CommonSpirit Health mandates COVID-19 vaccination for employees in 21 states

About Us | Serving the Common Good | CommonSpirit Health

CommonSpirit Health is requiring full COVID-19 vaccination for its 150,000 employees, the Chicago-based health system said Aug. 12. 

The requirement applies to employees at CommonSpirit’s 140 hospitals and more than 1,000 care sites and facilities in 21 states. It includes physicians, advanced practice providers, volunteers and others caring for patients at health system facilities. 

“As healthcare providers, we have a responsibility to help end this pandemic and protect our patients, our colleagues and those in our communities —  including the most vulnerable among us,” Lloyd H. Dean, CEO of CommonSpirit, said in a news release. “An abundance of evidence shows that the vaccines are safe and highly effective. Throughout the pandemic we have made data-driven decisions that will help us best fulfill our healing mission, and requiring vaccination is critical to maintaining a safe care environment.”

The compliance deadline for the vaccination requirement is Nov. 1, although the implementation date will vary by region in accordance with local and state regulations. Employees who are not in compliance and do not obtain a medical or religious exemption risk losing their jobs.

I just got Fired!

https://interimcfo.wordpress.com/2021/02/11/i-just-got-fired/

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I went out on a social event with a hospital CFO. During the course of the day, it seemed that all I heard was griping about the CEO. Then I heard that the organization was ‘giving back’ most of the last year’s gains, how most of the leadership team were idiots, and on and on. Finally, I told my friend that I thought he was in burn-out and that if he did not do something to alleviate the stress he was bearing, things were not going to end well. A couple of weeks later, I received a call from my friend. The conversation started with, “You will not believe what just happened.” My answer was, “How many guesses do I get?”

In hindsight, it was easy to see this transition coming. I know. It has happened to me – more than once. The circumstances, emotions, and process leading up to a transition event are relatively consistent in my experience. People stop listening to you. You start feeling out of touch with the rest of the organization. Your relationships with peers begin to cool, especially the relationship with the boss. You learn that you are increasingly not invited to important meetings or summoned to participate in matters that are clearly within your scope. You begin to sense divergence of political and or philosophical views with the core leadership of the organization. Your boss and others start going around you to approach your staff directly.

These processes continue until you get invited to an unscheduled meeting where you learn that you are about to be freed up to seek other opportunities.

First, a disclaimer. I am assuming that the termination is not for cause, i.e., violation of policy, violation of the law, or behavior unbecoming. The majority of separations and terminations I am familiar with have little if anything to do with cause and occur primarily because of lack of fit or growing disagreement between the incumbent and their manager regarding the organization’s course. Sometimes, the incumbent’s area of responsibility is no longer meeting the needs of the organization. Too often, internal corporate politics are responsible for deals that started well souring. Sometimes, a transition follows an executive, usually but not always the CFO, digging in over their interpretation of the organization getting too close to crossing a compliance red line. Instead of greasing the squeaky wheel, the organization decides to address the problem by getting rid of the irritant. I have been in a situation more than once where I had to decide whether my integrity was for sale and what a fair price might be. In every case, I elected to avoid the disaster that has befallen executives that flew too close to the OIG’s flame, and in one case, it led to a separation from the organization.

One of my favorite Zig Ziglar quotes is, “Failure is an event; it is not a person.” Just because someone ends up in a transition does not mean by definition that they are a terrible person. Time and again, in these blogs, I have stipulated that for me to follow someone that was ‘bad’ in some way is extremely rare. In these articles, I address termination from the view of the ‘victim.’

I am speaking from experience writing this as I have been through an unplanned transition more than once. I know my problem; I get frustrated with politics, BS, sub-optimization, the toxicity of culture, and eventually lose my sense of humor or ability to eat crap without gagging. Not too long after I start telling people what I really think and, . . . . well, you know the rest of the story. What I believe is a growing risk of being an employee is why I decided to leave permanent employment and become a career Interim Executive Consultant. Regardless of the cause of a turnover event, it is gut-wrenching. Even if you sense it coming, it is no easier to bear. In a matter of a few minutes, you go from someone whose expertise and perspective are in high demand to someone that has no reason to get out of bed. The pain is increased exponentially by those that used to dote on you refusing to return phone calls or answer emails.

More than once, I have received a call from someone looking for help because their deal either has gone bad or is in the process of deterioriation. Invariably, a few weeks later, I get the call. Upon answering the phone, the conversation starts, “You aren’t going to believe what just happened to me!” My first thought is not again! It pains me almost as much to witness someone else go through a transition as it is to go through it yourself. As I said before, my response is, “How many guesses do I get?” I ask this question with a high degree of certainty that the answer is a forgone conclusion.


