Tag: Risk Adjustment

3 major PCP risks in VBC—and how to reduce them

By Lindsay Dosen, senior vice president of legal and compliance, Vatica Health

As more physician groups move into value-based care (VBC), many are encountering risk adjustment compliance issues they aren’t prepared for. Some of these issues can have serious legal and financial consequences if left unchecked. Preparing for these issues will enable physician practices to successfully transition to, and thrive in, a VBC environment by reducing compliance risk, improving patient outcomes and boosting financial performance. This article focuses on three common VBC compliance risks that PCPs should be aware of—along with recommendations on how best to mitigate them.

Risk 1: Unsubstantiated HCC codes

With the traditional fee-for-service payment models that PCPs have historically operated under, health plans—not PCPs—have primarily focused on accurately capturing Hierarchical Condition Category (HCC) codes for purposes of risk adjustment. However, under VBC arrangements (depending on the type of gain-sharing relationship), PCPs must focus on accurately capturing and documenting HCC codes. Underreporting or missing codes could translate to lost revenue for the PCP. Overreporting or submitting HCC codes that are inaccurate or unsubstantiated could subject the PCP to legal liability and regulatory penalties.

While this has been a major issue for health plans in recent years, this is also becoming a significant compliance risk for PCPs, as regulatory agencies have increased scrutiny of the risk adjustment programs and activities of both health plans and healthcare providers. These regulatory actions often assert violations of the False Claims Act (FCA) based on the government’s position that the risk adjustment payments were artificially inflated due to inaccurate or unsubstantiated diagnoses codes. Violations of the FCA can result in multi-million-dollar fines, not to mention lasting damage to a physician group’s public image and reputation, even when the violations were committed in error and without intentional wrongdoing by the PCP.

Fortunately, there are ways PCPs can protect against this compliance risk. First, PCPs should avoid payment structures that base payment on either a higher number of codes or higher-value codes. These types of payment arrangements are construed by the Department of Justice (DOJ) as problematic because they incentivize over coding and upcoding. Second, PCPs should provide training that reinforces the importance of compliant and accurate coding and that educates their staff about the potential legal, regulatory and financial risks associated with submitting inaccurate or unsubstantiated codes. Last, PCPs should invest in compliance programs that review coding and documentation to ensure accuracy.

Risk 2: Improper medical record review and sign-off

Another common VBC compliance issue that PCPs face is medical record compliance. You would think that the Centers for Medicare and Medicaid Services (CMS) recommended medical record review and sign-off process would be simple and straightforward. And it is—but only if the right person is doing it.

CMS outlines specific requirements as it relates to medical record documentation and risk adjustment diagnosis codes. Submissions with documentation issues could impact the validity of the medical record in a Risk Adjustment Data Validation (RADV) audit, leading to a potential discrepancy for the audited CMS-HCC findings. For a diagnosis to be risk adjustment-eligible, it must result from a face-to-face encounter with an approved provider type. The medical record must have, among other things, a valid signature and credentials for the approved provider. For PCPs, that means not just anyone in the practice can sign off on a medical record. A CMS risk adjustment-approved physician must be present during the face-to-face encounter. The record must also be signed by the CMS risk adjustment-approved provider. Learn more here.

This is an issue that can be easily remedied with proper education and training. PCPs should take steps to make sure that their staff clearly understands the importance of following the CMS guidance related to medical record documentation for risk adjustment. PCPs and their teams should read and be familiar with these compliance guidelines and should develop and implement policies and procedures to ensure compliance.

Risk 3: Vendor non-compliance

A third VBC issue is the misconception that a PCP’s responsibility for compliance is limited to only activities within the practice. If a PCP is working with an outside vendor that is non-compliant, the PCP may also be held liable for the vendor’s compliance violations.

The best way to mitigate this risk is to vet prospective vendors thoroughly in advance to ensure they have a clean compliance record and a strong compliance program in place. When selecting a risk adjustment vendor, PCPs should conduct due diligence to include, without limitation, reviewing information about the vendor’s compliance and security programs, any applicable coding policies and procedures, mechanisms for reporting suspected fraud, waste and abuse, exclusion screening, and any prior enforcement or legal actions taken against the vendor. In addition, a thorough review should be completed of the vendor’s operations related to the services being provided, including coding. Finally, PCPs should be thoughtful when structuring any fee arrangements with the vendor so as not to encourage over coding or upcoding. Payments under the arrangement should be based on the scope and quality of the services performed, without fluctuation (including bonuses or penalties) tied to the value or volume of the diagnosis codes captured.  

Final recommendation: appoint a compliance lead

These three issues are examples of the compliance risks that PCPs operating in VBC are faced with every day. However, they are also examples of how an effective compliance program can help PCPs successfully navigate these issues and substantially reduce risk in VBC arrangements. An important way to ensure the PCP has an effective compliance program is to appoint a compliance lead for the practice. The compliance lead should stay up to date on compliance requirements and guidelines, develop policies and procedures to ensure compliance, provide training, promote awareness, and monitor and enforce compliance within the organization. An effective compliance program, led by a person with knowledge and expertise related to the compliance risks and regulatory requirements that are applicable to VBC, can greatly mitigate the compliance and financial risks to the practice. With compliance adequately addressed, PCPs can focus on delivering efficient, high-quality care to patients, which leads to successful financial performance in a VBC arrangement.

In-home risk assessments are under fire

A message from our chief strategy officer and co-founder, Steve Zuckerman

On October 17, 2022, the United States filed a lawsuit against Cigna Corporation and its subsidiary Medicare Advantage Organizations, intervening on a lawsuit filed by a whistleblower several years earlier. The lawsuit seeks damages under the False Claims Act for Cigna’s alleged submission of invalid diagnoses codes for purposes of inflating risk adjustment revenue for its Medicare Advantage plan members. Health plans like Cigna are required to report patients’ diagnoses which are used to calculate “risk adjustment” payments to the plan based on demographic information and the health status of patients. Over the last few years, lawsuits against Medicare Advantage Organizations (MAO) have increased significantly, centering around what the government alleges are improper practices focusing on boosting risk scores and associated payments.

