Price transparency, surprise billing, and a renewed focus on the workforce grabbed much of the focus from revenue cycle leaders during another unprecedented year.
It was another tumultuous year for the revenue cycle, from the slow burn of price transparency and the fight over surprise billing, to the renewed focus on the workforce, not to mention the continuing COVID-19 pandemic.
Here are three issues that defined 2021 for the revenue cycle:
1. Price transparency's slow burn
For all the build-up and fretting over the price transparency rule, it got off a slow start and hasn't sped up much since. Just a few days after the January 1 compliance deadline, Becky Greenfield, a partner with Wolfe Pincavage, told the HealthLeaders Revenue Cycle Podcast that none of the hospitals she had investigated were fully compliant with the rule yet.
Not much changed as the year progressed. In February, a Guidehouse analysis found that roughly 30% of hospitals weren't compliant with either requirement of the CMS price transparency rule, and only 48% of hospitals were compliant with at least one element of the machine-readable file requirement.
By June, research published in JAMA Internal Medicine confirmed what had been anecdotally reported for months: That hospitals are choosing which parts of the rule to comply with, and that partial compliance is common.
By late fall, though, there were indications that noncompliant hospitals might not be able to skate by forever. CMS said in its final Outpatient Prospective Payment System (OPPS) rule for 2022 that the fines are going up. It said it will set a minimum civil monetary penalty of $300 per day for hospitals with 30 or fewer beds. Hospitals with more than 30 beds will be charged $10 per bed per day, which will cap at $5,500 daily, and the maximum total penalty amount would be $2,007,500 per hospital.
Eric D. Hargan, former deputy secretary of the U.S. Department of Health and Human Services, told HealthLeaders that the fact that two polar-opposite presidential administrations support price transparency is a good indication that it's not going away.
Plus, he noted that the government may keep raising fines until it gets compliance. Moreover, hospitals that make a good-faith effort to comply will have credibility when it comes to showing the government which parts of the rule need to be changed.
"It's the people that recognize the shape of things to come and help participate in it … who will have a chance to shape what goes forward," Hargan said.
2. Surprise billing heats up
We're only days away from surprise billing's first enforcement deadline, but the fight over it is far from over.
The government said relatively early in the year that it would be using final-offer, or "baseball-style," arbitration to settle payment disputes between payers and providers when they can't resolve them on their own.
But the exact details didn't emerge until September, and when they did, they caused an uproar.
That's because organizations like the American Hospital Association and the American Medical Association, as well as lawmakers, say that the regulation issued Sept. 30 directs arbitrators "to lean toward picking the amount closest to the median in-network rate negotiated for the type of care involved," Kaiser Health News reported, which they say unfairly favors insurance companies.
In fact, the AHA and AMA are among several groups who have filed lawsuits to change that provision.
Another key element of the rule is delayed: HHS said it would defer the good faith estimate requirement for insured patients "until rulemaking to fully implement this requirement…is adopted and applicable."
Meanwhile, another major surprise billing issue is on the agenda for the new year: After ground ambulance bills were left out of the No Surprises Act, a new federal advisory committee will provide recommendations about how consumers can be protected against "exorbitant charges and balance billing when using ground ambulance services."
3. A renewed focus on the workforce
As the world enters the third year of the COVID-19 pandemic, the workforce has seen dramatic changes, and the revenue cycle is not immune. Nearly two years into the pandemic, many revenue cycles continue to work remotely, and leaders have developed strategies to manage a workforce that isn't physically together.
Those have included replicating the office infrastructure at home with all the equipment and technology employees need; requiring employees—and managers—turn on their cameras and microphones to stay active and engaged in virtual meetings; and doubling down on communications, including formalizing tiered huddles, holding town hall meetings, and having regular leadership-level check-ins.
A focus on the workforce also means focusing on the future. As baby boomers begin to retire and the revenue cycle increasingly requires more specialized skills, it's crucial for revenue cycle leaders to think seriously about succession planning, said Cassi Birnbaum, PeaceHealth's senior enterprise director of HIM, coding, and CDI.
Finally, revenue cycle leaders have started to think outside traditional roles and staff payment structures to ensure success. For example, at UC San Diego Health customer service is the highest paid position in the revenue cycle, and University of Wisconsin Health hired a denials management nurse to help the revenue cycle recognize trends, gain better insight into the tactics payers use to deny claims, and successfully appeal claims.
Alexandra Wilson Pecci is an editor for HealthLeaders.