Sadly, people going through a transition process do not fully appreciate what they are facing, especially the first time. The first problem is the amount of time the executive is going to be unemployed. When this happened to me the first time in the ’80s, I was shocked when a mentor told me to expect a month for each $10,000 of pre-transition compensation. I could not believe this was possible, but I have seen it happen time after time. With the inflation that has occurred since then, a good rule of thumb is probably a month for each $20,000 of pre-transition compensation. Thinking back to my principle that the time to start planning for a transition is now, one of the things to be prepared for is up to a year of interruption in income unless you are fortunate enough to have a severance agreement.

Contact me to discuss any questions or observations you might have about these articles, leadership, transitions, or interim services. I might have an idea or two that might be valuable to you. An observation from my experience is that we need better leadership at every level in organizations. Some of my feedback comes from people who are demonstrating an interest in advancing their careers, and I am writing content to address those inquiries.

I encourage you to use the comment section at the bottom of each article to provide feedback and stimulate discussion. I welcome input and feedback that will help me to improve the quality and relevance of this work.

If you would like to discuss any of this content, provide private feedback or ask questions, you can reach me at ras2@me.com.

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Hospitals drag feet on new regulations to disclose costs of medical services

https://www.washingtonpost.com/politics/2021/01/25/health-202-hospitals-drag-feet-new-regulations-disclose-costs-medical-services/

Price Transparency In Medicine Faces Stiff Opposition — From Hospitals And  Doctors | Kaiser Health News

Hospitals are now required to disclose the prices they secretly negotiate with insurers.

But many are dragging their feet on the new regulations, which were passed under President Donald Trump and could very well stay in place under President Biden.

The rules went into place Jan. 1, but hospital compliance is spotty.

“Hospitals are playing a hide-and-seek game,” said Ge Bai, an expert on health-care pricing at Johns Hopkins Bloomberg School of Public Health. “Even with this regulation, most of them are not being fully transparent.”  

Hospitals lost a bruising court battle last year to stop the rules, which require them to publish a list of prices for goods and services. The point is to bring more transparency to prices for medical goods and services — information that has long been inaccessible to consumers. The new rules were a centerpiece of Trump’s promise to inject more price transparency in the health-care system and curb surprise billing.  

But Nisha Kurani, a policy analyst at the Kaiser Family Foundation who is tracking hospital responses to the new rule, said she’s seen the full gamut. 

MedStar in Washington posted its prices in an Excel sheet on its website, but other hospitals only posted price estimates, uploaded files in difficult to use formats, or promised to release information only after someone inputs their insurance, Kurani said. 

Gothamist investigation found that only one of five major New York hospitals posted a list of their negotiated services to their website, and even then, not for all procedures. The fine for not complying with the new rules — $300 a day — is a drop in the bucket for many hospitals. 

The rules probably aren’t going away anytime soon. 

The Biden administration hasn’t taken any public position on the rules — and right now, officials are focused on reversing dozens of other Trump administration regulations they believe are damaging to health insurance and costs in the United States.

Revising the hospital transparency rules — if that’s even something the new administration wants to do — would likely be far down on the priority list, despite heavy lobbying by the hospital industry to suspend enforcement of the new rule. 

Plus, price transparency is broadly popular among the public and was one of the planks of a joint health policy plan developed by a task force Biden formed with Sen. Bernie Sanders (I-Vt.) after the 2020 primary elections. 

The American Hospital Association says staff who would help with compliance are stretched thin.

Molly Smith, the association’s group vice president for public policy, said many of the staff members who would normally be tasked with compiling and formatting the price data are the same people being asked to help set up patient registries and vaccine tracking systems in response to the pandemic.  

“We’ve got a lot of hospitals that are at or beyond capacity,” Smith said.  

A lawyer for the hospital association said that it is considering petitioning its legal case to the Supreme Court. Meanwhile, the lobbying group has been pushing the Biden administration to suspend enforcement of the new rule. 

Consumer advocates like the transparency rules designed to protect patients and drive down health-care costs.

“In the past there was absolutely no power for the consumer. It was like highway robbery being committed every day by the health-care system,” said Cynthia Fisher, head of the nonprofit Patient Rights Advocate, which pushes for price transparency.  

But now, Fisher says, “it’s the American consumer who is going to drive down the cost of care.”

