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Experience the Eide Bailly Difference Provider Based and Rural Health Clinic: Bottom Line Impact Presented by: Ralph Llewellyn Health Care Consulting Partner [email protected] www.linkedin.com/in/ralphllewellyn 701.239.8594 Table of Contents • Rural Health Clinic • • • Provider Based Clinics • • • Compliance Cost Report/Billing Clinic Productivity • • • Compliance Cost Report/Billing Hours Worked per Direct Care Hour Six Tips for Improved Physician Productivity Scheduling • • • Block Precision No-shows www. e ideba i l l y.c om Current Challenges • The costs associated with operating clinics continue to rise • Professional services • Staffing • At the same time reimbursements are at risk • • • • Third party Medicare Medicaid Providers must act to protect their reimbursement and improve their operational performance www. e ideba i l l y.c om Rural Health Clinics - Compliance • Revisions and clarifications to RHC Benefit Policy Manual • Issued November 22, 2013 • RHC must be in both a rural and underserved location • • Existing RHCs not required to continue to meet Contact CMS if relocating or expanding www. e ideba i l l y.c om Rural Health Clinics - Compliance • Revisions and clarifications to RHC Benefit Policy Manual • Must post hours of operation at or near the entrance • • • • Hours Days Administrative time separately Non-physician providers • Must be employed to be reimbursable • RHC • Entity that has 100% ownership of RHC • W-2 www. e ideba i l l y.c om Rural Health Clinics - Compliance • Revisions and clarifications to RHC Benefit Policy Manual • Commingling of space • Cannot pick and choose services to be RHC and nonRHC www. e ideba i l l y.c om Rural Health Clinics – Cost Report • Productivity Standards • Confusion and Inconsistency • • • 4,200 visits per 1.0 FTE Physician 2,100 visits per 1.0 FTE PA or NP No standards • • • • • Visiting nurse Clinical psychologist Clinical social worker Locum tenens Frequently overstated • Higher calculated standard • Lower reimbursement www. e ideba i l l y.c om Rural Health Clinics – Cost Report • Productivity Standards • What time is not included in FTE calculation • • • • • • Hospital patients Hospital administrative RHC administrative Continuing Education Vacation Other www. e ideba i l l y.c om Rural Health Clinics – Cost Report • RHC versus non-RHC costs • Costs associated with non-RHC services must be offset on the cost report. • • • Hospital patients Hospital administrative Emergency Room Call • Develop a strategy to capture cost • Cost may be allowable in the Emergency Room • • Other non-RHC activity Recommend time records versus per visit estimates www. e ideba i l l y.c om Rural Health Clinics – Cost Report • Emergency Room Call • • • Very difficult to identify and address if not specific in contract 80% reimbursed in RHC * Medicare utilization 101% reimbursed in ER * Medicare utilization • • Availability requirements Medicaid may also participate in cost www. e ideba i l l y.c om Rural Health Clinics – Cost Report • Pharmacy • • • Cost of pharmacy is part of cost per visit Revenue and Cost must be reported in the RHC cost center Do not report as non-RHC pharmacy costs www. e ideba i l l y.c om Rural Health Clinics – Cost Report • Lab and other ancillaries • • Separately billable Revenue and expense in corresponding hospital ancillary department www. e ideba i l l y.c om Rural Health Clinics – Billing • Charges are important • • 80% cost based reimbursement 20% charge based reimbursement • Deductibles impact calculation www. e ideba i l l y.c om Rural Health Clinics – Billing • Ancillaries are separately billable • • • Lab EKG Radiology www. e ideba i l l y.c om Rural Health Clinics – Billing • Wellness Services • • • No coinsurance or deductible applies Must be separately reported with CPT code Multiple lines possible • • • Wellness Other Market these services! www. e ideba i l l y.c om Provider Based Clinics • Blended reimbursement methodology • • Professional fee schedule Technical cost based www. e ideba i l l y.c om Provider Based Clinics - Compliance • 42 CFR 413.65 • Must meet all requirements • Most common challenges • • Public awareness Must bill all Medicare beneficiaries a technical component www. e ideba i l l y.c om Provider Based Clinics - Compliance • Public awareness • • Signage must indicate the location is part of the main provider Patient must know they are entering a department of the hospital www. e ideba i l l y.c om Provider Based Clinics - Compliance • Must bill all Medicare beneficiaries a technical component • Cannot treat some Medicare patients as provider based and others as freestanding www. e ideba i l l y.c om Provider Based Clinics - Compliance • Visiting specialists • • • Cannot treat provider based space as freestanding Designate separate and distinct space Contract for services and bill as provider based www. e ideba i l l y.c om Provider Based Clinics – Cost Report • Provider costs • • Costs associated with provision of patient care must be offset on cost report Other costs may be allowable • • • • • Medical staff Mid-level supervision Administrative time Emergency Room availability Separately identify costs in contracts when possible www. e ideba i l l y.c om Provider Based Clinics – Billing • Capture charges for all reportable procedures. • • • Injections Infusions Etc. www. e ideba i l l y.c om Clinic Productivity Assessing clinic productivity used to be simple: • Total staff hours / clinic visits = staff hours per visit Hours per visit could then be compared to: • Budget • Historical actuals • Industry averages • Number of patient visits / Provider FTEs Derive average number of visits per clinician per 8 hour shift, expressed as visits per clinician FTE. Then compare (similarly) to budget, historical actuals, or industry averages Source: Assessing Clinic Productivity by Paul Fogel www. e ideba i l l y.c om Clinic Productivity Measuring clinic productivity is made more complicated with 1. Increased non-visit patient work: emails, telephone consults, other non-visit type encounters 2. Employed physicians and use of NPs and PAs Source: Assessing Clinic Productivity by Paul Fogel Image: reach-montana.org telehealth network www. e ideba i l l y.c om Clinic Productivity The nature of clinic work has