OR Manager August 2023 - 23

Finances
needed to understand
their true effectiveness
on care outcomes and
costs. The cost side is
probably easier to quantify,
although collecting
data may be challenging
if hospitals continue to
be noncompliant, says
Esser-Lipp. The costs of
" shoppable procedures "
Fawn EsserLipp,
BSN,
MBA, CNOR,
CASC, CRCST
before and after the laws went into effect
would provide a comparison, she
adds.
Other trends, looking forward
Is there an unintended push toward a
bundled payment model? Under such
models, all costs associated with the
episode of care, including surgeon and
anesthesia fees, staff costs, supply
costs, facility fees, and any other indirect
costs, are included in one estimate
and one bill. Under the NSA, all
costs, including professional, facility,
laboratory, and testing, are required to
be included in GFEs.
Perhaps some variation of the bundled
payment model could simplify the
GFEs, Dr Patel says. " Why don't we just
say, fixing of the ACL, for example, is a
bundled price? Whether you have five
codes or 12 codes, it is going to be paid
out at the same amount. "
On September 16, 2022, CMS sent
out a request for input regarding " the
advanced explanation of benefits and
[GFE] for covered individuals. " The process
will get even more complicated
if the NSA applies to insured patients
because each health plan has different
negotiated rates with facilities and
providers. The same health plan also
may have different rates and benefits
for patients at the same facility. " The
estimate is based on the respective pay
of that patient. Some patients have multiple
payers; how do you navigate this? "
Richberg asks.
And on July 13, CMS proposed several
changes to hospital price transparwww.ormanager.com
ency
requirements, including for hospitals
to " use one of several standardized
formats for the machine-readable files;
revise the oversight and enforcement
process, including by requiring hospital
attestations of compliance; and establish
new website requirements...to ease
navigation of hospital price transparency
files. " The proposal also included
a 2.8% increase to Medicare payment
rates for hospital outpatient and ASC
services, effective in 2024, and an extension
of the 5-year interim period of
using the productivity-adjusted hospital
market basket update to ASC payment
system rates through 2025, among
other provisions. ORM
-Uyen Vo, BSN, MBA, is a freelance
writer with more than 20 years of
experience in healthcare.
References
American Hospital Association. AHA
Comments to CMS Re: Agency Information
Collection re: Requirements
Related to Surprise Billing; Part II.
March 4, 2022.
Centers for Medicare and Medicaid
Services. No Surprises Act. Overview
of rules & fact sheets.
Centers for Medicare and Medicaid
Services. Guidance on Good Faith
Estimates for Uninsured (or SelfPay)
Individuals-Part 3. December
2, 2022.
Centers for Medicare and Medicaid
Services. Enforcement Actions.
Dyrda L. ASCs get 2.8% pay bump in
CMS' 2024 proposal: 5 details.
Becker's ASC Review. July 14,
2023.
Jiang J X, Krishnan R, Bai G.
Price transparency in hospitals:
Current research and future
directions. JAMA Network
Open. 2023;6(1):e2249588.
Surprise Medical Bills: New Protections
for Consumers Take Effect in 2022.
Kaiser Family Foundation. February
4, 2021.
Cybersecurity, Belli
Continued from page 20
ments dependent on Medicare or
Medicaid; Congress continues to
cut hospital reimbursements for
Medicare. American Hospital Association.
May 2022.
Gooch K. Illinois hospital apologizes
for abrupt closure announcement.
Becker's Hospital Review. January
27, 2023.
Gross N. What businesses need to
know about cybersecurity insurance.
BizTech. November 1, 2021.
Jercich K. Universal Health Services
faces $67 million loss after cyberattack.
Healthcare IT News. March 5,
2021.
Kabir U Y, Ezekekwu E, Bhuyan S S,
et al. Trends and best practices in
healthcare cybersecurity insurance
policy. J Healthc Risk Manag. 2020
Oct;40(2):10-14.
Kuehne J. When combating ransomware,
what are your cyber insurance
options? BizTech. May 19, 2023.
Pino L. Improving the cybersecurity
posture of healthcare in 2022.
Department of Health and Human
Services. February 28, 2022.
Predicting COVID-19's long-term effects.
Definitive Healthcare. June
16, 2021.
Resource Center. Three Ways to
Improve Your Security Incident
Response Plan. HIMSS. June 30,
2020.
Rural hospital closures. The Sheps
Center for Health Services Research,
University of North Carolina.
Updated in real time.
Rural Hospital Sustainability Index
Analysis: Trends in rural hospital
financial viability, community essentiality,
and patient outmigration.
Guidehouse. May 9, 2022.
Yousry F. How a cyberattack left one
Indiana hospital reeling. NPR. May
13, 2023.
OR Manager | August 2023 23

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