The government’s lawsuit against Cigna focuses on diagnosis codes submitted on forms completed by several home assessment vendors. The lawsuit alleges that these vendors did not properly validate the existence of the reported conditions. Further, the diagnoses were not supported by the minimal information contained in the vendors’ forms. The government identified a major flaw in the home assessment vendor process in that it failed to coordinate with the patient’s primary care physician (PCP) or account for the patient’s full medical history. Instead, the home assessment vendors relied on limited data provided by Cigna and self-reported patient information which created an incomplete picture. As a result, according to the government, Cigna was overpaid tens of millions of dollars in risk adjustment payments from the Centers for Medicare and Medicaid Services (CMS).

The government’s action against Cigna is the latest in a string of lawsuits and recent Office of Inspector General (OIG) reports claiming that MAOs have received billions in risk adjustment overpayments. A common theme in these cases and recent OIG reports is that home assessment vendors work around PCPs, instead of with them. Sending a clinician to a patient’s home, without any relationship with the patient or the PCP, has been increasingly scrutinized as it’s viewed as a method to simply improve risk score without improving patient care or outcomes. In fact, going back as early as 2014, in its 2015 Advance Notice Proposal, CMS suggested to “exclude for payment purposes diagnoses identified during at home visits that are not confirmed by a subsequent clinical encounter.”

The mounting scrutiny of home assessments has continued. In September 2021, the OIG issued a report regarding billions in alleged overpayments to MA plans. It specifically criticized home assessments, making the point that the failure to work alongside PCPs raises concerns about the quality-of-care coordination for these patients and the validity of diagnoses. These concerns are being exacerbated by fundamental flaws in the home assessment process, including the failure to consider pertinent patient information contained in PCPs’ electronic medical records and the lack of follow-up with the PCPs to ensure chronic conditions and care gaps identified during the assessment are being addressed.

Despite the flaws with home assessments that are not connected to PCPs, MAOs ultimately bear the responsibility. In our experience, MAOs do not intentionally misrepresent their population risk. They are simply relying on vendors employing legacy programs that have not evolved to meet the current regulatory environment. The shift to value-based care will put even more pressure on payers and providers to use compliance-centric solutions that are focused on improving the accuracy and completeness of diagnoses codes and documentation.

As the pioneer in physician-centric risk adjustment processes, Vatica has emphasized for over a decade the importance of including PCPs in the risk adjustment process. Instead of using third parties with no pre-existing relationship with the patient and no access to the underlying medical record, Vatica’s solution empowers PCPs to improve outcomes while easily completing HCC coding with the greatest level of accuracy and completeness. By pairing technology and dedicated clinical support at the point of care, Vatica enables PCPs to drive the most compliant and accurate risk adjustment results, close care gaps, and improve performance.

Physicians want resources to address SDOH: Here’s where to find them

Physicians are well aware of the impact created by social determinants of health (SDOH) and want to address these needs, as indicated in a recent survey. But many believe they can’t help their patients, due to:

  • Limited time to discuss SDOH during patient visits
  • Insufficient staff to direct patients to the appropriate resources
  • Existing payer requirements that take time
  • Lack of reimbursement for screening for SDOH
  • Unavailable, inadequate or difficult-to-access resources

The good news is that as the focus on SDOH grows, more resources than ever are available to help physicians, from community resources to health plan-sponsored programs to time-saving solutions.

Primary care physicians (PCPs) can take advantage of multiple resources from their health plans. In particular, Medicare Advantage plans are rapidly transitioning to value-based care, at the direction of CMS. As CMS moves to pay for quality rather quantity, the depth and breadth of payer-sponsored programs grows.

SDOH programs show measurable improvements

Anthem, for example, offers the Members Connect program to its Medicare Advantage members. The program addresses social isolation and loneliness to improve members’ overall health. It connects members to a community health worker who helps them find specific community resources they need. Volunteers act as social care partners or “phone pals” who call members weekly to check on them and provide a social connection.

The program gets accolades from members: 74 percent said they increased engagement in their health. Anthem’s claims data shows that participants reduced hospital admissions by 8 percent and ER visits by 43 percent.

Superior HealthPlan, based in Texas, offers a multitude of programs: housing assistance, an in-house network of community health workers to guide members, and a unique program that helps provide funding for hygiene closets. The plan partners with community organizations across the state to offer these hygiene closets with products needed to maintain a healthy, active life. At nearly all of the hygiene closets, specific dates are designated as “Superior Days,” where plan representatives join with other community partners to host events and provide direct resources for those who need them.

To learn about programs available to their patients, physicians and office managers can contact their health plans’ provider representatives or quality teams.

Time-saving solutions

Lack of time and insufficient staff to address SDOH were cited by survey respondents as well. Here, too, PCPs can look to their health plans. With the transition to value-based care, plans offer resources such as care managers who support patients with SDOH-related needs. PCPs should be aware of which health plans offer these services and refer patients for additional support.

Note that ICD-10-CM Z codes are available to report patients’ SDOH but are generally underutilized by PCPs. When PCPs use these codes to report SDOH, that information is passed to health plans through claims. Plans can use that information to enroll patients into their various SDOH programs, alleviating the burden for PCPs.

