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July 2011 Edition of the Washington Healthcare News



VOLUME 6, ISSUE 7                                                                                              JULY 2011

ACOs: Will There be Savings to be Shared?
By Stephen Rose                        in the past, the premise of ACOs       join the mad scramble to compre-
Health Care Attorney and Owner         is that they will improve the health   hend the requirements and prepare
Garvey Schubert Barer
                                       of the population; enhance the pa-     to meet the quality and savings
                                       tient experience of care (including    requirements or be faced with the
                                       quality, access, and reliability);     very real possibility of not having
                                       and reduce, or at least control, the   a seat in this regulatory game of
                                       per capita cost of care.2 The “sav-    musical chairs.
                                       ings” created by ACOs participat-
                                       ing in the Medicare Shared Sav-        Providers Begin to Express Con-
                                       ings Program will then be “shared”     cerns
                                       between the federal government
                                       and the ACO. The Shared Sav-           More recently, health care pro-
                                       ings Program is only one of sev-       viders and provider organiza-
                                       eral programs envisioned by the        tions have started the process of
                                       Affordable Care Act (“PPACA”):         Please see> ACOs, P4

                                          The Affordable Care Act
                                          includes a number of provi-
                                                                                 Inside This Issue
After months of anticipation and          sions designed to improve           ACOs: Will There be Savings
                                          the quality of Medicare ser-        to be Shared?
speculation the Centers for Medi-
care and Medicaid Services issued         vices, support innovation           Healthcare Facilities:
                                          and the establishment of            Providence Regional Medical
proposed rules relating to a volun-                                                                                  8
                                                                              Center Everett Opens $460
tary Shared Savings Program for           new payment models in the
                                                                              Million State-of-the-Art Tower
Medicare providers and suppliers          program, better align Medi-
participating in Accountable Care         care payments with provider         Healthcare Administration:
                                          costs, strengthen program           Accountable Care
Organizations (ACOs).1 Under                                                  Organizations: The Future
the Shared Savings Program, pro-          integrity within Medicare,          of Quality Healthcare?
viders and suppliers will continue        and put Medicare on a firmer
                                          financial footing.3                 Healthcare Law: Legal
to receive traditional Medicare                                               Challenges to Medicaid Rate
fee-for-service payments under                                                                                      12
                                                                              Reductions Frustrated by
Parts A and B, and be eligible for     Immediately after the publica-         Proposed Federal Rules
additional payments if specified       tion of the proposed regulations
                                       various commentators warned that       Career Opportunities                  15
quality and savings requirements
are met.                               those who wanted to participate        Plan and Hospital Financial
                                       and meet the ACO implementation        Information Available at
As with other healthcare initiatives   date of January 2012 had better
                                                                  Letter from the Publisher and Editor
          Publisher and Editor
                 David Peel                                                      Dear Reader,
           Managing Director                                                     The volume of online job postings can indicate the
              Elizabeth Peel                                                     strength of the economy. However, it can also be
           Contributing Editor                                                   misleading.
                 Nora Haile
                                                                                I review The Conference Board’s Help Wanted
                                                                                Online (HWOL)™ report each month to see how
              Jennifer Sharp
                                                                                postings are trending. The number of postings on
            Business Address
              631 8th Avenue
                                                                                Healthcare News web sites are at all-time highs so
           Kirkland, WA 98033
                                                                                it didn’t surprise when HWOL reported online post-
          Contact Information
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          Phone: 425-577-1334
                                                                                to April 2011. The hottest categories have fewer un-
          Fax:     425-242-0452
                                                                                employed persons than online ads. Computer and
     E-mail:                        math science (.23) and healthcare practitioners and technical (.37) categories
          Web:                            have the highest demand when comparing unemployed persons to online ads.
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tribution, go to our web site at wahcnews.
com, click on the “subscribe” tab at the top
                                                       partment of Labor has been reporting initial claims for unemployment insur-
of the page and enter all information re-              ance above 400,000 for the past few months.
quested. Be sure to let us know whether
you want the hard copy or the web version.
                                                       For the foreseeable future, there will be high demand in some industries while
LETTERS TO THE EDITOR                                  others languish. Expect healthcare workers to continue to be in short supply
If you have questions or suggestions re-               so make sure your recruiting budgets are adequately funded.
garding the News and its contents, please
reply to                           David Peel, Publisher and Editor

                          Washington Healthcare News 2011 Editorial Calendar

   Month and Year                              Theme of Edition                Space Reservation              Distribution Date