But the effect might be modest.

Experts in health-care economics hotly debate whether the price transparency rules will, in fact, drive down costs. Even those who support the changes say the effect might be incremental.

“I don’t think it’s going to be an earthquake in terms of pricing, but it’s a first step in the right direction,” said Bai.  

There are several reasons the new price transparency rule may not have a massive effect on hospital prices. Perhaps the biggest, and one often cited by the hospital lobby, is that most Americans are not going to pay the negotiated price for a procedure. Instead, they are likely to pay co-pays or coinsurance that amount to a fraction of this price

This isn’t always true, of course. Those with high-deductible plans may pay the negotiated rate, and for those without insurance paying out of pocket, it can be helpful to get a peek behind the sticker price. But even for these patients, it may be challenging to extract useful information from unwieldy spreadsheets full of obscure billing codes. 

Bai said that she is hopeful that third parties may make some of the pricing information easier for consumers to use. And some self-insured employers may start identifying cheaper providers and incentivizing patients to use them. The rules also require hospitals to provide cost-sharing estimates for commonly used procedures in an easily navigable format. 

Still, price competition works only if there are players to compete. 

The market for health care has become increasingly consolidated as hospitals merge and buy up physician practices. If a hospital is the only health-care provider in town, then there’s not a whole lot patients can do about high prices, even if they think they’re unfair. 

“I don’t think transparency will fundamentally change the power balance between the payer and the hospital in many markets,” Bai said. 

Hospitals that don’t submit daily COVID-19 data could lose participation in Medicare, Medicaid

US Department of Health and Human Services moves to Microsoft Office 365

Hospitals currently not reporting daily COVID-19 data have a few months to get in compliance or risk being thrown out of Medicare and Medicaid.

The Department of Health and Human Services (HHS) announced Tuesday it will send notices to all hospitals over their requirements for reporting COVID-19 data to the Trump administration.

Any hospital not in compliance with the daily reporting requirements will have 14 weeks to get in line or risk their participation in Medicare and Medicaid, officials said.

The agency gave an enforcement timeline that gives “hospitals ample opportunity to come into compliance,” said Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma on a call with reporters Tuesday.

The Trump administration wants hospitals to submit daily data that includes COVID-19 deaths and hospitalizations as well as patients currently in the intensive care unit with the virus. Hospitals must submit data on the ages of patients admitted with suspected COVID-19 infections. Facilities need to also report their inventory of the COVID-19 therapy Remdesivir, any staffing shortages and the number of ventilators. Every week hospitals also report data on their personal protective equipment on hand and supply of critical medications.

Facilities now must also report on new data for influenza cases. “The new requirements will allow us to gather critical information on influenza at hospitals across the U.S.,” said Centers for Disease Controls and Prevention Director Robert Redfield, M.D.

Verma said that the large majority of hospitals in CMS’ system are already reporting this data to the agency. CMS will also give hospitals that are not in compliance a wide berth to get them into compliance.

Hospitals will be sent multiple notices over the 14-week timeline to get their data reporting in line.

“This work of getting hospitals into compliance around reporting has been an ongoing effort,” Verma said.

CMS proposed the mandatory daily reporting requirements back in August, much to the chagrin of hospital advocates. 

The American Hospital Association (AHA) said that CMS tying Medicare and Medicaid participation to compliance “remains an overly heavy-handed approach that could jeopardize access to hospital care for all Americans,” according to a statement released Tuesday. 

“Today’s interpretive guidance on COVID data reporting does answer some of the questions hospitals and health systems have been asking about compliance since the interim final rule was released six weeks ago,” the group said. “In particular, the Administration will provide hospitals with information on whether their data are making it into HHS Protect and they will give hospitals the necessary time to adjust their data collection to come into compliance if need be.”

The Federation of American Hospitals called the new rules “sledgehammer enforcement.”

“It is both inappropriate and frankly overkill for CMS to tie compliance with reporting to Medicare conditions of participation,” said FAH President and CEO Chip Kahn in a statement.

6 months in: Following the flow of CARES hospital funding

https://www.healthcaredive.com/news/6-months-cares-hospital-funding-covid/581506/

Congress has allocated $175 billion to help providers respond to the COVID-19 crisis, but HHS has been hit with multiple complaints about distribution as that money goes out the door.

The COVID-19 pandemic created massive upheaval for the nation’s healthcare system still evident six months after the U.S. declared it a national public health crisis.