Likewise, as plans ask PCPs to document and code Medicare Advantage patients’ health status for accurate risk adjustment, they may offer additional resources to assist patients with identified needs. A number of national and regional plans partner with outside resources, such as Vatica Health. Vatica offers a PCP-centric risk adjustment and quality of care solution, which combines technology and clinical consultants at no cost to the practice. These specially trained clinicians serve as an extension of the practice. They review and curate all relevant health plan and EMR data. This information is used to create a pre-visit notification to help the PCP efficiently perform the visit, document patients’ health status and assist with care gap closure.

Vatica’s time-saving solution enables PCPs to increase use of preventive services and improve patient satisfaction with Vatica’s combination of technology and clinical support teams. When patients’ conditions are accurately reported to health plans, that ensures adequate financial resources are available through CMS. This can also result in the patient receiving additional services from the health plan to address chronic care needs, complex conditions and SDOH.

More resources benefit PCPs and patients

SDOH continues to get more visibility, and rightfully so. This is good news for PCPs. More resources from health plans, government-funded programs and community organizations can help PCPs address SDOH. Outcomes include healthier, more satisfied patients and easy-to-access resources that can help to address lack of clinical staffing and staff burnout.

Bridging the quality gap through race and ethnicity reporting

As efforts continue to improve quality and reduce healthcare costs in the U.S., evidence shows that racial and ethnic health disparities have a significant negative impact. According to a report from the Commonwealth Fund, “Black and American Indian/Alaska Native (AIAN) people live fewer years, on average, than white people.” They are more likely to die from treatable conditions, to die during or after pregnancy and suffer serious pregnancy-related complications, and to lose children in infancy. Black and AIAN populations are also at higher risk for many chronic health conditions, ranging from diabetes to hypertension.  

The harsh reality of these health disparities was revealed by the COVID-19 pandemic and its disproportionate impact on people of color. Black, Hispanic and Asian populations in the U.S. have significantly higher infection rates, hospitalization, and death compared to white populations.  

The effect on the cost of healthcare is substantial. A recent Texas study showed that over the last six years, racial and ethnic health disparities in the state have resulted in $2.7 billion in excess medical spending and $5 billion in lost productivity.  

An important step to reducing disparities is efficiently collecting race and ethnicity data. This has proven to be a difficult task due to: 

  • The lack of standardized race and ethnicity categories 
  • Incomplete forms used to collect the data 
  • Electronic health records built without the ability to collect the information 
  • Discomfort of healthcare staff asking for information 
  • Few detailed descriptions for patients to accurately self-identify 
  • Patients may be reluctant to share this kind of information  

Additionally, social determinants of health (SDOH) have proven to be a significant source of disparity among racial and ethnic minorities. Using quality tools as a method for collecting data and advancing health equity has great potential to address the deeply rooted issues of SDOH. While some improvement has occurred, more work is needed.  

National Committee for Quality Assurance Strategies  

The National Committee for Quality Assurance (NCQA) compiles the Healthcare Effectiveness Data and Information Set (HEDIS). This provides quality results annually for more than 203 million people and 60 percent of the U.S. population. 

NCQA introduced a racial/diversity measure in 2015. But health plans struggled to obtain the needed data through member self-reporting, disease registries and other traditional means. NCQA’s 2019 records showed that approximately 76 percent of racial data and 94 percent of ethnicity data were incomplete for the commercial product line. Medicare plans demonstrated higher collection rates: 26 percent of racial data and 60 percent of ethnicity data is incomplete.  

The lack of completeness raised concerns about relying on traditional sources to accurately measure disparities in care. Without reliable data, identifying those with unmet needs is difficult. 

Improving Data Collection 

To increase collection of data from health plans, NCQA began requiring stratifications by race and ethnicity in 2021.  

NCQA started with five measures across key known disparities: colorectal cancer screening, controlling blood pressure, hemoglobin A1c control for patients with diabetes, prenatal and postpartum care, and child and adolescent well care visits.  

Race and ethnicity data on these measures help plans better understand member needs and provide services to address those needs. Plans can measure and track performance on disparities and implement data-driven approaches to close care gaps and improve outcomes in vulnerable communities, especially related to SDOH.  

Some plans are already working to close equity gaps. Centene Corporation was recently awarded the Innovation Award for Health Equity by NCQA. They implemented a data-driven approach focused on community disparities within markets. Improvements were seen in colorectal cancer screening rates for American Indian/Alaska Native members, increased rates of immunizations for Latino children and better maternal outcomes among Black mothers. 

Help is available to health plans seeking ways to reduce disparities of care among their membership. Vatica Health, for example, provides technology and dedicated clinicians to enable providers to efficiently capture more accurate and complete diagnostic coding and documentation for risk adjustment and improving quality of care. As part of this process, Vatica can collect race and ethnicity information using CDC specifications for the measures designated by NCQA. This helps Vatica clients meet NCQA requirements and collect the data needed to identify and reduce disparity gaps in care. 

Conclusion 

High quality, affordable healthcare for all isn’t possible without addressing disparities in our current system. Collecting race and ethnicity data is the first step toward developing effective solutions to address this complex challenge. While this is not a simple task, actions by NCQA and other stakeholders show potential. Collecting and using race and ethnicity data to identify disparities and factors that drive them is critical to achieving better healthcare for everyone. 

About Vatica Health  

Vatica Health deploys clinical nurses at the point of care, armed with powerful technology. Vatica’s solution accelerates the transformation to value-based care by helping providers, health plans, and patients work together to achieve better outcomes. Visit https://vaticahealth.com/ to learn more. 

Closing the gap on missed medical care

The COVID-19 pandemic has had a ripple effect, impacting not only those people who have contracted the virus, but the tens of millions of others who have managed to avoid it.  Many have foregone recommended preventive and well care since March 2020. Studies confirm this trend, including a recent report from Avalere on routine vaccinations missed.  From January 2020 – July 2021, monthly vaccine claims (for routine vaccinations excluding COVID) decreased an average of 32 percent for adults and 36 percent for adolescents, compared to the same months in 2019.  A poll conducted in January 2022 found that 30 percent of adults aged 50 and older missed a scheduled appointment for a medical test, procedure or operation.