     January 2011                                  Hospitals                   December 1, 2010              December 27, 2010

    February 2011                                   ASCs                        January 4, 2011               January 24, 2011

      March 2011                                   Hospitals                    February 1, 2011             February 21, 2011

       April 2011                                  Insurance                     March 1, 2011                 March 21, 2011

        May 2011                                    Clinics                       April 1, 2011                 April 18, 2011

       June 2011                           Human Resources                         May 2, 2011                  May 23, 2011

        July 2011                                  Hospitals                      June 1, 2011                  June 20, 2011

     August 2011                                   Hospitals                      July 5, 2011                  July 18, 2011

   September 2011                                   Clinics                      August 1, 2011               August 22, 2011

     October 2011                          Human Resources                     September 1, 2011            September 19, 2011

   November 2011                                   Hospitals                    October 3, 2011               October 24, 2011

   December 2011                                    Clinics                    November 1, 2011              November 21, 2011


                             HMA is committed to maximizing
                               health plan value by lowering
                            claims costs and providing superior
                                      customer service.

                             For the best of both Service and Savings,
                                        contact us today:

                                 Oregon                     Washington
                               Melody Ortiz                 Brooke Vassar
                            503.808.9287 x6213              425.289.5227


                                              Committed to Value
< ACOs, from P1                           whether applicants will be          partment of Justice are substantial
                                          able to achieve success.4           and add another disincentive to
drilling down through the regula-                                             participation.
tions. Questions are being raised      The letter from the Cleveland Clin-
regarding whether it is possible to    ic then goes on to list seven more     Other provider organizations have
increase quality of care to a larger   pages of, what the Clinic terms,       commented that the proposed
population of recipients while si-     “recommendation[s] to improve          regulations do not allow a gradual
multaneously lowering costs or at      the proposed rule.”5                   transition that would allow provid-
least lowering the growth in overall                                          ers new to care coordination ample
expenditures. Thus far there is not    The Medical Group Management           time to build the infrastructure
one “cookie-cutter” model for an       Association (“MGMA”) recently          needed to function successfully as
ACO. The nuts and bolts of what        commented that the Shared Sav-         an ACO or within an ACO. Rath-
an ACO could look like have been       ings Program detailed in the pro-      er, they state that the proposed
well chronicled by others and will     posed regulations “. . . may not be    regulations demand that all ACO
not be reiterated here. Without en-    viable as a national strategy unless   “participants quickly move to
dorsing or criticizing the positions   significant program policies are       taking on downside risk.”7 CMS
taken, this article focuses on some    modified when final rules are pro-     acknowledges that requiring all
of the concerns raised by providers    mulgated.6 As an overall observa-      ACOs to take this risk “. . . would
and provider organizations.            tion MGMA notes that the ACO           likely inhibit the participation of
                                       model is a hybrid business model       some interested entities.”8 How-
As a general statement, it appears     somewhere between the traditional      ever, CMS believes that requir-
that most health care providers        fee for service model and a capi-      ing participating ACOs to take on
support the concept and goals of       tation or similar “all-risk” model.    downside risk quickly is best for
ACOs but believe that the pro-         MGMA comments that ACOs pur-           the program because “. . . payment
posed regulations impose signifi-      port to provide the best of both       models where ACOs bear a degree
cant impediments to successfully       ends of the spectrum: cost control     of financial risk have the potential
participating in a Shared Savings      and cost certainty from the gov-       to induce more meaningful system-
Program.                               ernment’s perspective as a payer       atic change in providers’ and sup-
                                       and patient and provider freedom       pliers’ behavior.”9 The debate here
For example, the Cleveland Clinic      of choice. MGMA wonders out            is not whether ACOs should take
expressed its disappointment with      loud whether Medicare (and each        on downside risk but how soon in
the proposed rules, stating that:      of its stakeholders) can “have its     their lifecycle that risk should be
                                       cake and eat it too” using the ACO     borne. Many providers believe
   Rather than providing a             model.                                 that if ACOs take on too much risk
   broad framework that focus-                                                too soon the ACO may be forced
   es on results as the key crite-     Four specific areas of concern         out of business.
   ria of success, the Proposed        raised by MGMA are: (1) The
   Rule is replete with (1) pre-       complexity of the ACO program          Complaints have been registered
   scriptive requirements that         creates a bias against participa-      regarding how CMS will calcu-
   have little or nothing to do        tion; (2) The cost of ACO devel-       late the expenditure benchmark
   with outcomes, and (2) many         opment and ongoing operations          for ACOs. The benchmark will
   detailed governance and re-         are too high relative to the po-       be unique to each ACO. CMS
   porting requirements that           tential financial benefits; (3) The    will base the benchmark on esti-
   create significant adminis-         potential financial benefits are       mated Part A and B expenditures
   trative burdens.      Further,      too small and too uncertain; and       for ACO beneficiaries. Some pro-
   we have concluded that the          (4) The regulatory risks under the     vider groups have argued that a
   shared savings component            related joint notices concerning       better approach would use blended
   (Shared Savings) is struc-          ACOs issued by CMS, the Office         regional and national expenditures
   tured in such a way that cre-       of Inspector General, the Federal
   ates real uncertainty about         Trade Commission, and the De-          Please see> ACOs, P6
Chris Apgar, CISSP