changed 1. • Patients are often assessed and given medical advice without having to visit • • • • • No registration No discharge Avoid multiple layers of clinicians Only visit when needing to be seen in person Not all clinic visits are the same • • A visit for a vaccination takes considerably less time than a visit for a minor fracture Both would be counted as visits Instead of using the usual metrics, count the direct labor time it takes for various types of visits (and non-visits) Count the minutes: a five minute flu shot counts as five minutes. A one hour appointment is counted as one hour, and a 15 minute phone consult counts as 15 minutes Your new metric is Direct Care Hours Source: Assessing Clinic Productivity by Paul Fogel www. e ideba i l l y.c om Clinic Productivity Employed Physicians and Mid-levels 2. • Physicians, NPs, PAs, allied health professionals, etc. all spend different amounts of time per patient Create a template to track minutes per encounter Various appointment types are tracked with minutes per encounter and then totaled to direct care hours Your new metric is Hours Worked per Direct Care Hour = Total Hours Worked in the Clinic / Direct Care Hours This productivity ratio accounts for both patient volume and patient mix www. e ideba i l l y.c om Source: Assessing Clinic Productivity by Paul Fogel Clinic Productivity Six Ideas for Increasing Physician Capacity: 1. Support physicians in declining tasks that do not require a physician, except in emergencies or special situations • 2. Train staff well and hold accountable to performance standards • 3. “My time is limited and I need your help” as opposed to “I am too important for this menial task” Make expectations clear: vitals taken and recorded, chief complaint is noted, patient’s chart is complete Limit physician interruptions by batching questions and documents for review/signature • Other staff also benefit from fewer interruptions Source: Simple Tips to Improve Physician Productivity by Carol Stryker www. e ideba i l l y.c om Clinic Productivity Six Ideas for Increasing Physician Capacity: 4. Minimize variability in the clinic schedule • • 5. Minimize variability in the exam room • 6. If possible, group appointment types such as annual exams, office procedures, or rechecks. This minimizes changes in mindset involved in switching from one appointment type to another Stay on track by improving your approach to scheduling. Develop strategies to prevent missed appointments and tardiness Supplies, their locations, and room layout should be consistent across all exam rooms Encourage and support physician work/life balance • • Fatigue and poor health affect efficiency and quality Fewer work hours may allow for higher quality and more efficient work hours Source: Simple Tips to Improve Physician Productivity by Carol Stryker www. e ideba i l l y.c om Scheduling • Patient scheduling can make or break critical relationships, as it’s often the initial point of contact for many patients To optimize your scheduling processes, first maximize appointment accessibility • But, choosing an appointment strategy that strikes the right balance between optimizing capacity and providing exceptional service is a difficult undertaking • www. e ideba i l l y.c om Scheduling Block Scheduling: • Uses a set time block for all visits, regardless of complaint. • Advantages: • • • • Ease of scheduling Minimization of unusable slots Limited need for clinical expertise among scheduling staff But, this fails to account for difference in types of visits www. e ideba i l l y.c om Scheduling Block Scheduling, continued • Different types of visits can take more or less time • • • • • • New patient Chronic conditions Follow up Annual Wellness Visit Physicals DOT www. e ideba i l l y.c om Scheduling To account for variations, consider Precision Scheduling • • • The idea is to more accurately match appointment times to actual complaints/complexity To execute, organizations must first conduct a procedure analysis, which involves time studies to track the minutes required for each scan Also, providers must calculate the average duration of each visit and analyze historical volumes to determine visit mix www. e ideba i l l y.c om Scheduling Lowest Common Denominator Scheduling • The shortest visit becomes the lowest common denominator with all additional visits scheduled in this increment (for example, 15 minutes) • This begins to adjust for variations in visit lengths and minimizes the risk of unusable time slots • But, it can reduce scheduling flexibility and may result in appointment inflation (rounding up) • For example, a 21 minute visit gets two blocks and takes a 30 minute slot www. e ideba i l l y.c om Scheduling Which model will meet your needs? • Block scheduling can reduce the number of available appointments but it offers flexibility which is important for institutions with high volumes of unscheduled visits • Lowest common denominator blocking methods are good for providers with a stable visit mix but having significant variation in visit lengths www. e ideba i l l y.c om Scheduling Accommodating emergencies and unscheduled outpatients: the principled add-on policy • • Administrators track unscheduled patients and analyze the data by day of week, time of day, location, and referral source The output of this analysis is used to reserve appointments when addons are most likely to occur, maximizing the ability to accommodate unscheduled visits without compromising access for scheduled patients www. e ideba i l l y.c om Scheduling What to do with no-shows: Some patients simply don’t show up • To minimize the negative impact from no-shows, look at when and why this is happening • • If there is a specific patient or group of patients that are the majority of the no-shows, communicate with them, learn why, ask for help, etc. You may be able to emphasize the importance of keeping appointments www. e ideba i l l y.c om Scheduling What to do with no-shows: Principled Overbooking • Providers can consider this when there is a highly predictable no-show pattern and when additional patient volumes can be more easily absorbed • No-show patterns and patient satisfaction must be continually monitored to ensure that customer service isn’t compromised www. e ideba i l l y.c om Questions?? www. e ideba i l l y.c om