Israel Cordero, M.D., medical director of primary care for Middlesex Health in Connecticut, attested to this troubling trend during a recent interview with WFSB TV. “We have seen many patients delay routine and preventive care, as well as ongoing chronic disease management,” said Dr. Cordero, a long-time Vatica client. “We are seeing some of those aftereffects of delaying care during the pandemic.”

While all age groups are affected, seniors are among those most at risk from delayed or avoided care. Whether it’s a colorectal cancer screening, a flu vaccine or an eye exam for a person with diabetes, missing a recommended test or procedure could have significant long-term effects. To help keep seniors healthy and reduce the enormous amount of money spent on treating preventable illnesses, Medicare covers a number of preventive services. For example, the Annual Wellness Visit (AWV), which is informed by a comprehensive health risk assessment, focuses on early detection, positive lifestyle choices, and utilization of preventive services.

Only one in four beneficiaries receives an AWV, despite this service being 100 percent free. Unfortunately, many other preventive services are also underutilized. This problem has been exacerbated by COVID, demonstrated by the studies cited here. As we start to return to our pre-COVID lives, we must ensure that the most vulnerable among us–including seniors–get the routine and preventive care they need. This requires communication, creativity and collaboration.

Partnerships between payers and providers are one way to tackle this problem. Payers and providers are using a variety of outreach and incentive programs to get patients in the door, from multi-model outbound messaging and mailers to gift cards and greeting cards.  Another effective approach is leveraging health plan initiatives that provide physicians with clinical and administrative support as well easy-to-use technology.  Finally, marrying preventive services with payer-sponsored programs designed to capture and close risk and quality gaps benefits the entire healthcare ecosystem: plans, providers, and patients.

Given their vulnerabilities and higher prevalence of chronic conditions, older Americans were prioritized when the COVID vaccine was initially rolled out. Likewise, a similar focus is needed to reengage seniors in preventive and routine care. As the nation emerges from the acute phase of COVID, it’s critical to refocus on mitigating the development and exacerbation of chronic and preventable diseases. There are effective steps providers and payers can take together to ensure that seniors—some of our most vulnerable population—catch-up on preventive care and reduce their likelihood of developing serious illnesses.

How Vatica Health can help

Vatica Health is a pioneer in physician-centric technology that supports improvements in clinical outcomes, efficiency, and financial performance. The Vatica solution deploys clinical nurses at the point of care, armed with powerful technology. The nurses use Vatica’s solution to identify, document, and report gaps in care, helping physicians increase the utilization of preventive services such as colonoscopies, mammograms and diabetes screenings. Vatica Health is accelerating the transformation to value-based care by helping providers, health plans, and patients work together to achieve better outcomes. To learn more, visit https://vaticahealth.com/.

Why a “technology-only” approach will not drive value-based care performance

Over the last few years, we’ve witnessed significant advancements in medical technology including the proliferation of telehealth, remote patient monitoring, and artificial intelligence. These offer the potential to dramatically improve insights and shape healthcare delivery. While technology development is essential, it must properly interface with clinical services to drive the maximum benefit—for providers and for patients.

Recent technology developments that provide coding and care gap notifications in electronic medical records (EMRs) offer increased potential for value-based care. These solutions address an important problem—but are incomplete as they don’t ensure conditions are coded correctly. Patients must have their conditions accurately coded to ensure health plans and providers receive appropriate compensation. Accurate coding can lead to cost-effective clinical services with the goal of improving patient outcomes.

In reality, these “technology-only” solutions may compound the problem. Providers are inundated with competing priorities and lack resources to add additional uncompensated services—a situation exacerbated by COVID-19. Current solutions cause alert fatigue and have little impact on care. They also suggest insights based on unsubstantiated data and therefore create compliance risk.

Value-based care requires a comprehensive solution

The transition to value-based care is inevitable. By 2025, it is anticipated that all Medicare Advantage and traditional Medicare plans will adopt two-sided risk alternative payment models. Fifty percent of Medicaid and commercial plans will adopt these models. This move requires providers to accurately code services for appropriate risk-adjusted reimbursement, connecting financial performance and quality of care. Success in value-based care depends on accurately assessing patient needs so that provider paymentsbased on the reported health conditions for that patient—will be sufficient to deliver appropriate care.

Technology cannot replace providers and clinical judgement. To drive optimal performance in value-based care, consider leveraging powerful, clinically validated technology coupled with clinical experts. By using technology combined with clinical experts, care gaps and relevant diagnostic codes can be identified. Such comprehensive services lead to more accurate coding and better performance in value-based care for both providers and health plans.

Evaluating possible solutions

There are a growing number of solutions that promise to drive value-based care performance, but very few that provide a comprehensive approach to improving risk adjustment coding and quality of care. Here are three questions to consider when evaluating various solutions:

  1. Is the risk adjustment and quality solution provider-centric? Providers need intuitive, easy-to-learn, and simple-to-use technology that seamlessly fits into their workflow, uses their EMR and intelligently mines data to optimize efficiency.
  2. Does the solution provide comprehensive in-office support? In addition to data and technology, providers need access to onsite clinicians who understand the technology and serve as an extension of their team at no cost to the practice. These clinicians can perform various tasks to reduce the burden on providers and their staff.
  3. Does the solution ensure coding accuracy and compliance? While there are “technology-only” solutions that surface codes in providers’ EMRs, they are often derived from unreliable data sources and not validated by certified clinical coders. This creates audit and compliance risk.  