Phone: 503-977-9432
Fax: 503-245-2626
Mobile: 503-816-8555
E-mail:        Quality Compliance Resources
                               Apgar & Associates, LLC offers the highest quality service assisting health-
                               care organizations establish sound privacy and security programs, meet
                               regulatory requirements, address legal and regulatory issues and assist in
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Portland, OR 97219             vices offered.
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< ACOs, from P4

to create a benchmark.


As with any potential decision,
health care providers must assess
the pros and cons associated with
joining or creating an ACO or re-
fusing to do so. ACOs have been
heavily promoted as a panacea for
control of health care spending
while increasing health outcomes;
a world view that is yet to be prov-
en. However, some of the criti-
cism may be equally flawed.

A decision whether to participate
in the Shared Savings Program and
the provider’s selection of an ACO
to join, are weighty decisions that
require a careful consideration
with a full appreciation of both the
costs and the benefits evaluated in
the context of your specific situa-
                                                     Time to bring in outside help?
Stephen Rose has more than 25                        The Consultant Marketplace,
years representing healthcare pro-                   located on the Washington
                                                     Healthcare News web site, is
viders in matters relating to Medi-                  where over 50 companies that
care/Medicaid reimbursements,                        specialize in providing services
government audits, and corpo-                        or products to healthcare
rate compliance plans. He can be                     organizations are found.
reached at or                       To learn more, visit

  76 Fed. Reg. 19528-19654 (April 7, 2011).
  Id. at 19531.
  Id. at 19530.
  Letter from Delos M. Cosgrove, President
and CEO, Cleveland Clinic to Donald Ber-
wick, M.D., Administrator, CMS (May 26,
2011) (
  Letter from William F. Jessee, M.D. for
MGMA to Donald Berwick, M.D., Admin-
istrator, CMS (June 1, 2011) (http://www.
  76 Fed. Reg. at p. 19618 (April 7, 2011).

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Healthcare Facilities                                                 Washington Healthcare News | July 2011 |

Providence Regional Medical Center Everett
Opens $460 Million State-of-the-Art Tower
By David Brooks                       comprehensive building project in       to provide first-class health care in
Chief Executive Officer               our hospital’s 150-year history.        our growing community.
Providence Regional Medical
Center Everett                        The 12-story Marshall and Kather-       The new tower was designed
Providence Regional Medical           ine Cymbaluk Medical Tower, one         around Providence’s patient-and
Center in Everett will take its       of the largest private investment       family-centered care philosophy,
award-winning healthcare to the       projects ever in Snohomish Coun-        with comfort, privacy and con-
next level June 14 when it opens a    ty, is the centerpiece of a compre-     venience in mind. By combining
new $460 million, state-of-the-art    hensive plan to ensure Providence       cutting-edge technology with pa-
medical tower, the largest and most   Regional remains well equipped          tient-centric care, Providence aims