The virus continues to surge, reaching new heights with more than 4 million confirmed cases and more than 143,000 deaths. No other country has experienced more deaths or cases than the U.S., data with Johns Hopkins Coronavirus Research Center show.

Parts of the country are facing the prospect of another lockdown as cases overwhelm healthcare facilities.

Forced into quickly responding to the pandemic, health systems have taken substantial financial hits. While the impact has been far from even, one estimate from the American Hospital Association estimates the nation’s health systems’ financial losses in the first four months of the outbreak reached nearly $203 billion.

To help staunch the free fall, Congress earmarked $175 billion in two pieces of legislation in an attempt to keep providers afloat as the virus wreaked havoc on the economy. The majority of that was from the Coronavirus Aid, Relief, and Economic Security Act passed in late March.

Yet, about 65% of the money has yet to go out to providers, with just $61 billion delivered and attested to by providers by mid-July, a senior HHS official told Healthcare Dive.

Still, with no end in sight for the pandemic, at least on U.S. shores, providers are ramping up lobbying in an effort to secure more funding as case counts soar. AHA is asking for another $100 billion in the next round of congressional relief now under discussion.

Many healthcare providers stopped profitable elective procedures as stay-at-home orders blanketed parts of the country to contain the spread of the disease. This also allowed providers to conserve much needed resources such as personal protective equipment that proved hard to procure amid the crisis.

But revenue quickly plummeted as providers delayed care in preparing for a surge of COVID-19 patients.

“The funding hospitals and health systems have received to date, while helpful, is just a small fraction of what we estimate they will lose this year,” Lisa Kidder Hrobsky, group vice president of federal relations for AHA, told Healthcare Dive in a statement.

Where did the money go?

So far, HHS has outlined a spending plan for $125 billion of the $175 billion in provider relief funds.

The program has been met with an array of criticism, including whether the distribution of funds went to those most in need and whether the fine print has deterred providers from taking a piece of the massive financial package.

https://www.datawrapper.de/_/7PvZ4/

In response to those critiques, HHS has sent out additional federal funding in more targeted waves since April.

The first tranche of money — $30 billion in April — was designed to get out the door quickly, as providers were struggling. From there, HHS has attempted to pinpoint the money to certain providers and geographic areas to appease the needs of various providers.

To even out distribution, HHS began sending targeted funding, such as to hospitals overrun with COVID-19 patients, mainly in New York and other hard hit areas. The agency also funneled money to rural providers and skilled-nursing facilities, among others.

After HHS was met with the argument that wealthier hospitals, or those that had larger shares of privately-insured patients, received more funding, it allocated money for those taking care of the neediest.

At the same time, as the agency doles out the rest of the $175 billion, it has promised to reimburse providers for uninsured COVID-19 patients. That has raised questions about whether HHS will have enough for uninsured care and additional tranches.  

However, a senior HHS official said it has only paid out $340 million to providers for uninsured COVID-19 patients, less than what they had expected. So low, that HHS has been trying to encourage providers to apply for such funding.

Timeline of HHS funding

  • AprilHHS​ released $30 billion from the first tranche of money based on a provider’s 2018 Medicare fee-for-service revenue. By the end of April, an additional $20 billion from general distribution was released, for a total of $50 billion.
  • MayMore than $26 billion was sent to rural, skilled-nursing facilities and those hit hard by the virus.
  • JuneHHS released an additional $25 billion earmarked for safety-net providers and those that cater to large populations of Medicaid patients.
  • JulyHHS​ said it would release another $4 billion for safety-net providers and certain specialty rural providers missed in earlier rounds, along with another $10 billion for those in hot spots.

Fears eased over fine print

Some providers declined or returned funding they had received, worried about the fine print or the terms and conditions, like how to appropriately spend the money.

However, HHS has relaxed some of those conditions, easing the fears of some.

For a lot of providers, it was a sigh of relief, causing many to say, “‘Great, we can feel comfortable participating in this program’,” Tim Fry, an attorney with McGuireWoods, told Healthcare Dive.

In particular, HHS recently said that if at the end of this pandemic, providers didn’t use all of the funding for lost revenue or healthcare related expenses, there will be a process to return the money. Initially, providers expressed concern that it was an all-or-nothing program.

Plus, HHS provided clarity on how the money can be used, stipulating that the funds go to healthcare-related expenses or lost revenue attributable to the coronavirus. HHS has provided more guidance and examples of appropriate uses, a relief to many, Fry said.

Earlier, health systems were overwhelmed by the administrative burden and fearful over how to appropriately spend the money without running afoul of new rules.

