Will CMS Officials Heed Association Leaders’ Concerns on MIPS/MACRA, as We Surge Ahead Into the New Healthcare? | Mark Hagland | Healthcare Blogs Skip to content Skip to navigation

Will CMS Officials Heed Association Leaders’ Concerns on MIPS/MACRA, as We Surge Ahead Into the New Healthcare?

July 1, 2016
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Will senior CMS officials carefully consider association leaders’ major concerns on the proposed MACRA/MIPS requirements?

This week has been a week of intensified activity on the healthcare policy front. With just hours to go, numerous healthcare professional associations sent comments into senior officials at the federal Centers for Medicare & Medicaid Services (CMS), as the door was about to close for them to comment on the proposed rule related to physician payment requirements under the MACRA (Medicare Access and CHIP Reauthorization Act of 2015) legislation, which created the MIPS (Merit-based Incentive Payment System) system for physician reimbursement under Medicare.

As Assistant Editor Heather Landi and I reported in separate articles this week, numerous comments came from such associations as the Englewood, Colo.-based Medical Group Management Association (MGMA), the Philadelphia-based American Academy of Family Physicians (AAFP), the Alexandria, Va.-based American Medical Group Association (AMGA), the Chicago- and Washington, D.C.-based American Medical Association (AMA), the Bethesda, Md.-based American Medical Informatics Association (AMIA), and the Charlotte-based Premier health alliance, among others.

The recommendations of these and other healthcare professional associations are quite diverse, and touch on a very wide range of issues. Fundamentally, they revolve around issues of timing and timeframes, many specific aspects of measurement of quality and outcomes, many IT-related requirements in the program, concerns over the program’s complexity, and concerns over the impact of the MIPS/alternative payment model participation requirements on small and rural providers.

As has been well-noted, the meaningful use program for physicians is being folded into the new MACRA/MIPS program, meaning that whether practicing physicians participate in an alternative payment model (APM) or in the MIPS program, the kinds of requirements that doctors faced under meaningful use will continue, in modified forms. What’s more, most of the measurements around healthcare IT, going forward, are focused on achieving success in broad areas that CMS officials have been pushing more generally: health information exchange and data exchange, care management and population health management, and patient engagement.

If there’s a single area in which nearly all of the associations agree on, it is their strong recommendation that CMS officials delay the onset of physician requirements from January 1, 2017, as referenced in the proposed rule, to at least July 1, 2017. As association leaders have pointed out in their comments, the January 1 start date obligating physicians to collect data for the Quality Payment Program, is one that healthcare professional association leaders almost universally believe would be too difficult for physicians to adhere to.

Meanwhile, among the statements made by association executives in their comments to CMS that most stood out, are the following:

Ø  Halee Fischer-Wright, M.D., the MGMA’s president and CEO, in her letter to CMS Acting Administrator Andy Slavitt, was openly critical along numerous dimensions. Among other things, she wrote that CMS’s “narrow definition of APM [advanced payment models] provides almost no opportunities for medical groups to begin the shift away from fee-for-service reimbursement,” and further, “strongly opposes” the overly-narrow and restrictive Advanced APMs criteria proposed by CMS,” she wrote in her association’s letter, adding that, “While MACRA established a requirement that APMs bear more than nominal financial risk, CMS would establish a rigorous risk standard that requires strict repayment of losses—a criterion that excludes the vast majority of legitimate APMs, such as Track 1 MSSP ACOs and the Bundled Payments for Care Improvement models.”

Ø  Meanwhile, the AMA’s CEO James L. Madara, M.D., offered a whole laundry list of requests/recommendations for Acting Administrator Slavitt, among them, that CMS “provide more flexibility for solo physicians and small group practices, including raising the low volume threshold”; that CMS “provide physicians with more timely and actionable feedback in a more usable and clear format”; that CMS “align the different components of MIPS so that it operates as a single program rather than four separate parts, such as creating a common definition for small practices”; that CMS “simplify reporting burdens and improve chances of success by creating more opportunities for partial credit and fewer required measures within MIPS”; that the agency “reduce the thresholds for reporting on quality measures”; and that the agency “reward reporting of outcome or cross-cutting measures under a bonus point structure rather than a requirement in order to achieve the maximum quality score.”

