*Pay-for-Performance – With an escalating interest in value-based purchasing on the part of Congress, Medicare and other payers, health care practices must begin to position themselves to align with this new payment paradigm. CSI is familiar with the measure development process and the numerous demonstration projects currently underway. Connolly is prepared to assist health care entities in making a successful transition to this new reimbursement scheme.
*Regulation Interpretation, Guidance, Advocacy -- Those clients interested in successfully navigating the health care regulatory channels should feel free to call upon the experience, strategic expertise, policy analysis and contacts of Connolly Strategies in an effort to gain adequate coverage and proper payment for services provided to patients.
*Medicare Therapy Caps – The arbitrary Medicare cap on therapy has been suspended through June 2008 and replaced with an exceptions process. Documentation and quality measurement guidelines were outlined in CMS Transmittal 63. Congress must act to prevent the therapy caps from taking full effect on July 1. CSI can provide an effective voice for your organization in advocating for repeal or replacement of the arbitrary therapy caps. Continued grassroots pressure on Congress is critical at this time. Likewise, it is important to engage in meaningful work that will lead to the identification of possible alternatives to the cap such as including outliers and outcomes measurement. It will be from such proposals and from the numerous studies currently underway that the likely successor to the $1810 cap will emerge.
*Provider Reimbursement – Congress enacted a 0.5% increase in the Medicare Physician Fee Schedule effective for the first six months of 2008. Continued grassroots pressure on Congress is critical to avert a fee schedule cut of more than 10% on July 1. Since 2001, Connolly has been strategically involved in the broad coalition fighting for revision of the Sustainable Growth Rate (SGR), the arcane formula used to determine reimbursements under the Medicare Physician Fee Schedule. The coalition has been successful in postponing draconian cuts in Medicare reimbursement and will continue to work with CMS, Congress and a large cross-section of stakeholders in an attempt to develop a more reasonable formula.
*Fraud and Abuse, OIG Inspections, Audits, Corporate Compliance Plans -- From supervision of personnel to documentation and coding of treatment, every aspect of health care intervention is scrutinized in today’s environment. Connolly Strategies can provide assistance and guidance to practices and providers developing compliance plans which will protect the client against fraud and abuse errors. Important guidance with respect to the False Claims Act (FCA) and the Health Insurance Portability and Accountability Act (HIPAA) can also be made available.
*Physician Self-Referral – Stark II – Physician self-referral has been outlawed, yet the regulations weaken a key definition that enables the practice to continue. Recent evidence indicates escalation of this phenomenon. The recently published Stark II regs are lengthy, complicated and in some cases apparently contradictory. Proper interpretation, application and response to the regulation is essential.
*Coding Issues – Numerous coding issues surface annually as a result of the yearly revision of the Resource-Based Relative Value Scale (RBRVS). Moreover, the fee schedule is being applied to nearly every practice setting, making proper interpretation and application critical, particularly in this era of stepped-up fraud and abuse detection initiatives. Likewise, every provider group has an interest in the established and rigorous regulatory requirements employed by CMS to calculate practice expense values. Connolly’s direct experience in conducting one of the first ever practice expense surveys under new (then HCFA) requirements can provide necessary and valuable guidance to a profession desiring to develop accurate practice expense data which can account for 10 to 15 percent of Medicare reimbursement.
*Rural Health Issues -- As a former clinician and practice owner who provided health care in rural Montana, Connolly understands the issues and obstacles associated with the delivery of health services to patients in rural America. Assistance with Congress or a regulatory agency in overcoming these obstacles and making the voices of rural patients and practitioners heard is a service in which Connolly Strategies excels.
*Medicare Coverage – CMS now utilizes the Medicare Coverage Advisory Committee (MCAC)to develop coverage decisions and guidelines for Medicare. This process places the burden of proof on the professions/industries to demonstrate that there is sufficient evidence to warrant coverage. Under Connolly’s direction, the APTA was successful in both of its first two attempts at moving issues through the cumbersome, political and bureaucratic process and obtaining positive coverage decisions. Organizations contemplating or facing a national coverage determination process should engage simultaneously in reimbursement strategies. CSI stands ready to assist clients prepare for and present persuasive arguments to the MCAC.
In the words of a client: "If you are unsure if you need a Washington representative, then you probably do. Jerry is knowledgeable, strategically positioned, well-connected and dedicated. He serves his clients' interests thoroughly and effectively."
JG -- CSI Client