How Vatica Health can help

Vatica Health is a pioneer in provider-centric technology and support solutions that directly improve clinical outcomes, efficiency, and financial performance. Vatica Health deploys clinical nurses at the point of care, armed with powerful technology. Vatica Health is accelerating the transformation to value-based care by helping providers, health plans, and patients work together to achieve better outcomes. Visit https://vaticahealth.com/ to learn more.

6 ways to ease physicians’ burden from coding, documentation and risk adjustment

By Shannon Lukez, Senior Vice President, Clinical Solutions, Vatica Health | This article first appeared on HFMA

The COVID-19 pandemic has heightened the need for the nation’s hospitals and health systems to gain physician cooperation in documenting and coding patient risk.

The reason is that many patients, and particularly the elderly, stopped visiting their care providers during the pandemic, often resulting in an undocumented deterioration of their health status.

Consider, for example, a 76-year-old patient with Type 2 diabetes and stage 3 chronic kidney disease, whose conditions were fully documented in the patient’s medical record and coded to the highest degree of specificity on all claims submitted in 2019. Let’s assume the patient not only refrained from visiting a physician’s office in 2020 due to COVID-19, but also was not comfortable enough with technology to receive telehealth services. Facing isolation, with severely reduced family and community support, the patient experienced growing depression and anxiety — and uncontrolled diabetes. The patient also began experiencing symptoms of high blood pressure and severely reduced access to healthy food as result of the increased financial strain brought on by the pandemic. Because the patient did not see a physician in 2020, none of this information was documented in their medical record or coded.

Undocumented deterioration in a patient’s health status impacts a healthcare organization’s revenue considerably. The absence of preventive care significantly increases the possibility for patient illness and premature death, while also depriving healthcare providers the opportunity to positively impact the patient’s life. Failure to recapture previously documented conditions, as well as new ones, leads to poor patient outcomes and lower levels of reimbursement.

The added challenge of physician burnout

Unfortunately, this heightened need for physician engagement comes at a time when many physicians are struggling with burnout exacerbated by the challenging work conditions created by the pandemic amid the ever-present risk of contracting the virus.

According to a 2021 national survey conducted by Medscape, 42% of physicians reported feeling burned out. Interestingly, 79% said the burnout started before the pandemic, with a majority (58%) citing “too many bureaucratic tasks” as the number-one cause.

These circumstances may cause many healthcare finance leaders to feel hesitant to add to physicians’ plates any kind of operational burden, particularly tasks related to enhanced coding, documentation and risk adjustment. It’s not easy to ask physicians — especially those who are salaried — to spend more time documenting conditions and reporting data for value-based payment programs while also increasing daily patient volume. Yet the financial future of a healthcare organization depends on its ability to delicately balance and accurately perform both tasks. As the industry shifts from volume-based to value-based payment models, healthcare organizations and physicians must cooperate to achieve long-term financial viability.

Consequences of physician burnout

Physician burnout is problematic because it leads to unsatisfied physicians and high turnover, which significantly affects patients. For example, burnout is associated with higher rates of major medical errors. It can also negatively affect patients’ access to and continuity of care as well as their care experience. All of these issues can harm a healthcare organization’s reputation and, in turn, its bottom line. For these reasons, physician burnout is an important ongoing concern for healthcare finance leaders.

How to foster physician engagement in capturing risk

Addressing these challenges requires a strategic approach to making coding and risk adjustment practices more physician friendly. Following are six strategies that CFOs should consider as they strive to support physicians in more accurately and documenting the risk profile of their patients.

1 Provide physicians with training on standard coding and documenting practices. One of the challenges associated with creating a risk-adjustment strategy is getting all physicians on the same page in terms of process and workflows. All too often, each practice — particularly one that’s newly acquired — will either have its own way of capturing risk or have no formal process at all. Consistency is important because it reduces the cost to operationalize the program, permits standardization of training and other key elements, and facilitates the establishment of expectations. Both the healthcare organization and the physicians will know exactly what is expected.

2 Align physician compensation with value-based care initiatives. Compensating physicians for their efforts is of paramount importance to obtaining physician buy-in and ongoing participation. Yet some healthcare executives contend that coding and documentation are simply part of the physicians’ role, so extra compensation is unnecessary.

This perspective does not consider newer models of care that focus on population health and outcomes, where revenue is largely determined by value, affordability and outcomes. And outcomes and value will be determined through analyses of claims and encounter data, which must be supported by accurate and thorough medical records documentation.

Aligning physician performance and compensation with overall organizational goals ensures shared accountability. Just as important, by thoughtfully designing compensation programs for both clinical and support staff, a health system can proactively counter the problems of physician burnout, declining retention and a growing shortage of talented physicians.

Paying physicians a base salary plus a gain-share bonus based on value-based care performance, for example, gives them an incentive to go the extra mile documenting for risk adjustment. It also sends the message to physicians that executive leaders are aware of the extra time and effort improved coding and documentation requires.

3 Optimize the electronic health record (EHR). EHRs, on their own, do not sufficiently support coding and documentation to optimize value-based care performance. However, solutions are available that optimize EHR performance to help identify care gaps and facilitate accurate coding.

Physicians need help with this process as risk adjustment coding is complex and cumbersome. In the CMS risk adjustment model alone, roughly 10,000 diagnoses are assembled into about 1,300 diagnostic groups that are then aggreged into condition categories (CCs). CCs are related clinically and with respect to cost. Hierarchies are imposed among related CCs, hence the term hierarchical condition categories or HCCs. HCCs paint a complete picture of each beneficiary’s acuity to effectively manage costs for high-risk members while ensuring they receive high-quality care and the organization receives appropriate and accurate payment.