                   Providence Regional Medical Center Everett’s
             12-Story Marshall and Katherine Cymbaluk Medical Tower
                                                                                                                 Volume 6, Issue 7
to set a new standard for the way      members to stay with them.                       features family lounges with inter-
patients and their families experi-                                                     net access, and the surgery waiting
                                       Of equal importance, the tower is
ence hospital care in America.                                                          areas provide a kitchen, playroom
                                       designed to be a calming, healing
The facility, which houses many                                                         and resource center for all.
                                       environment for patients, family
Providence services, features $60      members and visitors alike. The                  The doctors, nurses and other
million in the latest medical equip-   building brings nature and the                   caregivers at our new tower will
ment and is designed to adapt to       outdoors inside, with features that              provide the industry-leading care
technology as it evolves in the fu-    include a two-story atrium lobby,                Providence is known for – but
ture. It dedicates an entire floor -   patient rooms with sweeping views                we expect our warm, welcoming
larger than an NFL football field      on all sides of the building and a               approach to serving patients and
- to emergency services, which in-     rooftop viewing garden with native               their families is what will truly set
cludes 79 private treatment rooms      plants, grasses and trees. It also               us apart.
including four trauma rooms. CT
and X-ray services are also located
within the department to provide
quick access to imaging capabili-
More than $20 million in diagnos-
tic imaging equipment, including
two MRI scanning machines and
four CT scanners, are housed on
the diagnostic imaging floor. The
department has a unique design
that will accommodate both inpa-
tient and outpatient imaging needs.
Electronic medical records allow
doctors and staff from multiple or-
ganizations to share information in
real time, which speeds diagnosis                Legal strategies for the
and treatment.                                healthcare challenges ahead.
Two floors of the tower are dedi-
cated to both surgical and interven-
tional procedures and two floors            Your healthcare business is operating in an increasingly complex
                                            environment. Miller Nash’s team of healthcare attorneys has the
will house 48 patient rooms dedi-
                                            knowledge and depth of experience to successfully address the
cated to intensive care, which in-          unprecedented challenges and expanding responsibilities you face.
clude six dialysis stations. Each of
the top three floors has 56 patient         Please contact Bob Walerius |
rooms for medical or post-surgical
                                              Regulatory Compliance | Board Governance | Medical Staff | Fair Hearings
                                            Mergers & Joint Ventures | Physician Recruitment & Contracting | HIPAA Privacy Laws
We worked closely with our Pa-              Health Information Technology | Physician Credentialing | Stark/Fraud & Abuse
                                                  Litigation & Dispute Resolution Business Formation & Transactions
tient and Family Advisory Coun-                                   Labor and Employment | Real Estate
cil when designing the tower and,
as a result, incorporated several
elements not typically found at a                                                washington

hospital. For example, most rooms                                             vancouver

have a special ‘family zone’ area,                                              portland
                                                                                                     TEL 206.622.8484
complete with a sleeper sofa and
                                                                         central oregon
storage area for patients’ family

Healthcare Administration                                              Washington Healthcare News | July 2011 |

Accountable Care Organizations: The Future
of Quality Healthcare?
By Loy Maslen                           and process improvement) for an         causing quality and outcomes to
RN, BSN, NNP-BC, CPUM Associate         assigned population of people; i.e.     suffer. To combat these issues, a
Quality Improvement and Education
Consultant                              Medicare patients.                      recognized ACO will need to meet
Derry Nolan & Associates, LLC                                                   indicators and data derived from
                                        The Center for Medicare and Med-        five key areas:
                                        icaid Services (CMS) is asking
                                        healthcare providers to be account-     1. Patient and providers’ experi-
                                        able to the care provided. That in-        ence of care (patient and staff
                                        cludes administration, governance,         satisfaction scores)
                                        and implementation either within
                                        the scope of our roles or in our        2. Care coordination (informa-
                                        employment positions. It also en-          tion sharing across the contin-
                                        compasses the obligation to report,        uum of care)
                                        explain and be answerable for any
                                        resulting consequences.                 3. Patient safety (reporting, anal-
                                                                                   ysis and error prevention)
                                        Initiated by the goals of the Af-
                                        fordable Care Act to improve care       4. Preventive health (treatments
                                        while lowering its cost, ACOs              to minimize illness and hospi-
                                        will help make quality a habit             tal admissions)
                                        in healthcare. Those ACOs that
                                        meet required quality performance       5. At risk population, frail and el-
Healthcare reform is about ac-          standards have the potential to re-        derly health (using proven care
countability for care. As a nurse,      ceive payments from the Medicare           standards to assist with care
should someone ask me if I pro-         Shared Savings Program, which              provision)
vide quality care, I would answer,      “promotes accountability for a pa-
“Absolutely.” But if they ask me,       tient population, coordinates items     The overall quality performance
“What is your data to support that      and services under Parts A and B,       score will be calculated on 65
claim of quality care?” Then I may      and encourages investment in in-        quality metrics within those five
need to say, “I’ll be right back with   frastructure and redesigned care        defined key areas, equally weight-
you on that.”                           processes for high quality and ef-      ed. CMS will define the quality
                                        ficient service delivery.”1             performance benchmarks based on
That’s where the ACO comes in.                                                  Medicare Fee-For-Service (FFS),
ACOs are a type of payment and          From an operational perspective,        Medicare Advantage or ACO per-
delivery reform model that begins       as well as from a clinical one, the     formance data over time.
to tie provider reimbursements to       ACO model makes sense. Today’s
quality metrics (measures of qual-      healthcare organizations are often      Note that the ACO is eligible for
ity indicators) and reductions in       fraught with inefficient workflows      monetary compensation only if it
the total cost of care (performance     and faulty communication habits,        demonstrates to CMS that it has
                                                                                                                  Volume 6, Issue 7