Ø  Meanwhile, the comments from the AAFP laid it all out very simply, with the primary care physicians’ association’s key point being this: “Given the significant complexity of the rule, we strongly encourage CMS to issue an interim final rule with comment period rather than to issue a final rule.” The association also quoted the commentary of an individual family physician, who wrote, “I am a Texas physician who is extremely disappointed and disillusioned with the Centers for Medicare & Medicaid Services' draft rule… Physicians as a profession and individually are dedicated to constantly improving the quality of care we provide. But as I read it, this rule will wreak havoc with my practice while offering absolutely no evidence that it will do anything to improve patient care. Here is how you can help this problem,” that doctor wrote. “Since you won't finalize the rules until on or around Nov. 1, 2016, the Jan. 1, 2017, start date is completely unreasonable. Physicians need at least a six-month deferment to prepare our practices and processes for all the changes MACRA is demanding. Please begin the first period on July 1 and end it on Dec. 31. This deferment will be particularly critical for small practices.”

Ø  And AMIA’s core recommendations were summarized neatly in the following points. “In order to improve the current proposal and to help guide future proposals, AMIA established several principles CMS should consider related to QPP [the Quality Payment Program],” AMIA wrote, including “use data reporting requirements to learn, not simply to grade; focus on defining clear, expected outcomes, rather than prescriptive process measures; engage organizations and experts to perform scientifically rigorous, peer-review studies to determine which requirements should be retained in future years; develop feedback loops that are accurate, timely and meaningful”; and “encourage increased data exchange and interoperability whenever possible.”

These key points from those associations, as well as others, clearly reflect the broad concerns of the associations in this area. They point to some serious tweaking that senior CMS officials might consider. Perhaps the most intriguing of all of these is the AAFP’s strong suggestion that CMS officials put in place an interim final rule rather than a plain-old final rule.

There would be some real strategic and tactical risk in doing so, of course; because once one begins to tweak something, the tweaking could become endless. And let’s face it, no one is ever going to be 100-percent satisfied with the final outcome.

But these recommendations are well-thought-out, and reflect considerations that appear to be very reasonable. Above all, it seems clear to me that it is incumbent on senior officials at CMS to truly thoughtfully consider some of these suggestions and recommendations, if they want the full cooperation of physicians and other providers, and of these provider associations, going forward into this emerging world of intensified data collection and reporting around value-based care delivery and payment, with broadly intensified quality, outcomes, efficiency, and data and IT elements in so many areas.

Now, what will actually happen…? It really is anybody’s guess. We really have entered uncharted territory here. But one thing that I think is rather clear, is this: for better or worse for everyone, given the tremendous imperatives facing the U.S. healthcare delivery system to bend its own cost curve and to improve all of the outcomes around care delivery—the quality-of-care outcomes, the patient, family, and community satisfaction outcomes, and the financial and operational outcomes—we are inevitably being drawn into rather a new dynamic here. It is one in which CMS officials will necessarily need to iterate concepts forward in a more collaborative way, with physicians, hospitals, and other providers. There are now so many programs and requirements, and the pace of change and of anticipated change is such that one simply cannot imagine things working out without a huge dose of cooperation, collaboration, coming together, whatever one might want to call it.

So, perhaps more even than at other key moments in the past, this feels like a true inflection point for U.S. healthcare; because this headlong plunge into the new healthcare is one that is unprecedented in both its complexity and in the need for all the stakeholders around healthcare to be able to come together in good faith to make this all work. The next few years are going to be determinative in more ways than one. And it will be interesting to see whether the path ahead feels more like a 19th-century stagecoach ride over rutted roads, or like the smooth path of a high-speed train on shock-absorbing bumpers—or maybe some combination of the two. Stay tuned, and we’ll all find out, together.