Efficiently distilling this information for physicians reduces the burden on them and improves performance in value-based care, quality and risk adjustment initiatives. Healthcare organizations should work with their EHR vendors on ways to improve EHR performance to optimize the provider experience and patient outcomes.

4 Advocate for programs that remove operational burden associated with risk adjustment. For example, health systems could consider working with a health plan on a plan-sponsored program for primary care physicians (PCPs) that is easy to use and provides support to physicians. Such programs can combine powerful technology with clinical and administrative resources dedicated to medical practices.

These programs can help the participating health systems realize incremental revenue, improved outcomes, increased numbers of preventive health encounters (e.g., annual wellness visits) and improved overall performance in value-based care arrangements. The senior financial executive can initiate this strategy by reaching out to the organization’s managed care partners to see whether they provide this type of program and, if so, what type of performance reporting is included. Ideally, the health plan would provide real-time data so the physicians could understand care gaps for each patient and how well they are addressing those gaps.

If health plans don’t offer this option, the health system could consider developing a program internally, depend on its goals, available resources and competing priorities. In deciding whether to pursue such an approach without outside help, the organization would need to perform an in-depth assessment of the potential benefits weighed against the costs associated with the required  upfront investment and ongoing resources for program management, analytics and reporting.

Armed with the results of such an analysis, the senior finance executive can champion the effort by communicating to the health system’s C-suite the potential financial impact of a PCP-focused program to the health system, and how it could help the organization not only survive, but thrive, in the years ahead. In this way, the senior finance leader also can help demonstrate to the physicians that there is uniform buy-in at the leadership level for a program designed to help them manage the risk-adjustment process.

5 Provide support to help physicians capture and address social determinants of health. Medical care accounts for only 10% to 20% of the modifiable contributors to healthy outcomes. The other 80% to 90% are referred to as social determinants of health (SDoH) — the conditions in the environments where people grow, live, work and age that affect a wide range of health, functioning, and quality-of-life outcomes and risks. Examples of SDoH include the lack of essential resources necessary to maintaining health, including housing and economic stability, literacy skills and access to nutritious food and physical activity opportunities. Because SDoH often can affect risk adjustment and, consequently, revenue, it is important for physicians to capture this information.

Healthcare organizations should assist physicians in this effort by providing a framework and support for capturing SDoH. Successful SDoH-focused programs include training clinical staff, providing access to local resources, developing workflows and promoting standard practices that help simplify the risk-adjustment process, including allocating time during patient encounters for these critical conversations.

6 Be transparent about the financial impact of physician performance in value-based care. Given the significant impact physicians have on a health system’s performance under value-based payment arrangements, executive leaders should share financial performance data with physicians (and potentially other staff as well). For some healthcare organizations, incremental revenue earned through participation in such programs can help them end the year in a financially positive position. Transparently communicating to physicians the financial impact of performance in value-based-payment contracts, including positive results attributed to quality and risk adjustment programs, builds awareness, trust and engagement.

A necessary charge

Value-based care is a strategic imperative for U.S. hospitals health systems, and it requires, first and foremost, physician engagement. Thus, although finance executives may be wary of asking physicians to take on the additional administrative tasks such contracts require, they must do so because success will depend on physicians’ absolute commitment to accurately documenting care and adjusting for risk. Although physicians may initially object to the additional work, they will likely become more receptive if they can be shown how better coding and documentation directly improves the organization’s financial performance — and how that translates into reduced pressures placed on physicians.

It is here where the finance leader can make a difference. By examining and implementing  creative and effective solutions aimed at easing the administrative burden on physicians, the senior finance executive can help them better meet the challenge of performing documentation and coding. The result is a win-win in the form of improved value-based payments and alleviated physician burnout.

Why providers face an increased challenge in understanding patient risk

During the first six months of 2020, an estimated four out of 10 adults in the United States avoided medical care because of concerns related to COVD-19. With these delays in care came missed opportunities for hospitals and health systems to capture risk and predict costs accurately.

With the rollout of the COVID-19 vaccine, some patients are slowly resuming preventive services, which is good news. Yet this trend means providers may be overwhelmed with patients whose chronic conditions have worsened or who are newly diagnosed with a chronic condition. It is of paramount importance that the provider organizations capture these diagnoses to ensure their payment is appropriately adjusted for risk.

For patients who are still not returning to their provider, it also will be important for providers to address care gaps. Telehealth may be a great way to engage these patients so that physicians can capture risk without necessitating the need for an in-person visit.

In addition, in 2020, about 8.3 million people signed up for Affordable Care Act plans that rely on risk-adjusted payment models. This is a new population of patients for whom risk adjustment suddenly matters. Many of these patients don’t have a baseline risk adjustment factor score, making it critical to capture any and all diagnoses that affect risk-adjusted payments as soon as possible.

How an end-to-end risk adjustment strategy helps direct contracting entities grow with confidence

By Brian Flower, Vice President of Client Solutions

Value-based care (VBC) is truly a team sport—especially when it comes to direct contracting entities (DCE) that include healthcare providers and suppliers sharing the common goal of improving healthcare delivery. DCEs operate under the Global and Professional Direct Contracting Model (GPDC), one of the Centers for Medicare & Medicaid’s (CMS) latest innovations to right-size costs and improve outcomes for patients with traditional fee-for-service Medicare coverage.

According to CMS, the goal of the GPDC is to transform risk-sharing arrangements in Medicare fee-for-service, empower beneficiaries to personally engage in their own care delivery, and reduce provider burden to meet healthcare needs effectively. There are 53 DCEs participating in the first Performance Year (PY2021) running from April 1, 2021 through December 31, 2021.

