— by Susan McBain, Orcas Issues reporter —
October is just over a week old, but the Orcas Island Health Care District has already held two special meetings. The first focused on budgets—both the District’s and that of Orcas Family Health Center (OFHC)—and the second was devoted to a presentation by consultant Shar Sheaffer, CPA, of public accounting firm DZA, on how different federal designations might increase reimbursements to the clinics.
At their Oct. 2 meeting, the commissioners considered a revised budget from OFHC requesting a subsidy of $461,512 for fiscal 2020, which began October 1. Last year’s subsidy request was just under $330,000. The main ingredient in the change is an increase in salaries and benefits, including insurance coverage, for all employees to bring OFHC’s overall compensation structure closer to that of the UW Neighborhood Clinic (UWNC). Commissioner Pegi Groundwater felt that the increase, although done in the spirit of fairness, would make the overall increase in the District’s 2020 budget unsustainable. Commissioner Diane Boteler acknowledged that problem but wanted to support OFHC’s budget increase for this coming year. The commissioners voted 4–1 to approve the revised budget.
The commissioners next considered their own 2020 draft budget. The District is entitled by law to a 1% increase over the prior year’s levy plus an allowance for new construction plus any “banked capacity.” Banked capacity is the amount the District could have collected in its first year had the millage rate been set at the maximum of $0.75 per $1,000; it amounts to $230,398. (The actual millage rate in the first year was just under $0.65.) The District’s 2020 revenue from property taxes is budgeted at $1,509,057, based on the allowed 1% increase and allowance for new construction. If the District took only this amount, the resulting millage rate would be about $0.57. However, if the commissioners decide that the District needs to tap its banked capacity, the millage rate for 2020 would be approximately $0.67. The next budget draft will factor in the final approved budgets for both clinics, which will help determine needed revenues for 2020.
Commissioner Patty Miller prepared a five-year cash flow analysis, which showed that after the substantial overall increase in subsidies for the two clinics this year—3% for OFHC and 5% for UWNC—the District’s bottom line becomes negative in 2022 even if future increases are more moderate. Given that projection, the commissioners face two big budget decisions at their next meeting: whether to tap their banked capacity, and whether to budget for any major changes to the structure of the Orcas health care system.
The latter decision will be substantially informed by the 18-page consultant’s report presented in the second special meeting, held Oct. 7. That report included analyses of financial and operational data from both clinics, together with information on federal designations that have the potential to increase Medicare and Medicaid reimbursement rates. The two most appropriate designations for clinics on Orcas are a Rural Health Clinic (RHC), a designation by Medicare for clinics in underserved rural areas, or a Federally Qualified Health Center (FQHC), a federal designation intended to provide comprehensive health services to the medically underserved, thereby reducing the patient load on emergency rooms. (OFHC is already designated an RHC.)
The report provided details on several aspects of these designations, but in the end the consultant, Ms. Sheaffer, felt that FQHC Look Alike status would be best for the situation on Orcas. Although the application and reporting processes are more cumbersome, she felt that the Medicare reimbursement rate is likely to be higher. Also, an FQHC designation would automatically make a clinic a “covered entity” in the federal 340B Discount Drug Program, allowing the designated clinic to purchase drugs at discounted prices for dispensing through local pharmacies. Both the clinic and the pharmacy would thus have lower costs.
The report also made two other major recommendations:
- That the two clinics consolidate into one location in order to minimize costs, and
- That UWNC move toward providing services using only one physician and two mid-level providers (physician assistants and nurse practitioners), rather than the current three physicians.
The commissioners will be contacting other FQHCs and providers in the area to gather further information before their next regular meeting. That meeting is scheduled for October 15, 5 p.m. – 7:30 p.m. at the Eastsound Fire Hall. The meeting has been extended 30 minutes to provide an introduction to two senior leaders from Premera, parent company of LifeWise, which will take over for Kaiser in January. District Superintendent Anne Presson has been working with Premera to ensure a smooth transition.
The Town Hall planned for October 5 was rescheduled to Monday, October 28, 5:30 p.m. – 7:30 p.m. in the Madrona Room at Orcas Center. The commissioners hope to hold another Town Hall in early December as well.
For readers interested in more detail about meetings, minutes of each meeting are available on the District website. Minutes of a meeting are posted soon after final approval by the commissioners, usually at their next meeting.
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In 2003, Michael Bell, CPA (now Wipfli) conducted a survey for OIMCA when they were faced with Island Hospital’s (first) departure from the Orcas clinic. That survey included actual numbers, numbers which indicated real patient encounters and levels of reimbursement from the clinic’s previous year(s) and projected reimbursement under the Rural Health Clinic designation versus non-RHC. I am not seeing numbers in the report by DZA which I found on the Health Care District website. Are these numbers available?
Thank you, Susan for your good reporting and keeping us all informed!
