Advis leaders provide their top predictions for the future of healthcare in 2022.
Staffing shortages will continue to be a top concern for healthcare operations and patient safety. The COVID-19 pandemic has taken a toll on the nation’s healthcare workforce, particularly its nurses. Healthcare leaders have been forced to act, from addressing burnout to replacing permanent staff departing for lucrative “traveler” positions. Many states have implemented targeted efforts to address nursing shortage issues. The American Nurses Association recently called upon the U.S. Department of Health and Human Services to assemble stakeholders to identify short- and long-term solutions to this pressing problem. Expect this trend to continue into 2022 and potentially beyond.
The Consolidated Appropriations Act of 2021 created a new Medicare provider type – the Rural Emergency Hospital (REH) – which will be recognized beginning on January 1, 2023. REHs will not provide inpatient care but must provide emergency services and meet the CAH Condition of Participation for emergency services. Medicare reimbursement will be based on the Medicare OPPS amount plus 5 percent. In addition, on a monthly basis Medicare will make an “additional facility payment” that approximates the savings realized by participating CAHs and other small rural hospitals that eliminate inpatient services.
With the prospect of REH Medicare participation coming closer, many CAHs and small rural hospitals (as well as their broader health systems) will devote substantial resources during 2022 to evaluate the implications of converting to the new model. In addition to determining the host of services necessary to best serve their respective communities, rural hospital providers must evaluate the reimbursement, operational and clinical impacts of pursuing REH certification. Many providers will accelerate their evaluation processes to be prepared for REH conversion as close to January 1, 2023 as possible in the event that REH designation promotes continued service to their communities as well as financial viability going forward.
In CY 2022, healthcare providers will continue to invest in at- home care models and telehealth, while increasing reliance on big data and analytics. With advancements and best practices emerging throughout the pandemic for at-home and telehealth care, Advis expects providers to integrate data analytics into at- home treatment at a greater scale. Historically, health systems have been somewhat slow to deploy data and analytics, often due to utilization of multiple, disconnected platforms. However, with investments in telehealth broadly occurring across the industry, the opportunity to change this trend is there. It follows that the Hospital at Home model will become even more prevalent, as providers continue to adjust to new patient behaviors and preferences as a result of the pandemic. Currently, there are over 180 hospitals in over 30 states approved for Medicare reimbursement under the HaH model. Expect the number of providers utilizing this model to grow.
The 340B program has entered into unprecedented levels of uncertainty and ongoing change over the past few months. Whether it’s the pending supreme court decision on the -22.5% reimbursement reduction or the manufacturer 340B contract pharmacy boycotts and ongoing hearings, covered entities have been left to the mercy of the courts. Further, the expectation that Congress will act to resolve some of the underlying 340B issues that have plagued the program over the past several years is growing. However, these issues continue to take a back seat to the current administration’s larger initiatives.
In 2022, I expect there will be answers: but no one can say what those answers will be. It is recommended that covered entities prepare for all potential scenarios to best position that covered entity to maintain compliance and optimization of its 340B universe.
Much of the HHS No Surprise Act (“NSA”) regulations go into effect January 1, 2022. This includes provision of good faith estimates to uninsured and self-pay individuals. For insured individuals, hospitals and providers are to provide a good faith estimate to the individual’s insurer or plan. Based on this information, the insurer/plan is to prepare an Advanced Explanation of Benefits (“Advanced EOB”) explaining whether the provider/facility is in- network (or not), identifying total estimated out-of-pocket patient costs, as well as additional content. Given the challenges with developing the appropriate infrastructure to transmit significant essential information between providers and plans or insurers, HHS has advised that it will delay the applicability date of the Advanced EOB requirement until sufficient data transfer standards have been identified and implemented. Advis believes this is one key area of the NSA where significant developments will occur in the coming year. In the meantime, Advis suggests hospitals and providers assess the capabilities/limitations of their current IT systems to identify potential areas where upgrades may be required.
As a result of the pandemic, the healthcare landscape of the future is forever changed. Fortunately, some good things have come out of this emergency. Innovation in AI and telehealth will continue to create at the consumers’ fingertips a contact free experience filled with information. Also, more and more providers are launching programs to address the healthcare disparities in our vulnerable communities of color and LGBTQ.
The future of healthcare may look more and more like an episode of the Jetson’s, but more importantly this wave of innovation will ultimately help make all of our bodies healthier and happier, and more affordably, too.
The growth of physician employment and practice ownership by hospitals, health systems, and other corporate entities is not a new trend, but it will continue to be a key trend in 2022. Recent studies, including one by the Physicians Advocacy Institute (PAI) have already documented a sharp uptick during the pandemic
in physician practice ownership and employment by hospitals/ health systems or “other” corporate entities such as payers and private equity. I expect to see this acquisition trend continue as organizations compete for physicians amidst a growing physician shortage and the financial challenges that the pandemic has presented for independent physician practices and practitioners. Policy changes such as revised Corporate Practice of Medicine doctrines, federal payer updates, anti-trust enforcement, and increased scrutiny/oversight of PE-backed ventures will be areas to monitor in reversing the current trends. However, I expect to see continued consolidation in 2022 given the current health care climate.