Here’s how it works. DCEs contract directly with Medicare under a risk-adjusted payment model similar to that of other alternative payment models. This means they accept financial accountability for the overall quality and cost of medical care furnished to Medicare fee-for-service beneficiaries aligned to them. While CMS has provided various participation options, all options are aligned the same. They measure DCE performance against annual medical cost benchmarks while ensuring quality metrics are met and reported.

DCEs represent a big win for CMS in the drive to expand value-based care and the vertical alignment of incentives in healthcare. However, for DCEs to be successful, these entities must educate and promote the shift to from FFS to VBC at the provider level, employing strategies to manage patient populations for whom preventive care and risk adjustment accuracy weren’t necessarily a priority in the past. While CMS has structured the financial equation to mitigate increases in RAF scores overall, targeted patient engagement, risk adjustment, and quality capture interventions are critical to ensuring predictable and reasonable benchmarks for each DCE. DCEs need each PCP’s help and buy-in to accomplish this. PCPs who don’t accurately capture hierarchical condition categories (HCC) can drag down a DCE’s benchmarks, negatively impact revenue, and stall overall growth. Again, VBC is a team sport.

The challenge: Achieving controlled growth without compromising data integrity

DCEs want—and need—to grow quickly. However, growth without a strategic plan can easily backfire. They can’t afford to onboard PCPs who have little or no experience in value-based care if they don’t have an onboarding process in place to drive documentation and coding compliance. This process shouldn’t put the onus on PCPs to take on more work. There simply aren’t enough hours in the day, and many PCPs are already facing burnout. Adding another task to their to-do list would cause unnecessary friction.

In GPDC, CMS has set up a financial structure to recognize the importance of quality care and allocating resources based on the needs of specific populations. For the majority, RAF growth will be capped at +/- 3% to ensure that risk adjustment accuracy is a priority instead of the priority. However, those with VBC experience know that the potential 6% window in med-expense benchmark is no small thing—potentially $3M+ on a population of 5,000 beneficiaries in Atlanta, Georgia.

DCEs need a risk adjustment strategy that promotes patient engagement, improves quality reporting, and prioritizes accuracy and compliance.

The solution: An end-to-end prospective approach to risk adjustment

Leveraging an end-to-end, prospective risk adjustment partner helps DCEs ensure risk and quality accuracy without having to worry about each PCP’s experience with HCC capture and risk adjustment. Even practices that are new to the world of value-based care can quickly be brought up to speed with custom workflows and education as well as clinical and administrative support. The goal is to yield maximum accuracy with minimum physician effort. Mitigating burnout is key. And promoting early detection and effective management of chronic conditions are cornerstones of effective prospective risk adjustment.

Following are five priorities for DCEs as they continue to expand:

  1. Understand current state of documentation and coding accuracy, patient engagement, and quality performance on provider panels.
  2. Understand options for ensuring risk adjustment accuracy and quality performance to drive better patient outcomes.
  3. Empower providers with the right tools to improve the accuracy of population-specific medical expense benchmarks.
  4. Identify and measure key indicators at the PCP level to align organization value-based outcomes with provider performance and incentives.
  5. Maintain compliance and focus on the quadruple aim.

Each of these priorities is equally as important, and collectively, they lay the foundation for a DCE’s long-term success.

How Vatica Health can help

Vatica takes the pressure off DCEs by supporting the VBC onboarding process for all PCPs regardless of their experience with risk adjustment and quality capture. It does this by pairing expert clinical teams, including licensed registered nurses, with cutting-edge technology to work with physicians at the point of care. By synthesizing EMR and health plan data to create the most complete view of each patient and applying a rigorous clinical documentation improvement process, Vatica improves data accuracy and reduces compliance risk. It also provides comprehensive PCP training as well as 100% clinical coding validation. When coupled with PCP engagement, prospective risk adjustment enables comprehensive insight into the disease burden of a member population. In addition, prospective programs actually drive higher return on investment due more accurate and complete coding and documentation. It’s about engaging patients when they’re directly in front of their provider. This is where real change can occur. This is how to move the needle on value-based care. To learn more, visit https://vaticahealth.com/.

Why Medicaid risk adjustment can’t be ignored during COVID-19 and beyond

Given the number of people who experienced income and job loss during the COVID-19 pandemic, it’s not surprising that Medicaid enrollment increased by 7.7 million or nearly 11% between February and November 2020, according to recent data from the Kaiser Family Foundation. However, what may come as a surprise—at least for some Medicaid plans—is the effect of this growing population on their revenue. Spoiler alert: It isn’t good news.

The challenge: Medicaid risk adjustment is a moving target.

Most health plans acknowledge the value of risk adjustment for the Medicaid population.  However,  implementing a successful program is a difficult process. Why? Medicaid risk adjustment programs are complex and vary by state. For example, while most states use the Chronic Illness and Disability Payment System (CDPS), there are several others including DxCG, CRG and more. Furthermore, states’ risk adjustment regulations, incentives, and penalties all tend to vary widely.  This variability poses challenges and increased costs particularly for multi-state health plans when trying to devise and implement a comprehensive risk adjustment strategy.

Other challenges include the frequency with which Medicaid eligibility changes, volatility among sub-populations, as well as the difficulty associated with obtaining encounter data from an often-transient population. Despite these obstacles, risk adjustment is incredibly important because Medicaid managed care is often high-risk with low margins and reimbursement for care of this population depends on the specificity and accuracy of encounter data.  

The complication: A growing Medicaid population could dilute risk.

Here’s where it gets even more complicated. Most states aggregate risk scores and then compare the performance of health plans in a region to each other. Failure to ensure Medicaid members receive appropriate care, including comprehensive annual exams by a primary care physician, can lead to severely diluted risk scores. New Medicaid beneficiaries are most likely to be individuals for whom health plans have no prior encounter data. This means there is no baseline for understanding how much it will cost to care for these members. Imagine an individual with multiple complications due to uncontrolled diabetes. If the health plan does not receive this data from care providers, it can’t accurately report this information to the state, which can result in sub-optimal funding to provide the care necessary for that beneficiary.

