Health Care Reform: Impact on the Audiology Profession 2012 Health Care Reform The Patient Protection and Affordable Care Act (ACA) Audiologists need to be successful in showing the value of our services. WHY? HOW? WHEN? ACA • “On March 23, 2010, President Obama signed • the Affordable Care Act. The law puts in place comprehensive health insurance reforms that will roll out over four years and beyond,….” Audiologists will be increasingly paid for patient outcomes (value-based purchasing) rather than number of tests or number of visits ACA • Medicare’s current fee-for-service payment • systems, which pays on the basis of quantity and consumption of resources, does not support this vision for quality health care. Value-based purchasing (VBP) aligns payment more directly to the quality and efficiency of care provided by rewarding providers for their measured performance across the dimensions of quality. ACA • Congress and Presidential Administrations over • the last 20 years have moved Medicare from prospective payment systems to value-based health care purchasing initiatives (paying for results) rather than the number of tests or services, regardless of outcomes. The ACA sends a strong signal that QUALITY will be a central driver of health care reform changes. ACA • $75 million annually appropriated by the ACA for quality measure development between 2010 and 2014. ACA • In an environment that rewards value and quality, attention to outcomes measurement and improvement will be essential to the success of organizations across the health care system. (Sennett, C., MD, PhD. American Health & Drug Benefits; 2010-2011) ACA • Milliman’s Health Care Reform Briefing contends that “restructuring the payment system can motivate providers to perform, and payers and patients to pay for, only those procedures consistent with the best evidence and the needs of the patient.” (Cornett, B. S. ASHA; 8/3/2010) ACA Opportunities for Quality Outcomes Measurement and Reporting • Value-based purchasing creates pressure to perform • Performance must be quantifiable • Development of metrics to measure all facets of health care performance will be a key element of the reform process and is funded by reform legislation ACA • More robust measures of clinical quality and outcomes will emerge, including: Health outcomes and functional status of patients Management and coordination of care across episodes of care and provider settings Care transitions for patients across the continuum of providers, health care settings, and health plans. ACA • Prohibition against discrimination of providers • by health plans The provider non-discrimination provision reads in part: “A group health plan…or individual health insurance coverage shall not discriminate with respect to participation under the plan or coverage against any health care provider who is acting within the scope of that provider’s license or certification under applicable State law.” ACA – MPFS Examples of Quality Outcomes Measurement & Reporting Today: • Older systems of quality measurement will be expanded, such as the Physician Quality Reporting System (PQRS) formerly the Physician Quality Reporting Initiative (PQRI) introduced by CMS. PQRS will become a requirement, that is, quality reporting will no longer be an option. ACA - MPFS • In 2010, private-practice audiologists enrolled • as Medicare providers began to participate in the Medicare Physician Quality Reporting System. PQRS is a voluntary program designed to improve the quality of care to Medicare beneficiaries. Private-practice health care professionals who participate in PQRS by reporting on approved quality measures are eligible for a 0.5% incentive payment from 2012-2014. MPFS • The final 2012 Medicare Physician Fee Schedule contains five audiology measures. • Starting in 2015, eligible providers who do not satisfactorily report on quality measures will be subject to penalty ACA • Accountable Care Organizations (ACOs) are a method of integrating local group physician practices with other members of the health care system and rewarding them for controlling costs and improving quality. • Hospitals, primary care doctors, specialists and possibly even nursing homes and home care agencies would collaborate in an ACO, which would coordinate care and payment for care of participating patients. ACA • Some compare the concept to a construction contract with the ACO having the role of a general contractor and providers that of subcontractors. • The theory is that there will be increased communication among providers leading to better care and less duplication of services, such as laboratory tests, that will reduce overall health care costs. (Thompson, M. Post-Star; 4-11-2010) ACA Accountable Care Organization Instead of paying individually for each visit or medical procedure, Medicare or Medicaid would pay a set periodic payment, regardless of the amount of services, to the ACO, which would pass along proportionate payments to participating providers. ACA 1. An ACO may provide services with in-house 2. staff, or contract with other provider organizations. An ACO may prefer to contract with a single hearing entity rather than separately with multiple hearing organizations. Audiology services might be incorporated into diagnostic or rehab contracts, by independent audiology contracts, or through ENT practices that are ACO participants. ACA - ACO • ASHA submitted comments in response to the proposed ACO regulations issued on April 7, 2011. ASHA urged CMS to require ACOs to: Make audiology services accessible to patients. CMS responded that market forces will determine the need for the range of services offered. Allocate an equitable portion of shared savings to audiologists. CMS stated that it does not have legal authority to dictate how shared savings are distributed. Encourage the use of telehealth services provided by audiologists. In response, CMS announced that it is preparing a separate incentive package, not limited to ACOs, which includes telehealth services beyond what is currently reimbursed under fee-for-service Medicare. ACA Providers will be paid for managing outcomes rather than volume of visits. With emphasis on functional status, and the need to show efficiency – for AR the International Classification of Functioning, Disability, and Health (ICF) may be useful for understanding and measuring health outcomes. • See Gagné, J. & Jennings, M. B. (2011, July 05). Incorporating a Client-Centered Approach to Audiologic Rehabilitation. The ASHA Leader. ACA The International Classification of Functioning, Disability, and Health (ICF) provides a framework for structuring clinical care to address increasing demands for efficiently achieving functional outcomes. ACA “Bundled” Payments Under a “bundled” payment model, providers receive a single payment for a defined set of services. ACA • Bundled payment models disincentivize the use of those providers whose services increase utilization and cost without adding perceived value. • Clinicians will be chosen for the “bundle” who can produce results efficiently, and can perform collaboratively. ACA Bundled Payment Initiative Under National Health Reform CMS seeking applications Oct.2011 – March 2012 • Model 1: Acute hospital stay only • Model 2: Hospital stay + post-acute care associated with • • • the stay Model 3: Post-acute care only Model 4: Inpatient stay including all physician services, etc. Distinct from National Pilot Program by 1/1/13 ACA Bundled Payment Goals • Decrease cost of an acute episode and associated post-acute care • Foster quality improvement • Stimulate development of new evidencebased knowledge • Applicant agrees to 2 to 3% discount of inpatient and other payment rates. Pre-ACA In summary, the Congressional Research Service (CRS) prepared a report (2006) for Congress on pay-for-performance in health care, noting: • “Many health care industry leaders and policy makers have joined the call to pay health care providers different amounts based on variation in the quality of their services as determined through their achievement on quality performance measures.” Not a New Concept The 2006 CRS report Pay-for-Performance in Health Care opens with: If a physician make a large incision with an operating knife and cure it, or if he open a tumor (over the eye) with an operating knife, and saves the eye, he shall receive ten shekels in money. If a physician make a large incision with the operating knife, and kill him, or open a tumor with the operating knife, and cut out the eye, his hands shall be cut off. — Code of Hammurabi, c. 1750 B.C. www.asha.org
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