“We are not infinitely flexible around those requirements, but when we hear from providers of issues that they’re having — and we think we can be reasonably [accommodating], we try to be,” a senior HHS official said.

 

 

 

 

Five components of an intelligent middle revenue cycle

https://www.beckershospitalreview.com/healthcare-information-technology/five-components-of-an-intelligent-middle-revenue-cycle.html

What is revenue cycle management (RCM)? - Definition from WhatIs.com

Keys to achieving revenue integrity and compliance across your organization

It’s old news: Revenue cycle complexity continues to increase, exacerbating existing challenges. And as we tackle those, new ones arise to take their place.

Ever-changing regulations are a given, but adopting value-based reimbursement (VBR) models currently poses a major challenge. New payment models complicating revenue cycle activity become more difficult with additional quality reporting and other requirements. Add in the operational realities of siloed workflows, data proliferation, and disparate systems, and it’s clear why efficient collaboration can seem nearly impossible.  Intelligent middle revenue cycle operations that manage to these challenges are vital to achieving revenue integrity and financial stability.

 

Use the right solutions at the right time

Today’s environment requires sharpening the way you ensure revenue integrity. Providers need an easy, seamless way to manage middle revenue cycle operations, and there are several effective strategies to accomplish that. Of course, it’s important to recognize and make use of your EMR system’s capabilities. It’s also essential to leverage complementary technologies with specific core competencies that will improve revenue cycle performance. For example, a solution that continuously monitors records in real time enables timely auditing, coding adjustments and case completion to reduce billing turnaround and reimbursement delays.

 

Take a smart approach to enabling technology

Augmenting your core systems with complementary technologies or capabilities on a single, integrated platform makes it much easier to support internal collaboration between different departments or teams. An integrated platform also enables you to seamlessly deploy additional capabilities onto that platform, ensuring speed to value. Instead of using multiple disparate tools, a shared platform enables interdepartmental communication and helps minimize inefficiency.  A smart technology platform that crosses departmental siloes and brings transparency across teams is critical. Platforms that leverage clinically aware artificial intelligence and other automation enable staff to proactively focus on the areas where their expertise has the most impact. In addition, when leveraging an integrated platform, one expert team’s work will not get cancelled out by another team’s contributions.

Regardless of which core system you use, integrating technology with targeted competencies and connectivity adds value to the EMR. It can provide a depth of specialized expertise that drives better documentation, coding and real time audit interaction — keys to a high-performing revenue cycle.

 

Prioritize comprehensive, correct documentation and coding

Unfortunately, it seems the battle against claim denials is here to stay. You can’t overlook the importance of front-end data validation to eliminate rework and inefficiency. However, the ability to ensure complete and accurate clinical documentation for every case will significantly impact revenue capture and reduce the inefficiency of denials and rework.

Broaden the scope of your CDI program with technology that uses clinical intelligence to drive concurrent documentation review for all payers. Getting it right up front contributes to better coding, accurate reimbursement, and appropriate quality measures, all of which are vital to success under VBR.

 

Increase collaboration with payers

As long as payers and providers continue working at odds, the costly onslaught of denials will persist. In a perfect world, both sides would join forces to find mutually beneficial solutions for claim errors, denials and payment delays. Imagine the savings in administrative inefficiency alone. However, we’re not in that world yet. Therefore, it’s important to make a proactive effort to understand the specifics of each payer’s contract and adjust your internal processes and technology rules accordingly. As operating margins get smaller, organizations have no choice but to increase efficiency and accuracy, and working together with payers can contribute significantly to that goal.

 

Consolidate, collaborate, communicate

Industry pressures to improve performance are unrelenting, especially around smart solutions, innovation, and increasing both efficiency and the bottom line. Organizations are expected to improve these areas while, at the same time, enabling patient-centric operations. One way to achieve this is to leverage innovative, integrated tools to augment core systems and promote partnership, communication and efficiency across multiple related disciplines.

Consider clinical documentation, coding and auditing. Numerous departments need pieces of that information for different reasons, including utilization review, medical necessity determinations, chart audits and quality monitoring, in addition to bill preparation. A single repository containing up-to-date data in a real-time view driven by supporting workflow, rules and alerts provides consistent and reliable information when and where it’s needed.

As patient care becomes more complex, so does the middle revenue cycle. Seek solutions that will simplify and manage the complexity in an administratively efficient way. Consider your prospective vendor’s core competencies when evaluating solutions and look for integration and intelligent automation that will add the most value to your organization.