fulfilled the required quality per-                and quality outcomes.                    of costly wastes.
formance elements and achieves
the other regulatory performance                   Communication should be a simple         Consider this: the products of
criteria. Mature organizations ex-                 concept, particularly in healthcare.     healthcare systems are services.
ist that already meet the measures                 Patients talk to doctors, nurses         Therefore, measuring healthcare
required. Those organizations not                  and other staff members. Health-         quality must extend beyond clini-
only meet the clinical measures,                   care providers talk to each other.       cal measures. Organizations must
but are also likely made up of high                Unfortunately, the barriers that         also measure patient perceptions
performance teams.                                 frequently block understandable          and experiences. So, although ser-
                                                   exchanges create gaps. Those gaps        vice quality is usually measured by
Creating       High        Performance             in quality communication limit           five dimensions:
Teams                                              quality service to patients and staff
                                                   alike. The natural progression? Pa-      1. Tangibles
Healthcare is complex, so ap-                      tient and staff dissatisfaction and
                                                                                            2. Reliability
proaching issues as a cohesive                     frustration.
group working together to achieve                                                           3. Responsiveness
a goal allows for creativity, sharing              Failure to address these commu-
expertise, developing new skills,                  nication issues in healthcare leads      4. Assurance
increasing personal autonomy and                   to inefficiency, ineffective and po-
influencing decisions. Such teams                  tentially unsafe care, rework, a di-     5. Empathy
can only come together through                     minished capacity for team perfor-
eliminating barriers encountered in                mance and unintended outcomes.           We will add two more:
everyday communications. Com-                      Simply improving and standard-           6. Accessibility
munication excellence is the key                   izing parts of our communication
to unlocking team performance                      strategies can eliminate these types     Please see> Quality, P14


   OUR BREADTH OF EXPERIENCE keeps our clients focused on their
   mission—providing quality care to their patients. Serving health care clients for
   over 75 years, we provide sound and practical advice to health care professionals,
   clinics, and institutions in such areas as labor and employment, risk management,
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Healthcare Law                                                         Washington Healthcare News | July 2011 |

Legal Challenges to Medicaid Rate Reductions
Frustrated by Proposed Federal Rules
By Renee M. Howard                     “Section 30(A)” of the Medicaid          Belshe, 103 F.3d 1491, 1497 (9th
Shareholder                            Act, requires state Medicaid Plans       Cir. 1997).3 Based on this require-
Bennett Bigelow & Leedom, P.S.
                                       to utilize “methods and proce-           ment, many health care provid-
                                       dures” that “assure that payments        ers have successfully challenged
                                       are consistent with efficiency,          budget-driven Medicaid rate re-
                                       economy, and quality of care and         ductions on the basis that the state
                                       are sufficient to enlist enough pro-     did not conduct a responsible cost
                                       viders so that care and services are     study prior to developing a new
                                       available under the plan at least to     rate (or that the study itself was
                                       the same extent that such care and       inadequate), and that the provid-
                                       service are available to the gen-        ers would be financially harmed if
                                       eral population in the geographic        such rate went into effect.
                                       area.”2 These payment-related
                                       requirements are known as the            The proposed rules would sub-
                                       “quality” and “access” standards.        stantially alter this legal standard.
                                                                                Rather than require cost studies,
                                       In recent years, various types of        the rules would allow states to con-
                                       providers have brought success-          duct a more flexible access analy-
                                       ful legal challenges to Medicaid         sis that examines three factors: (1)
                                       rate cuts that do not comply with        enrollee needs; (2) availability of
Providers who participate in Med-      Section 30(A) quality and ac-            care and providers; and (3) utili-
icaid should familiarize them-         cess requirements. While provid-         zation of services. Clarifying that
selves with proposed federal regu-     ers cannot get money damages in          the relationship of rates to provider
lations published on May 6, 2011       these lawsuits, they have been able      costs is no longer the primary fo-
that, if adopted, would substantial-   to block state Medicaid programs         cus of an “access” analysis, CMS
ly impede their ability to challenge   from implementing rate cuts that         noted: “Depending on State cir-
Medicaid rate reductions in court.     violate Section 30(A).                   cumstances, cost-based studies
Interested parties may submit com-                                              may not always be informative
ments to the proposed rules, which     Since 1997, federal courts in            or necessary. In addition, because
must be received by the Centers        Washington and elsewhere in the          many State payment rates are not
for Medicare and Medicaid Ser-         Ninth Circuit have required states,      specifically calculated based on
vices (“CMS”) no later than 5 pm       in order to comply with Section          provider cost considerations, it can
EST on July 5, 2011.1                  30(A), to conduct “responsible           be burdensome and not particu-
                                       cost studies” to ensure Medicaid         larly productive to rely solely on
The proposed rules interpret a fed-    rates will be “reasonably related”       that one factor as a measure of ac-
eral Medicaid law that limits how      to provider costs, and to conduct        cess.”4 Going a step further, CMS
state Medicaid programs can set        such cost studies prior to setting       suggests that a Medicaid rate can
payment rates. That law, known as      the new rates. Orthopedic Hosp. v.       satisfy Section 30(A) requirements

