CMS Whispers

CMS is whispering. Can you hear it?

Traditionally, CMS releases proposed rules in the summer months. Thousands and thousands of pages of proposed regulations, changes to methodologies, and new payment codes have been or will be published over an eight-to-ten-week period. The sheer volume of documentation is overwhelming, and understandably, most of us rely on industry roundups and summaries to get a glimpse of what’s on the horizon for 2023.

And that shortcut may provide significant insight into why we are where we are in healthcare.

In our industry, it’s not uncommon to have a low-grade sense that CMS is a little unmoored. That they are changing course with every new program or program revision, or worst, that they are completely course-less with no thought to the turbulence that might ensue from their decisions. The initiatives CMS brings forward can seem disconnected from each other and from the realities of caring for an aging population. This can lead to the feeling that “winning” at Medicare requires you to game the system.

That’s when consultants are brought in to advise on how to stay ahead of regulations and rulemaking. Technology vendors develop software to improve efficiency in playing the game. Health systems and clinics invest millions of dollars of human capital into playing to win, even though they sometimes believe that this may be near impossible, because the house always wins.

What all of this misses, though, is that this isn’t a game. It’s a journey. And CMS is telling us exactly where we are headed, and what we need to do to get there.

But CMS is speaking in whispers. These whispers are buried in line after line of text, and layer after layer of complexity. CMS is murmuring to health systems where they should direct their efforts and how to optimize reimbursement. The exact coordinates where high-value care, improved patient outcomes and quality of life, and provider reimbursement meet is echoed throughout CMS policy and rulemaking. But few seem to hear it because there’s just too much noise.

What would it look like if, instead of trying to win a game that CMS isn’t even playing, you sought to amplify the whispers?

Maybe it would mean instead of scanning recaps or summaries of major provisions in proposed rules, you pursued nuanced conversations about what CMS is saying in the minor details and understood how proposed changes reflect the overall course that CMS is charting.

Maybe it would mean instead of scrambling for a technology solution that provides a workaround for a provision that seems to be more inconvenience than anything else, you understood the implications of addressing the provision instead of working around it.

Maybe it would mean instead of having your staff chase the “winning cards” in documentation, coding, or reimbursement, you invest in building programs that drive high-value care and reimbursement by doing what’s best for patients.

Whatever it looks like, one thing’s for sure: you can’t listen to the noise and listen to the whispers at the same time.  

If you’re having trouble hearing the whispers, connect with us for a free consultation.                                        

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Dr. Stephen Strange and Puzzles vs. Mysteries