Throughout the history of our company, many of our executives have invested their time, money and energy into an organization called the National Association of Rehab Agencies and Providers (NARA). NARA is a collection of therapy providers that are committed to advocating on behalf of our profession and sharing best practices to advance the cause of rehabilitation providers throughout the country. I have had the privilege of serving as the Vice President of NARA for the last few years and recently participated in NARA’s annual conference in Washington DC. Here is a summary of what I heard at NARA regarding the key things influencing rehab services both now and in the future:
1. More evidence of healthcare shifting to providing easier and lower cost access to care.
As payers merge with providers, as community access becomes a priority, and technology giants like Microsoft, Google and Amazon enter our healthcare marketplace, we need to be prepared for the impact this will have on healthcare. For example, CVS and Aetna have teamed up together to present a unique opportunity to redefine access to high quality care at a lower cost to the community. United Health and DaVita have gotten together to look at how they can improve patient satisfaction through integrating care delivery systems, but also, using information technology to support the services they provide. Walmart is in talks to buy Humana, while Kindred Healthcare shareholders just approved a sale to Humana. These examples show that care in the home as well as convenient community-based locations (i.e CVS, Walmart) is becoming a vital element in improving the health of seniors, especially those living with chronic conditions. The market is moving towards enabling them to receive services in the comfort of their own home or convenient community-based locations while spending less time in what we know are more costly institutional settings. Technology will play a larger role in both service delivery and integrated care.
2. Therapy associations have successfully influenced policy changes at the highest level by working together.
NARA, ASHA, APTA, AOTA, ACA, NASCL, AMPRPA have all been working together to impact critical legislation effecting rehab providers (i.e. repeal of the Part B therapy caps). The associations have realized that together, we can have more impact. We have developed joint task forces that continue to work on upcoming issues affecting our profession. We're all working on responses to proposed rules, as well as proactive communication to generate alternative proposals. I believe our collaboration and coordination also impacted the addition of reporting therapy minutes in the new proposed Patient Driven Payment Model, which is a big improvement from RCS-1 that was proposed last year. We continue to work on being ready for potential outcome reporting under MIPS with probable inclusion of non-physician providers. We're also focused on seeing if under this administration (which is clearly interested in decreasing regulatory burden) we can focus our advocacy on some of those regulations impacting our industry. On a somewhat related topic, I learned while in D.C. that our legislators are very, very interested in decreasing the use of opioids. We as providers of physical, occupational, and speech therapy, can really present some effective non-pharmacological alternatives to managing patient’s pain. In summary, we have a tremendous opportunity with this combined voice to have some significant impact in the next few years.
3. Change across the post-acute continuum is coming, and coming quickly.
There are some changes in proposed rules for both skilled nursing facilities and inpatient rehab facilities that will move the needle significantly and continue driving us towards a payment system that rewards value over volume. This includes the CARE Tool item set and Section GG items which are a means to create a common language for patient outcomes across care settings. If this is all implemented as proposed, items will soon be present in what's called the IRF PAI (inpatient rehab assessment tool); the OASIS (home health assessment tool); and the MDS (Skilled nursing assessment tool), which will allow the ability to compare outcomes across that continuum. These changes are initial steps towards a site-neutral payment system.
We as providers are quickly moving from a “more is better” model to a “show your value” model. For example, the new Patient Driven Payment Model (PDPM) will pay our skilled nursing facilities based on patient characteristics and not the volume of care provided. Case mix indexing will still play a role, but there are several different components that will contribute to the reimbursement that will ultimately determine the patient's daily rate. The payment is also proposed to decrease over the patient’s length of stay. That will motivate providers to get people to that less expensive level of care sooner. But as providers, we have to be careful how we respond to these changes. We had a senior council from the Office of the Inspector General speak to us at NARA and she really cautioned providers that while payment may not be focused in the future on the amount of therapy provided, they're really not expecting to see practice patterns change dramatically.
In summary, the healthcare landscape is changing. Whether it is because of newly blended companies disrupting the market, or changes in public policy, or newly proposed payment models, we all need to keep an eye on what is coming. At Therapy Specialists, because of our involvement with NARA, we're armed with strategies that will help our patients and business partners be successful in this new environment. We are thankful for the opportunity to be a part of NARA and for their legislative impact on proposed policies in Washington DC that benefit the rehab profession.