                                                                                                       Volume 6, Issue 7

irrespective of the payment level:        the proposed rules and consider         has represented health care clients
“If beneficiaries are able to gain        submitting comments to ensure           in litigation and government in-
access to care . . . . then clearly the   that the final rules provide mean-      vestigations implicating the fed-
standards of the Act have been met        ingful protections against budget-      eral False Claims Act, the federal
regardless of other factors, includ-      driven rate cuts.                       Anti-Kickback Statute and physi-
ing payment levels.”5                                                             cian self-referral (“Stark”) laws,
                                          Renee is experienced in represent-      state Medicaid issues, and health
The singular focus on “access” to         ing a wide range of health care         care licensing matters. Renee also
Medicaid services is problematic          providers and suppliers, includ-        assists clients with internal inves-
for providers such as hospitals,          ing hospitals and health systems,       tigations of allegations of fraud or
which must provide some measure           academic medical centers, physi-        other noncompliance with state or
of treatment to all who come to           cians, imaging centers, and medi-       federal health care laws, and re-
the emergency department regard-          cal suppliers and distributors. She     Please see> Medicaid, P14
less of insurance status or payment
rates. Indeed, the framework in
the proposed rules was developed
based on a study that focused on
primary and specialty care provid-          Health Insurance
ers and services, and did not spe-
cifically address hospital, ancil-          Options and Advice from the
lary, and long-term care services.6
The rules also do not address Sec-          Local Experts at EmSpring.
tion 30(A)’s second requirement
that states must ensure “that pay-
ments are consistent with efficien-
cy, economy, and quality of care,”
in addition to ensuring access to           No worries:
services.                                   We know how they all fit.
Finally, the proposed rules would
make it difficult for providers to es-
tablish that a state failed to satisfy
Section 30(A) access requirements,
as the rules give CMS discretion to
deny a State Plan Amendment only
where a state fails to conduct an
access analysis altogether and not
where the access review is method-                                                  KIRKlAnD .......(425) 818-0726
ologically unsound or reveals defi-                                                 218 Main Street
ciencies.7 For example, if a state’s
                                                                                    YAKImA .......... (509) 575-6497
access review identifies access is-                                                 3911 Castlevale Rd, Suite 2109
sues, instead of denying the State
                                                                                    SPoKAnE ....... (877) 550-0088
Plan Amendment, the proposed                                                        601 Main Street
rules permit the state to submit a
corrective action plan, and take up                                                 WWW.EmSPRIng.Com
to twelve months to remediate the
deficiency.                                 Health Reimbursement Arrangements (HRA) | Health Savings Accounts (HSA)

Given these issues, Medicaid pro-
                                             Dan Fisher | Sue Ferrari | Kathy Rheaume | Carol Wagar, CPA | Ed Haines
viders should critically examine

< Medicaid, from P13                  and other health care compliance               Maxwell-Jolly, 572 F.3d 644 (9th Cir. 2009).
                                                                                       76 Fed. Reg. at 26344.
                                      matters. She can be reached at                 5
                                                                                       Id. at 26350.
sponding to Medicare, Medicaid                            6
                                                                                       Medicaid and CHIP Payment and Access
and third party payor audits. Renee                                                  Commission (MACPAC), Report to Congress
regularly advises clients on Medi-    1
                                       The proposed rules are available at http://
                                                                                     on Medicaid and CHIP (March 2011), Ch.
                                                                                     4, p,126, available at http://www.macpac.
care and Medicaid reimbursement
and payment issues, structuring fi-   pdf/2011-10681.pdf (76 Fed. Reg. 26342
                                      (May 6, 2011)).
nancial relationships under fraud     2
                                       42 U.S.C. § 1396a(a)(30)(A).
                                                                                       Proposed 42 C.F.R. § 447.204(b).
and abuse and self-referral laws,     3
                                       Holding reaffirmed in Indep. Living Ctr. v.

