Last month I talked about the importance of having a clear, well-articulated vision for your business. This month, I am thinking about how environmental factors might impact O&P over the next year or two and how that clarity of vision can help you navigate any changes that come along.
There are two ways to handle changes we can’t control: The fatalistic approach (Oh well, there’s nothing I can do, so I’ll just see what happens) and the strategic approach (I can’t know exactly how I am going to get to where I am going, but I am going to execute my plan based on my vision.) I hope you are in the strategic group.
Have you heard of the “Regulatory Sprint to Coordinated Care”? This refers to a 2018 Health & Human Services (HHS) effort to accelerate change in the United States healthcare system by removing “unnecessary obstacles” to coordinated care. The latest unnecessary obstacle to fall is the 2006 Stark law. The Stark law was intended to prevent physician self-referral, which many in our profession believe helped slow the trend of physician-provided O&P care. It is not repealed, but it has been modified to simplify the physician’s ability to refer patients within their financial empire. This could lead to negative consequences for O&P.
The desire for episodic payment bundling has never subsided, but like all government initiatives, it moves at a glacial pace. Today’s buzz phrase is the “coordinated delivery of quality healthcare.” As a glacier moves, every inflexible thing in its path gets destroyed. And as you must realize, ours is a very small profession with many voices shouting out, “We’ve always done it this way!” The reality is that we are not at the forefront of the policymakers’ minds when they determine policy, and what impacts our referral sources will impact us. It rolls downhill, you know.
What do we know? The current administration wants to expand access to healthcare, incent the coordination of care, and reduce the number of healthcare providers participating in the fee-for-service model. This information is all widely publicized and readily accessible for validation. But further, we need to look at President Biden’s nominees and appointees to key positions to see where we think they are heading.
Expect an increase in RAC audits with Xavier Becerra heading up HHS. According to Knicole C. Emanuel, Esq., at racmonitor.com, Becerra will bring his prosecutorial efforts to the healthcare system and is expected to increase audit activity. Furthermore, a January 27 posting at medicaidlawnc.com says we can expect a renewed emphasis on False Claims Act violations [31 U.S.C. § § 3729-3733].
So get ready. The landscape is changing. It will be subtle at first, and there will be some resistance. I don’t think we are going to be faced with value-based care in O&P in the next few years, but I do think we are going to see increased scrutiny of our records and processes. It’s up to you now to make sure that your practice has the people and the processes in place to anticipate and then strategically respond to changing environmental conditions. Your documentation is more important than ever, and the tools you use to record and maintain that documentation are more important than ever. What is it worth to you when it comes to supporting and defending your business against these threats? How well prepared are you and your staff to respond? What can you do to get ready?
The opinions expressed are not necessarily those of The O&P EDGE.