From Dr. Tom's Desk
Last week’s newsletter generated an enormous backlash, but after re-reading the judge’s opinion I stand by my analysis that her recent order vacating CMS’ 2014 Overpayment Rule opens the door to a risk-coding free-for-all.
As long as you don’t commit fraud, your chances of experiencing any significant claw back in your risk-coding is essentially nil.
I recommended that you be aggressive in your coding; don’t commit fraud but feel free to go right up to the line as far as what’s ethical. Above all, don’t be intimidated or anxious about the process. The judge outlined in her decision what it’s going to take to create another overpayment rule that would be enforceable. In her footnotes she even suggests a compliant rule will be difficult to create if CMS insists on retaining the risk-coding system---which is the at the heart of Medicare Advantage.
Now is your time to grab a share of the revenue coming out of the Medicare Advantage so you can insulate yourself against the future payment cuts that simply must come. No one else is talking about this let alone publishing this analysis on the internet, but I guarantee that they have all come to the same conclusion. The insurers, the large organizations---it’s open season on risk-coding---and most don’t see a need to partner with their providers.
With or without their provider’s help, they’re going to grab the gold ring.
Me? I started as a little guy, a simple family doctor who used an innovative contract to climb to the top at a time when the current tailwinds were actually directed against my success. I’m only about helping other doctors and the organizations willing to partner with them do the same, so they can serve their patients well.
That’s why here is the only place you’ll read this perspective.
Unless you’re willing to pay the big consulting bucks---there’s no one else looking out for you.