The health district commissioners are taking an important step evaluating health care options for the community. This article report left me with some questions, and I’ll look for clarification in the consultant’s report. It might be helpful, if Ms. Ms. Sheaffer and the health district could clarify the points below.
1. Does 340B discount drug pricing apply only to Federally Qualified Health Centers (FQHCs) or also to FQHC Look Alikes? Its a great program that benefits patients, medical practices and participating pharmacies.
2. Do both RHCs and FQHC Look Alikes qualify for Federal Tort Claims Act coverage (as do FQHCs), which eliminates the expense of professional liability (malpractice) insurance? That could offer a considerable savings compared to our current situation.
3. Is OFHC already a Federally Designated RHC or is that currently a State (of WA) designation? My understanding from the WA state Office of Rural Health is that only the state designation applies and the full federal benefits do not apply. I could be wrong here.
I am a proponent of FQHCs. I started one in Oregon and have seen the good they can do for community health. It may not be the magic answer, but its an option. One of the aspects I especially like is that 51% of the board of directors of the practice must be patients of the practice, which assures responsiveness to and advocacy for the community it serves.
In my experience its worthwhile to establish a FQHC rather than an RHC or Look Alike (“FQHC Light”). The accountability under a FQHC is more than the other two, but considerably more benefits and advantages come with the FQHC designation. Regulations may have changed, but that’s my understanding.
Finally, the Health District is a favorable position to apply as a “public entity” FQHC versus a private non-profit one. Federal funds are “earmarked” for public entity applications. The nationwide competition for perpetual funding is less intense, and it ties public funding and public accountability together. Meetings of the Board of Directors are public.
Thank you, Commissioners, for your hard work on these important matters.
Yes the consultant’s report [at orcashealth.org/wp-content/uploads/2019/10/DZA_Final-Narrative_10_06_2019.pdf ] Does not include the spreadsheets available to the Commission and discussed at the special meeting with the consultant on Monday. There were some corrections to the figures that were still being worked out that do not affect the conclusions but which are needed to make the report complete. Hopefully these will be posted soon. And hopefully they will be discussed in similar detail at the Town Hall Meeting on the 28th.
Another set of figures to look for is the comparison of patient out of pocket expenses under the several clinic structures being discussed. The numbers generated ad hoc at the meeting were incomplete but suggestive.
It is also significant that the numbers that broke the camel’s back as far as the UW clinic, was its insistence on raising its provider salaries + benefits into the quarter- $million per year range. We are still in the dark about this sizable chunk of change that will determine in large part the sustainability of healthcare on Orcas. This is a complex problem because having providers with the skills to operate independently without resorting to off-island Emergency departments will determine the practicality of after-hours care, yet their salaries conversely will determine its fiscal feasibility.
The pay structure of UW sets the bar for physician pay higher than what is sustainable, and the wage demands of OFHC cause us to consider what IS fair on this rural island, what our financial targets are when this is all settled. The reported exchange between members of the Commission, Pegi and Diane, would not be complete without the addition of Patti’s comments to this effect. This was brought home in the missing supporting spreadsheets to the Report: that in calculating the effects of various expenses one must take into account the effect of total staffing mix on cost-based compensation not to be borne by the PHD through taxation. The formula varies for each clinic structure under consideration and is the object of further research.
Hopefully this will become clearer by the next Town Hall. The matter at issue IMHO is WHAT SERVICES we require in our unique situation on a rural island with an aging populace, and WHAT MEANS to which we have access from taxes and from primarily Federal funding sources, which are in flux during our ongoing national healthcare debate. With the mix of expertise available on the Commission, we look for some insightful explication.
Two points:
First, I think most of us realized quite some time ago that co-location or merger at the OIMC has always been a requirement to rationalizing services on the island. That said, unless UW steps up its game (responsiveness/coverage) and steps down its costs, it might not be the best “anchor” tenant.
Second, Tom states: “Finally, the Health District is a favorable position to apply as a “public entity” FQHC versus a private non-profit one.” Unless I’m wrong, this envisions the Hospital District BEING the provider of services–owning the clinic, running its operations, absorbing all of its losses (there are no profits in rural health care) and on the hook for all regulatory requirements. My 40 years of experience in health law causes me to be enormously concerned about that proposition.
I’m eager to read the full report and hear from the Commissioners.
The Consultant’s report, previously mentioned details how an FQHC is governed by a 9 to 15 member independent board. The Commission has been discussing how this might work, but one idea is that some members of the PHD commission would share a chair on the FQHC advisory board.
Do the homework. The reports and regulations are publicly available and injecting uninformed speculation when the facts are so easy to come by is a disservice. Running an FQHC under the auspices of the PHD is not the same as having the commissioners managing a clinic. Having missed the discussions of the last few meetings on this topic [the minutes are online], I suggest coming to the next meeting with your questions or attend the next Town Hall. But really…