The same is true for members with previously diagnosed chronic conditions. Recapture of these conditions is critical to developing accurate population risk scores. If the diagnosis was reported in the prior year, but not the next, they will be omitted from the risk score calculation. Lastly, failure to accurately capture social determinants of health leads to systemic under-compensation, which disproportionately affects physicians and health plans serving these patients.  This was true before COVID-19, but it is even more critical now as the number of Medicaid beneficiaries has risen and continues to grow.

Ultimately, Medicaid plans must ensure their encounter data accurately reflects severity of illness and risk of mortality, of their covered population. Otherwise, they could find themselves spending far more than they actually receive in payments.

The solution: A PCP-centric, health-plan sponsored program.

The sooner Medicaid plans can accurately capture all chronic conditions and social determinants of health, the better. The most effective and streamlined way to do this is by leveraging primary care physicians (PCP) who have the ability to quickly establish long-lasting  relationships with these patients. PCPs are the providers with whom patients develop trust and, therefore, are likely to  see most frequently. Through frequent interactions and encounters with their PCPs, it is possible to address health problems in real-time and document social determinants which may be impacting their health and quality of life.  

When health plans sponsor PCP-centric risk adjustment programs, they are creating a win-win dynamic – ensuring that their members will receive high quality care in the most appropriate setting, and making sure they receive the correct amount to manage the patient.  Unlike other programs that work around physicians and cause abrasion, PCP-centric programs support physicians and their staff with the clinical support and technology to efficiently document all chronic conditions and code to the highest degree of specificity.  In addition, PCP-centric, health-plan sponsored programs often include services to assist with member engagement,  appointment scheduling and confirmation, patient education on the use of telehealth, and more. These wrap-around services are particularly helpful with transient populations for whom outreach requires more persistence. The more touch points patients have with their provider, the more likely that provider can capture data that leads to accurate risk adjustment and appropriate reimbursement. The best part? There’s no additional burden placed on physicians and staff. For the health plan, the benefits of these programs include higher quality data capture, improved outcomes, and lower costs due to greater patient engagement. Additionally, an enhanced bond between a PCP and his or her patients helps reduce the likelihood that a patient will switch health plans.    

3 ways health systems can improve care and earn additional income

After an extremely challenging year for healthcare systems, there are now opportunities to improve financial and clinical performance as the country begins to normalize.

In 2020, hospitals and health systems lost at least $323 billion and physicians were stretched to the breaking point. Unfortunately, the burden does not seem to be lightening for primary care physicians. Approximately 40% still feel the same level of strain due to COVID-19 that they felt a year ago. Finding additional ways to generate much-needed revenue, positively impact care, and reengage with patients is more critical now than ever before.

Preventive care services

It’s no secret that patients missed out on preventive care services due to the pandemic. Over the past year, 31% of patients in the United States delayed care and more than 50% of seniors canceled existing appointments. It is imperative to get back on track with preventive and routine care, especially for patients with chronic conditions.

Your physicians and staff should be proactively reaching out to patients, particularly Medicare patients, to schedule appropriate preventive care visits, such as Annual Wellness Visits, immunizations, and various cancer screenings.  Scheduling a preventive care visit is a win-win for the patient and the physician. For the patient, it’s typically a no-cost visit that aids in the early detection and prevention of diseases, reduces the exacerbation of existing chronic conditions, and improves overall health and quality of life. For the physician, it’s a great opportunity to reengage with patients, create new revenue streams, and improve outcomes, which is especially important for improving performance under value-based care arrangements.

Health plan incentives

Health plans are eager to collaborate with physicians to achieve coding and quality of care goals. They need data and insights into their members and are willing to incentivize your organization to get it. Many payers offer programs that are free to your physicians and also pay incentives to capture real-time diagnostic coding that enables them to accurately risk-adjust their members. Some of these programs even help take the burden off of physicians and their staff by partnering with organizations that do the majority of the work, and they simplify the workflow by combining coding with preventive care services such as Annual Wellness Visits.

The timing for this could not be better. There is an emerging trend among health plans to shift from home assessments to PCP-centric prospective programs to better risk-stratify their members and address gaps in care. Given the established relationships patients have with their PCPs, prospective programs are often the most effective method for addressing gaps in care and ensuring alignment between medical record documentation and coding to the highest degree of specificity. Prospective programs permit real-time alerts of previously diagnosed conditions as well as those that are suspected. This ability to impact outcomes at the point of care is powerful.

VBC performance

Value-based care is designed to incentivize providers to improve outcomes in a cost-efficient manner. In other words, payment and quality of care are inextricably linked. The combination of driving higher utilization of key preventive care services and improving the accuracy of coding supercharges value-based care performance.  

Unfortunately, many physicians lack the tools, resources, and experience to thrive in the value-based care model. Diagnostic coding and quality reporting are labor-intensive tasks and are predicated on a complex set of rules. In addition, EMRs are not equipped with all the necessary functionality and may not contain relevant health plan data, which results in an incomplete patient picture and suboptimal outcomes. Fortunately, there are solutions that include computer-assisted diagnostic coding technology, enhanced quality measure reporting, and clinical decision support at the point of care — all of which enable PCPs to improve outcomes and their financial performance under value-based care arrangements.

As we continue to move toward a new normal, physicians are beginning to see more patients for routine in-office visits, making this the perfect opportunity for patients and physicians to start reaping the numerous benefits derived from a refocus on preventive care and partnering with health plans on in-office programs to improve diagnostic coding and documentation.