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By Lyndean Brick
No one could have predicted 2020. But this year has had a monumental impact on our 2021 predictions. From healthcare delivery models and regulations to telehealth and demand in services, Advis predicts what is to come for healthcare in 2021.
The rejuvenation of in-person retail and concierge healthcare delivery models.
The 2020 COVID-19 pandemic has forever changed the way that Americans consume and utilize healthcare services. Undoubtedly, there will be a permanent shift to a variety of telehealth offerings. There is still a need in most markets, however, for in-person care that can be delivered efficiently and effectively. More than ever, providers must carefully rethink where and how they deliver services. Brick and mortar retailers, healthcare or otherwise, are uniquely positioned to reinvent the model. Providers that are most engaging, innovative, and efficient, will position themselves as market leaders. An unprecedented amount of regulatory flexibility will allow them to do so quickly and compliantly. Healthcare kiosks and mobile providers will no longer face the barriers that limited patient utilization in the past. Those providers that most uniquely position themselves for in-person services will be best suited for long-term success.
Regulatory flexibilities brought about by the COVID-19 pandemic will not fade quickly, and components of many will become permanent.
Regulatory agencies acted quickly to implement numerous regulatory waivers – from reimbursement adds to “hospitals without walls” to using everyday communications devices in telehealth – to help support patient care during this pandemic. Many of these flexibilities and benefits will not immediately fade away with the government ending the Public Health Emergency. Rather, we have already seen activity to start the permanent implementation of changes. CMS added many telehealth services to its reimbursement list and softened restrictions on virtual visits. HRSA finalized a rule to immediately allow child sites to participate in 340B once they’re established, no longer requiring the quarter enrollment period delay. We expect continued movement on this trend line, be it via Congressional activity or sub-regulatory rulemaking, to continue to make many of these COVID-19 relief flexibilities more permanent.
The Provider Relief Fund will see increased funding and more continued changes to the utilization and reporting standards.
HHS acted historically as well as quickly in providing billions of relief dollars to healthcare providers at the outset of the pandemic. Since then, however, the agency’s actions have often been confusing and sometimes problematic for providers. Frequently, HHS has changed the rules of the game midstream, flip-flopping positions on important topics such as lost revenue calculations and capital expenditures. This has required providers to pivot on relief funding strategies on numerous occasions. Still today, there is a need for clarity on how best to move forward. With the new administration and continued pushback by provider advocacy groups, we anticipate that HHS will eventually “get it right” and allow providers much needed flexibility in the form of calculating lost revenues by any reasonable method, allowing allocations amongst parent companies and subsidiaries of funding to where it is most needed, and clearly establishing eligibility and reporting standards. It may not be until mid-year when we ultimately see these changes, yet recent proposed legislation and discussions from incoming leadership show support for continued PRF funding and flexibility.
We will continue to see an expansion of telehealth services and other home-based delivery models.
We will see an adoption of many telemedicine and physician/non-physician professional supervision requirement flexibilities as instituted during the pandemic. Both institutional providers and professionals have an interest in lobbying for a permanent adoption of these flexibilities as a means to maximize their professional time and to broaden health care access beyond hospitals and physician practices. It is predicted that Congressional action will ensure allowing for continued expansion of telehealth services and other home-based delivery models aimed at limiting need for inpatient care. We will also see tech innovation accelerate as more individuals take advantage of the availability of these telehealth services.
The 340B Program will continue to be in the spotlight.
In the short term, 340B Covered Entities and advocacy groups will continue to fight against manufacturer restrictions on multiple fronts, including direct outreach to manufacturers/government representatives, formal lawsuits, and complaints brought through the recently announced 340B Alternative Dispute Resolution (ADR) process. Creative strategies and operations modifications to maintain 340B savings, including centralized distribution set ups and leveraging of hospital-owned retail pharmacies, can be expected. Manufacturers will continue to push the envelope and put legally dubious limits on when 340B pricing is offered. This will be especially true for contract pharmacy relationships due to HRSA’s questionable authority to enforce existing regulations, most of which were promulgated through informal guidance. As safety net providers are increasingly harmed by this manufacturer activity, the chances will increase that bipartisan legislation is introduced and potentially passed that would shore up and better define HRSA’s enforcement authority over the 340B Program.
The sun-setting of the inpatient only list will drive HOPD surgeries.
The sunset of the inpatient only list is poised to expand the number and types of surgeries that can be performed on an outpatient basis. As hospitals seek to make-up for lost revenues, it is expected that more and more surgeries will be performed in the outpatient setting, especially for the nearly 300 orthopedic surgeries removed from the list this year. Hospitals will seek to jump on this windfall to lure more orthopedic surgeons to perform surgeries in the HOPD setting, rather than the ASC, stifling the 9% expected growth rate in ASCs.
There will be a re-evaluation of the use of post-acute care venues.
While many skilled nursing facilities, inpatient rehabilitation facilities and long-term acute care hospitals closed to or limited admissions throughout the public health emergency, the need for these valuable services within the continuum was further highlighted. A number of flexibilities were aimed at the ability to increase the use of these venues to ease the regulatory constraints, and it is predicted that these venues will serve as a platform for future change.
The regulatory environment will take a front seat.
The last four years have brought impactful changes to the 340B Drug program, Conditions of Participation (CoPs), Price Transparency, Medicaid Section 1115 waivers, and other regulatory driven policy directives for providers. With a changing of the guard, providers should be keenly following the direction of HHS/CMS under the Biden administration. While the pandemic will be the immediate focus, the second half of 2021 and how the administration treats policies implemented over the last four (4) years will set the tone for the provider’s relationship with this administration moving forward.
Behavioral and mental health services will demand increased attention.
As the effects of a pandemic and extended isolation continue to manifest, behavioral and mental health providers will continue to become increasingly stretched. Health care providers will be required to expand mental health offerings in innovative ways, such as through telehealth and other digital health offerings. Meanwhile, insurers will be pressured to expand coverage of behavioral health services. Expect to also see a surge in mental health applications designed to mitigate specific mental health issues like anxiety, depression, stress, and sleep disturbances.
Lyndean Lenhoff Brick, J.D., is Founder, President and CEO of Advis, a modern healthcare consultancy at the forefront of American Healthcare. Lyndean specializes in innovative revenue enhancement and savings protocols at the intersection of regulation, compliance and provider operations.
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