< Quality, from P11                   foundation for the high perfor-                tions to improve teamwork and
                                      mance teams that will make qual-               performance outcomes. She holds
7. Communication                      ity a habit.                                   the firm belief that an ACO begins
The high performance teams that                                                      with partnerships between pa-
grow from achieving these mea-        Loy Maslen, RN, BSN, NNP-BC,                   tient, family, providers and staff,
sures experience bonus benefits:      CPUM Associate, is a quality im-               applying standard structure and
job satisfaction and communica-       provement and education consul-                process to drive improved qual-
tion improves, mutual respect         tant with Derry, Nolan & Associ-               ity outcomes while simultaneously
grows. If your healthcare organi-     ates, bringing over 30 years of                decreasing costs and eliminating
zation can build such high perfor-    diverse healthcare experience to               waste. Maslen can be reached at
mance teams, you will naturally       inpatient and outpatient organiza-    or (425)
evolve to improved quality and        tions. A TeamSTEPPS™ Master                    774-4893.
outcomes. Your healthcare organi-     Trainer and VitalSmarts™ Crucial
zation can meet ACO performance       Conversations Master Trainer,
                                                                                     pdf/CH7349848.PDF, page 4, Section B. Stat-
criteria. But first, we must begin    Maslen helps clients learn effec-              utory Basis for the Medicare Shared Savings
to truly communicate, laying the      tive evidence-based communica-                 Program.

  Time to bring in outside help?
  The Consultant Marketplace, located on the
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                                                                                                                                                              Volume 6, Issue 7

Career Opportunities
                                                                                                                                     To advertise call 425-577–1334
                                                                                                                                     Visit to see all
                                                                                                                                             available jobs.

                  Controller                                                                                                  Healthcare Sales Executive
                 (Wenatchee, WA)
                                                           Director, Human Resources                                                             (Portland, OR)
                                                         Jefferson Healthcare, in Port Townsend, Washington, is            This position is primarily responsible for building and execut-
The Controller will provide leadership for the Finance                                                                     ing tactical and strategic sales plans for HMA’s Oregon terri-
                                                         recruiting for a Director, Human Resources.
Department and will maintain agency financial infor-                                                                       tory. The Sales Executive must demonstrate a consistent fo-
mation, prepare financial reports, maintain and bal-     Jefferson Healthcare is a full service, publicly owned, 37        cus on achieving or surpassing goals and a proven record of
ance accounting ledgers and provide direct oversight     bed, self supporting acute care hospital.                         excellence. He or She must show a passion for continuous
                                                                                                                           improvement, and demonstrate personal motivation, energy,
of the Purchasing, Accounts Payable, Cash Receipts,      The hospital has approximately 350 employees and four             creativity and adaptability while pursuing goals. The Sales Ex-
Payroll and General Ledger functions. The Controller     clinics.                                                          ecutive should inspire others through their own vigorous drive
is responsible for maintaining compliance with exter-                                                                      to achieve, motivating groups by communicating a compelling
                                                         Jefferson Healthcare has all of the standard acute care
nal stakeholders by ensuring the accuracy and timeli-                                                                      vision and translating that vision into clear, actionable goals
                                                         services plus Cardiac Rehab, Chemotherapy, Pulmonary
ness of required reporting.                              Rehab, Rehabilitation Services, Support Groups and a
                                                                                                                           and objectives. They work closely and collaboratively with Cli-
                                                                                                                           ent Services team members, and seek out and share the latest
                                                         Surgical Center.
CVCH is a dynamic community health center with                                                                             information on successful industry and business practices.
fully integrated EMR. Our services include Medical,      The Director, Human Resources supervises a staff of five          Successful Candidate will have: Experience selling products
Dental and Behavioral Health services with our main      employees.                                                        with complex funding arrangements including Administrative
clinic in Wenatchee and a site in Chelan. We serve       A Bachelor’s Degree in Human Resources is required. Five          Services Only, ASC, minimum premium, prospective, and ret-
20,000+ people in a geographically stunning part of                                                                        rospective financial arrangements is required. Familiarity with
                                                         or more years of progressive Human Resources experience
the world and are proud to be a progressive group                                                                          industry trends in health care insurance, as well as federal
                                                         in a healthcare facility as a Director or Assistant Director is
                                                                                                                           and relevant state legislative and regulatory issues. Currently
of mission-focused employees committed to serv-          also required.
                                                                                                                           licensed (in Life and Disability) and have a valid state driver’s
ing the underserved. We are leaders in the Medical                                                                         license with a good driving record and proof of auto insurance.
                                                         Labor relations experience along with PHR or SPHR is
Home Model, are Joint Commission accredited and          preferred.                                                        Demonstrates selling skills such as call planning, needs identi-
are routinely recognized as one of the highest quality                                                                     fication, overcoming objections, closing, and follow-up. Works
Community Health Centers in Washington.                  Jefferson Healthcare is very well managed in an idyllic           effectively under short deadlines. Additional requirements ap-
                                                         setting.                                                          ply.
The successful candidate will have a Bachelor’s de-                                                                        Healthcare Management Administrators (HMA) believes in
                                                         For more information please contact:
gree in Accounting with five years accounting and                                                                          delivering superior value to our many self-funded Northwest
supervisory experience. CPA preferred. Visit our         George C. Deering                                                 clients by combining competitive rates with superior service. If
website at                                 President                                                         you would like to learn more about our organization, please E-
                                                         Deering and Associates                                            mail your resume, cover letter and salary history to: recruiter@
To apply, contact Sarah Wilkinson, HR, @ 509-664-        (425) 264-0865 (Office)                                  Faxed resumes are welcome at 305/574-
3587 or                              (888) 321-6016 (Toll Free)                                        0443. Be sure to visit our website at

