicare is losing money now, with the limited pool of beneficiaries, perhaps a larger pool, with little or no over-regulation and so many initiatives, models, and programs, can do a better job. Because what has been tried before isn’t working, and is getting worse.

The logical thing to do is to make a clean break with the past. Medicare for All, or something like it.

 

 

CMS Proposes to Allow States to Define Health Benefits

A connection of mine today posted a link to a CMS Fact Sheet in which they propose to allow states to define essential health benefits beginning January 1, 2019.

According to the fact sheet, this rule is intended to increase flexibility in the individual market, improve program integrity, and reduce regulatory burdens associated with the PPACA in the individual and small group markets. (See my post, “Regulation Strangulation“)

The rule also includes proposals that would provide states with more options in how the essential health benefits (EHBs) are defined for their state, it would also enhance the role of states related to qualified health plan (QHP) certification, and to provide states with additional flexibility in the operation and establishment of Exchanges, particularly the Small Business Health Options Program (SHOP) Exchanges.

Finally, they propose to permit states to reduce the magnitude of risk adjustment transfers in the small group market to minimize unnecessary burden, and proposes other changes that would streamline the Exchange consumer experience and the individual and small group markets.

What does this really mean?

Anytime the federal government attempts to allow the individual states to determine or define certain social benefits, we end up with a hodgepodge of rules, regulations, costs of impairment, etc.

We know that in certain states, the loss of a body part in one state has an impairment value different from the same body part in another state, according to the ProPublica report .

So when I see that CMS wants to allow states to define what essential health benefits are,  we have to ask ourselves, what do they mean by essential, and is one state’s essential health benefits, another state’s burden?

I understand that certain states, particularly so-called “Red” states with conservative governors and legislatures, will be free to decide that certain treatments and procedures are just too expensive for them to cover, or that they violate the ethical or moral sentiments of the community in the state, i.e., abortion, birth control, sexual reassignment surgery, etc.

Allowing states to define and decide what is essential and what is not, may be harmful to the health of many of their citizens, even if it saves the state money.

And I am rather leery of CMS’s desire to “strengthen” the individual or small group markets, because who decides what constitutes strengthening, and who makes those decisions and under what circumstances.

Rather than allowing legislators and governors to decide what medical care their citizens can receive in their state, rather than trying to shore up a market, whether it is the individual market or the group market, we should move to provide all Americans with the same health care and the same medical benefits, coast to coast, under a Medicare for All plan.

Anything less would be worse than what we have now, and would be more costly and more complex and confusing. This rule should be scraped.

Regulation Strangulation

The American Hospital Association (AHA) released a report that stated that there is too much regulation that is impacting patient care.

The report, Regulatory Overload Assessing the Regulatory Burden on Health Systems, Hospitals, and Post-acute Care Providers, concludes with the following assessment:

Health systems, hospitals and PAC providers are besieged by federal regulatory requirements promulgated by CMS, OIG, OCR and ONC, many of which are duplicative and cumbersome and do not improve patient care. In addition to the regulatory burden put forth by those agencies, health systems, hospitals and PAC providers are subject to regulation by additional federal agencies, such as the Department of Labor, the Drug Enforcement Administration, the Food and Drug Administration and by state licensing and regulatory agencies. They also operate under stringent contract requirements imposed by payers, such as Medicare Advantage, Medicaid Managed Care plans and commercial payers, which also require reporting data in different ways through different systems. States and payers contribute to burden through, for example, documentation, quality reporting and billing procedures layered on top of the federal requirements.
Regulatory reform aimed at reducing administrative burden must not approach the regulatory environment in a vacuum — evaluating the impact of a single regulation or requirements of a single program — but instead must look at the larger picture of the regulatory framework and identify where requirements can be streamlined or eliminated to release resources to be allocated to patient care.
In a previous post, Models, Models, Have We Got Models!, I said that from the beginning of my foray into the health administration world, I noticed that there were too many models, programs, and schemes dedicated to lowering costs and improving quality of care, that only raised the cost of health care and did not improve quality of care.
This is what I said then about all the models, programs, and rules promulgated by CMS over decades that have not made things better:
The answer was simple. Too many models, programs, rules, and so on that only gum up the works and make real reform not only impossible, but even more remote a possibility as more of these inane models are added to what is already a broken system.
So it seems that I was right even then, and now the AHA has proved it so. Why not scrap these models, programs, and rules and institute real reform…Medicare for All and be done with it?

Slight Increase in Average Medical Costs for Lost-Time Claims, Part 2

Ever since I began my MHA degree, I have analyzed the average medical cost severity for lost-time workers’ comp claims.

The average medical costs for lost-time claims have been rising steadily for the past two decades and only recently had a negative change.

The data for average medical lost-time claims severity comes from all jurisdictions where NCCI provides ratemaking services. The data is valued as of 12/31/2005, and accident year 2016 is preliminary as of 12/31/2016.

NCCI estimated that Accident Year 2016 was 5% higher than the corresponding 2015 value, as seen in Chart 2.

Chart 2.

Chart 2.

