- In a recent letter to President-Elect Trump, the American Hospital Association (AHA) urged the upcoming administration to continue the value-based reimbursement transition by developing more effective alternative payment models, promoting telehealth, and expanding Advanced Alternative Payment Model options under MACRA.
“Hospitals have been at the forefront of innovative new payment and care delivery models, such as accountable care organizations (ACOs) and bundled payments,” wrote Richard J. Pollack, AHA President and CEO.
“We believe it is critically important that the healthcare sector contribute to transform toward providing greater value for its services, and these new models - which require significant upfront investment – hold the promise to improve patient convenience, care coordination and quality, while achieving cost savings,” he continued.
The AHA called on the upcoming administration to “preserve and improve upon new payment and delivery models to drive adoptions of those that are more effective in raising quality and reducing cost.”
As a means of preserving and continuing value-based reimbursement, the industry group suggested that the administration eliminate utilization and payment barriers for telehealth, remote patient monitoring and other similar technologies.
Reimbursement restrictions on telehealth and other health IT services has limited the use of these treatments even though they could improve care delivery for patients. A 2014 survey in the Journal of the American Board of Family Medicine showed that most primary care physicians have shied away from using telehealth because they are not reimbursed for it.
According to the AHA, other similar reimbursement restrictions should be removed to promote care delivery across the care continuum, including the skilled nursing three-day stay rule and prospective beneficiary assignment from all ACO models.
The AHA also asked the Trump administration to expand the Advanced Alternative Payment Model definition under MACRA “to allow more clinicians who partner with hospitals on new models to achieve payment incentives.”
Currently, the only approved Advanced Alternative Payment Models are the Comprehensive End Stage Renal Disease (ESRD) Care Model, Comprehensive Primary Care Plus program, Medicare Shared Savings Program ACOs in Tracks 2 and 3, Next Generation ACOs, and the two-sided financial risk track of the Oncology Care Model.
While CMS announced in October that it plans to re-open applications for several approved models for 2017 participation and develop new risk-based alternative payment model options for future participation, the AHA called on the upcoming administration to create more options to allow more eligible clinicians to earn value-based incentive payments.
The most recent suggestion stemmed from the AHA’s statement on the final MACRA implementation rule. In October, the organization expressed disappointment that the final rule continued to “narrowly define Advanced Alternative Payment Models, which means that less than ten percent of clinicians will be rewarded for their care transformation efforts.”
Additionally, the AHA called for further healthcare payment reform, including reducing administrative burden for providers and decreasing hospital costs.
The organization stated that the administration could save billions annually and help providers spend more time on patients rather than paperwork by implementing the following changes:
• Eliminate Stage 3 Meaningful Use program to prevent hospitals from investing in EHR upgrades for the sole purpose of meeting regulatory requirements
• Develop exception safe harbors and waivers under the Anti-kickback stature to protect clinical integration projects and revise the Stark law to protect clinical arrangements that meet the Anti-kickback safe harbor to help providers and hospitals to collaborate to improve care
• Standardize the federal merger review process for the Department of Justice and the Federal Trade Commission to better support beneficial hospital mergers and transformation
• Remove regulations that limit post-acute care access, including the long-term care 25 Percent Rule and the pre-claim review demonstration for home health agencies in select states
• Modify Recovery Audit Contractor contracts to include a financial penalty for high rates of incorrect claim denials that create unnecessary appeals
The AHA also recommended that the Trump administration focus on lowering hospital costs by decreasing prescription drug rates.
The organization urged the administration to “adopt a comprehensive set of solutions to address escalating drug prices, including providing support for the introduction of generic alternatives, discouraging anti-competitive tactics such as ‘pay-for-delay’ and ‘evergreening,’ improving access through drug reimportation, providing mandatory rebates and placing requirements around direct-to-consumer advertising.”
The upcoming administration should also support the 340B Drug Pricing Program, which allows eligible hospitals to lower prescription drug rates for expensive outpatient medications, the AHA continued.
In October, the AHA found that hospitals saw a 23 percent increase in inpatient prescription drug spending from 2013 to 2015. The increased spending has been more pressure on hospital revenue cycles, the report stated.
Other ways to lower hospital costs, according to the AHA, included challenging health insurance mergers, exploring policies to control medical liability, and Medicare reforms, such as adequate payment, protecting individuals from financial burden, combining Medicare Parts A and B, and raising the Medicare eligibility age.
“As your Administration and Congress look to address the healthcare needs of Americans, we look forward to working with you on solutions that will ensure the adoption of sound public policies that result in more affordable, accessible, high-quality care,” the letter concluded. “Given that healthcare represents a significant portion of the economy and essential public services, we urge you not to make any abrupt changes that could lead to significant instability for patients, providers, insurers and others.”