               Dedicated to Exceptional Medicine and Compassionate Care                                                         Chelan Clinic Administrator
                                                                                                                                                   (Chelan, WA)
                 PHMG Clinical Practice Program Manager                                                                    The Clinic Administrator will provide leadership at our
                                                                                                                           Chelan Clinic and future clinic site in East Wenatchee
 PeaceHealth’s Lower Columbia Region, in Longview, Washington, includes St. John Medical                                   to ensure effective day-to-day operations and su-
 Center, a 200-bed acute care and Level III trauma center community hospital, and PeaceHealth                              pervision of support staff. This position will work col-
 Medical Group, a multi-specialty physician practice. We are an integral part of a nationally recog-                       laboratively with CVCH managers to ensure that all
 nized not-for-profit health care system known for its innovations in patient-centered care, patient                       program goals are achieved in support of our mission
 safety, and health care technologies We currently are recruiting for a Clinical Practice Program                          to provide healthcare with compassion and respect
 Manager for our Primary Care Clinics within PeaceHealth Medical Group:                                                    for all.

 In this role, you will support our primary care clinics by managing the clinical practice program                         CVCH provides Medical, Dental, Behavioral Health,
 operations and staff performance on clinical-related policies and processes in conjunction with                           Diabetes Education and WIC services. We serve
 the Clinic Managers. Will also ensure compliance with all regulatory guidelines and facilitate the                        20,000+ people in a geographically stunning part of
 development, implementation and evaluation of clinical best practices, as well as, collaborating                          the world and are proud to be a progressive group
 with clinic leadership on ensuring consistent delivery of patient care.                                                   of mission-focused employees committed to serving
                                                                                                                           the underserved. Our center is Joint Commission
 Require a minimum of an AA degree in Nursing, strong clinic nursing experience, as well as proj-                          accredited and is routinely recognized as one of the
 ect management and process improvement experience.                                                                        highest quality Community Health Centers in the state
                                                                                                                           of Washington.
 With its ideal location just 40 miles north of Portland and a short drive from the beautiful Pacific
 Coast and several different mountain adventures, Longview is a small city with an urban flair.                            The ideal candidate will have a Master’s degree in
 Longview’s 37,000 friendly neighbors enjoy the pace and natural beauty of a family-first commu-                           Healthcare, MPH or MHA, with two years supervi-
 nity that benefits from the amenities of nearby Portland and Seattle.                                                     sory experience in healthcare. Bachelor’s Degree in
                                                                                                                           Healthcare or related field with appropriate experi-
 We offer a competitive salary range and a comprehensive benefits plan. Interested candidates                              ence will be considered.
 may apply online via our website at Resumes may be submitted in addi-
                                                                                                                           To learn more about CVCH, visit our website at www.
 tion to application, to:
                                                                                                                           To apply contact, Sarah Wilkinson, Human Resourc-
                                                                                                                           es @ 509-664-3587 or

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