Source: NCCI’s Financial Call Data p Preliminary based on data valued as of 12/31/2016.

Comparing the above chart with last year’s chart, you will notice that there is a difference of 0.4% for 2015.

Looking at both charts, it is easy to see that the average medical cost for lost-time claims is still going up, and is now closer to $30,000. The trendline has been increasing since 1991.

I have been advocating every year that doing the same things repeatedly, and expecting different results is not only crazy, it is not lowering the average medical cost for lost-time claims.

It is also apparent that the enactment of the ACA has not done much to lower the average; in fact, just the opposite.

avg-med-cost-2016

NCCI went further in analyzing average medical cost by examining the cumulative change in the Medical Lost-Time Claim Severity from 1995 – 2016, as indicated in Chart 3.

Chart 3.

Chart 3.

Sources: NCCI’s Financial Call Data; Centers for Medicare & Medicaid Services p Preliminary based on data valued as of 12/31/2016.

The growth in the corresponding Personal Health Care Chain-Weighted Price Index (PHC), a proxy for medical care price inflation that responds to changes in the blend of different medical services over time, varied from 2.6% in 1995 to 1.3% in 2016p.

The takeaways here are:

  • In the latest year, medical lost-time claim severity increased by 5%, compared with a 1.3% growth in the PHC.
  • In 2015, medical lost-time claim severity decreased by 1.4%and the PHC presented its lowest increase in years (0.5%).

When the changes in medical lost-time claim severity is compared to the change in the growth of the PHC index over three time periods, any change over and above the change in PHC is considered a change in the utilization of medical services.

Key takeaways:

  • From 1995 to 2001, PHC increased by about 16% and utilization of medical services increased 56.6% for an overall combined increase in medial lost-time claim severity of 72%.
  • Compared with the prior period, 2002 to 2008 saw a similar rate of increase in the PHC, but utilization slowed
  • In the most recent period, the change in utilization is almost nonexistent.

The key takeaways for the five previous years, 2011 – 2015 are:

  • The majority of the observed changes are increases, indicating that the average medical benefit level across most states was higher in 2015 than in 2011.
  • Mississippi’s relative higher average medical severity change is primarily the result of larger losses.
  • Virginia is in the process of developing a medical fee schedule, which may put downward pressure on that jurisdiction’s average medical lost-time claim severity.

What does this mean for you?

This is the eighth Annual State of the Line report I have examined, and from all the data I have seen in this period, the average medical cost for lost-time claims has never shown a marked decrease with all the various methods employed to lower costs so many in the industry have touted.

And while there have been cases where costs have gone down for individual employers and states; overall, this is not the case. Perhaps it is due to medical cost inflation, or perhaps to the cost of health care generally, but either way it is not getting better.

Models, Models, Have We Got Models!

FierceHealthcare.com today reported that CMS (those lovely folks with all them rules), launched three new policies Tuesday that continue the push toward value-based care, rewarding hospitals that work with physicians and other providers to avoid complications, prevent readmissions and speed recovery.

The newly finalized policies are meant to improve cardiac and orthopedic care, and also create an accountable care organization (ACO) track for small practices, according to the report.

There will be three new cardiac care payment models for hospitals and clinicians who treat patients  for heart attacks, heart surgery to bypass blocked coronary arteries, or cardiac rehabilitation following a heart attack or heart surgery.

Federal officials said that the cost of their care…varied by 50% across hospitals and the share of patients readmitted to the hospital within 30 days also varied by 50%. Medicare, the article points out, spent more than $6 billion in 2014 for care provided to 200,000 Medicare patients who were hospitalized for heart attack treatment or underwent bypass surgery.

As for orthopedic care, the new payment model is for physicians and hospitals that provide care to patients who receive surgery after a hip fracture, other than hip replacement.

They also finalized updates to the Comprehensive Care for Joint Replacement Model, which began earlier this year.

So far, that’s three models. But wait, there are more where those came from.

There’s the new Medicare ACO Track 1+ Model, that has a more limited downside risk than other tracks in the Medicare Shared Savings Program (another model I discussed a while back in the post, “Shared Savings ACO Program reaps the most for Primary-care Physicians“).

These new five-year models provide clinicians with other ways to qualify for a 5% incentive payment through the Advanced Alternative Payment Model (APM) path under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) and the Quality Payment Program. (three more models — so many, in fact, I am losing count)

Why am I pointing out the problem with the release of new payment models?

I’ll tell you why. When I began my MHA (Masters in Health Administration) degree program, I took an online elective on Healthcare Quality. The textbook we read discussed how CMS over a period of several decades, created and instituted so many models and programs, that it made me wonder why our health care system was so complex, expensive and so out of whack compared to health care systems of other industrialized countries.

The answer was simple. Too many models, programs, rules, and so on that only gum up the works and make real reform not only impossible, but even more remote a possibility as more of these inane models are added to what is already a broken system.

Winston Churchill said that you can always count on Americans to do the right thing, after all the other things were tried. We are still on the trying part, and I am afraid we will never get to where Sir Winston said we would.