NARHC Forum
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| 5/9/2022 @ 4:12:00 PM
Post 1 of 4
Contributor: Misty Duncan, Caldwell Family Clinic
Does anyone have policies or Quality information for RHCs? I am new to Quality and we are going to be opening our first RHC this summer so looking for some resources. This is new territory for me all around. I know there are not official requirements aside from the Program Evaluation but wondering what other things have been useful. TIA Misty - Quality, SCHD1 5/10/2022 @ 10:33:00 AM
Post 2 of 4
Contributor: Charles James, North American Healthcare Management Services
Misty - There is a lot happening with "quality", and the discussion has most certainly reached RHCs. Quality Activity generally means identifying patient clinical and organizational needs, then finding measurable ways to improve them. The objective is to improve the health outcomes of patients and reduce cost to the system. The quality program we are all most familiar hearing about is MIPS (Merit-based Incentive Payment System). These payments are directly related to services reported on a Medicare 1500, and obvious problem for most RHCs. There is currently no financial penalty on RHC claims for NOT participating in MIPS. There IS a financial penalty on fee-for-service/non-RHC claims that is difficult for most RHCs to get out of (due to our low 1500 claim volume).
An alternative to MIPS is a Medicare Shared Savings Program. Participation with an ACO automatically replaces MIPS. Medicare Shared Savings programs are a type of Accountable Care Organization (ACO). In general terms, an ACO focuses on identifying patients Medicare has attributed to the participating providers. Then, outreach to patients aimed at increasing the number of Annual Wellness Visits/ Care provided to those patients. Finally, participants must properly treat document patient disease burden, then prove it. Many hospitals and established RHCs are participating in ACOs. Most smaller RHCs and many other hospital based RHCs are not participating. They need to be. Many of those participating receive great financial benefit from participation. Many other potential participants are frightened that joining an ACO will increase workload or not be worth the effort. These can be the case. If so, my suggestion is that these participants are in the WRONG ACO. There are many excellent organizations out there right now with RHC experience. There are many other ACOs that have no idea what to do with RHCs. Quality payments are meant to replace the fee-for-service program entirely by 2026. Many Commercial payers pay a variety of quality incentives based on similar clinical activities, such as providing A1Cs to X% of qualifying patients. PCMH is ONE avenue that Medicaid plans are putting the proverbial toe-in the water with varying degrees of financial benefit. From an RHC Compliance perspective, the important item of note is that a properly documented Quality Assurance/Performance Improvement Program can replace the RHC Program Biennial Evaluation. From State Operations Manual Appendix G "If a RHC has developed a QAPI program and that program meets/exceeds the regulatory requirements for a Program Evaluation, the QAPI program would be acceptable." I hope that helps. I would be happy to discuss any of these initiatives (or our own) off-line. 5/11/2022 @ 2:11:00 PM
Post 3 of 4
Contributor: Misty Duncan, Caldwell Family Clinic
Thank you for your response. Because of quality coming down the pike for RHC's we are definitely on board with getting a plan going now. We are currently in the works of over-hauling our current QAPI Plan for the hospital. Can this encompass the RHC or do they need their own? FYI: When we open the RHC in July it will not be under the same roof as the hospital. We will be opening the doors to a brand new facility in early 2023 when the RHC will then be under the same roof as the hospital. I wasn't sure if this information would be beneficial in answering questions. 5/11/2022 @ 2:22:00 PM
Post 4 of 4
Contributor: Charles James, North American Healthcare Management Services
Could you please email me privately? cjamesjr@northamericanhms.com
Thank you - Charles |
