Vital Signs: A March 2024 wrap-up of revenue cycle management healthcare news

Welcome to “Vital Signs,” your go-to monthly digest of all things related to RCM tailored specifically for independent practices. Want more? Check out previous editions for the top insights and developments over the last few months.  

It has been a busy month as medical practices continue to regroup and recover from the Change Healthcare cybersecurity incident. However, there’s lots of other news to unpack as well. Here are 8 revenue cycle management (RCM) stories to put on your radar.  

The specifics: Update on last month’s reporting: Since the February 21 cyberattack on Change Healthcare, medical practices continue to feel the financial impact. At least 6 federal lawsuits were filed by providers against UnitedHealth and Change Healthcare between March 14 and March 20.

Why it matters: Some industry experts estimate that as many as 25% of physician practices exhausted their cash reserves during the cyberattack and recovery, and currently face catastrophic funding shortfalls.

What’s next: On March 15, Change Healthcare reported it restored its electronic payments platform. On March 18, Assurance, its medical claims preparation software, went back online. Its biggest clearinghouses went back online the weekend of March 23.

However, if you were (or continue to be) impacted by the cyberattack, you may be eligible for temporary funding assistance if you need it. Since March 18, Change Healthcare has advanced more than $2.5 billion to care providers through its Temporary Funding Assistance Program at no cost.

In addition, be sure to bookmark The Intake's daily updates page that continues to provide comprehensive industry updates regarding the Change Healthcare cybersecurity incident. And keep your eyes on a proposed bill that would enable advanced and accelerated payments for healthcare providers hit with a cyberattack as long as they and their vendors meet minimum cyber posture standards.

The specifics: On March 13, the Office for Civil Rights (OCR) announced it will initiate an investigation of Change Healthcare and UnitedHealth Group to determine whether a breach of protected health information occurred and whether both entities currently comply with HIPAA. 

Why it matters: While OCR is not currently investigating healthcare providers, health plans, and business associates that were tied to or impacted by the cyberattack, it reminds all entities of their regulatory obligations and responsibilities.

What’s next: Ensure business associate agreements are in place and that you provide timely breach notification to US Department of Health and Human Services (HHS) and affected individuals as required by HIPAA.

The specifics: Even despite the federal budget deal that reduced Medicare physician payment cuts from 3.37% to 1.68%, the AMA says it’s not enough and that the annual cycle of pay cuts must end. 

Why it matters: Experts say running a medical practice has become unsustainable. When adjusted for inflation in practice costs, Medicare physician payment declined 30% from 2001 to 2024.

What’s next: Stay abreast of AMA advocacy work to reform Medicare payment, including H.R. 2474, the Strengthening Medicare for Patients and Providers Act — bipartisan legislation that would provide physicians with an annual, permanent inflationary payment update. This article from KFF.org also outlines other potential solutions, including significant changes to the design of the quality payment program, bonus payments for advanced alternative payment models, a permanent add-on payment for services provided to low-income Medicare beneficiaries, and more.

The specifics: A new FAQ from CMS provides detailed information on how providers can bill several codes that took effect January 1, 2024, including caregiver training services, social determinants of health risk assessment, community health integration, principal illness navigation, and principal illness navigation peer support. 

Why it matters: As with any new CPT code, there is always uncertainty about how and when to report them to avoid denials. This FAQ includes important definitions, whether providers can furnish services via telehealth, whether there are limits on how often providers can bill services, who can perform the services, and much more.

What’s next: Review the FAQ and any links embedded into the document for additional resources to ensure compliance and revenue integrity.

The specifics: One recent study found that private equity (PE)-acquired physician practice sites increased from 816 across 119 Metropolitan Statistical Areas (MSA) in 2012 to 5,779 across 307 MSAs in 2021. 

Why it matters: Authors of the study concluded the findings raise concerns about competition and call for closer scrutiny by the Federal Trade Commission, state regulators, and policy makers.

2023 Tebra research also found that over half of Americans feel controlled by their health insurance, and private practice acquisitions could further limit their options. Acquisitions might also limit private practice providers by forcing them to incorporate into hospital systems where medical professionals suffer more burnout and feel less appreciated.

What’s next: Stay abreast of federal inquiries into PE involvement in healthcare, including a new request for information surrounding healthcare dealmaking. In this request, the Federal Trade Commission, Department of Justice’s Anti-Trust Division, and the HHS say they want to hear from the public on PE, health system, private payer, or other healthcare-related asset manager deals that “may increase consolidation and generate profits for firms while threatening patients’ health, workers’ safety, quality of care, and affordable health care for patients and taxpayers.”

The specifics: This recent article highlights doctors’ use of artificial intelligence (AI) to answer patient messages, take notes during exams, and more.

Why it matters: These tools may save doctors time and prevent burnout. However, experts say the tools also raise questions about trust, transparency, privacy, and the future of human connection.

What’s next: As doctors continue to explore AI solutions, they’ll need to decide whether (and how) to disclose this information to patients, whether (and how) to obtain consent, how to ensure accuracy and oversight, and more.

The specifics: CMS recently announced a new voluntary payment model that provides a one-time advanced shared savings payment and monthly prospective primary care payments to primary care providers in eligible Accountable Care Organizations (ACO). To qualify, these providers need to use innovative, team-based, person-centered proactive care. CMS will select approximately 130 ACOs to participate.

Why it matters: This model, known as the Primary Care Flex Model, is the latest example of the CMS Innovation Center’s investment in strengthening the primary care system. 

What’s next: Read up on the model, including frequently asked questions and a CMS fact sheet detailing payment overview. ACOs may begin submitting applications on May 20, 2024.

The specifics: The Association of American Medical Colleges (AAMC) recently published an analysis projecting a shortage of between 13,500 and 86,000 physicians by 2036. AAMC says the numbers could be higher if investments in graduate medical education do not continue to grow. This includes a projected shortage of between 20,200 and 40,400 primary care physicians specifically. 

Why it matters: As the demand for physicians continues to grow, a projected shortage could be catastrophic in terms of maintaining (and improving) patient access as well as addressing health inequities. 

What’s next: How might these projections impact your medical practice moving forward? Might they affect the types of services you’ll offer, in what geographic location you’ll practice, or what additional non-physician providers you might hire?