 

 

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CMS: 93% of Clinicians Get Positive Payment Adjustments for MIPS Year 1

November 8, 2018
by Rajiv Leventhal, Managing Editor
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Ninety-three percent of MIPS (Merit-based Incentive Payment System)-eligible clinicians received a positive payment adjustment for their performance in 2017, and 95 percent overall avoided a negative payment adjustment, according to a CMS (Centers for Medicare & Medicaid Services) announcement today.

The first year of MIPS under MACRA’s Quality Payment Program (QPP) was dubbed by CMS as a “pick your pace year,” which essentially enabled clinicians to avoid payment penalties as long as they submitted at least the minimum amount of quality data. As such, in its announcement, CMS did admit that the overall performance threshold for MIPS was established at a relatively low level of three points, and the availability of “pick your pace” provided participation flexibility through three reporting options for clinicians: “test”, partial year, or full-year reporting.

CMS said that 93 percent of MIPS-eligible clinicians received a positive payment adjustment for their performance in 2017, and 95 percent overall avoided a negative payment adjustment. CMS specifically calculated that approximately 1.06 million MIPS-eligible clinicians in total will receive a MIPS payment adjustment, either positive, neutral, or negative. The payment adjustments for the 2017 program year get reflected in 2019.

Breaking down the 93 percent of participants that received a positive payment adjustment last year, 71 percent earned a positive payment adjustment and an adjustment for exceptional performance, while 22 percent earned a positive payment adjustment only. Meanwhile, just 5 percent of MIPS-eligible clinicians received a negative payment adjustment, and 2 percent received a neutral adjustment (no increase or decrease).

Of the total population, just over one million MIPS-eligible clinicians reported data as either an individual, as a part of a group, or through an Alternative Payment Model (APM), and received a neutral payment adjustment or better. Additionally, under the Advanced APM track, just more than 99,000 eligible clinicians earned Qualifying APM Participant (QP) status, according to the CMS data.

CMS Administrator Seema Verma noted on the first pick-your-pace year of the QPP, “This measured approach allowed more clinicians to successfully participate, which led to many clinicians exceeding the performance threshold and a wider distribution of positive payment adjustments. We expect that the gradual increases in the performance thresholds in future program years will create an evolving distribution of payment adjustments for high performing clinicians who continue to invest in improving quality and outcomes for beneficiaries.”

For 2018, the second year of the QPP, CMS raised the stakes for those participating clinicians. And in the third year of the program, set to start in January 2019, a final rule was just published with year three requirements. Undoubtedly, as time passes, eligible clinicians will be asked for greater participation at higher levels. At the same time, CMS continues to exempt certain clinicians who don’t meet a low-volume Medicare threshold.

Earlier this year, CMS said that 91 percent of all MIPS-eligible clinicians participated in the first year of the QPP, exceeding the agency’s internal goal.

What’s more, from a scoring perspective in 2017, the overall national mean score for MIPS-eligible clinicians was 74.01 points, and the national median was 88.97 points, on a 0 to 100 scale. Further breaking down the mean and median:

  • Clinicians participating in MIPS as individuals or groups (and not through an APM) received a mean score of 65.71 points and a median score of 83.04 points
  • Clinicians participating in MIPS through an APM received a mean score of 87.64 points and a median score of 91.67 points

Additionally, clinicians in small and rural practices who were not in APMs and who chose to participate in MIPS also performed well, CMS noted. On average, MIPS eligible clinicians in rural practices earned a mean score of 63.08 points, while clinicians in small practices received a mean score of 43.46 points.

Said Verma, “While we understand that challenges remain for clinicians in small practices, these results suggest that these clinicians and those in rural practices can successfully participate in the program. With these mean scores, clinicians in small and rural practices would still receive a neutral or positive payment adjustment for the 2017, 2018, and 2019 performance years due to the relatively modest performance thresholds that we have established. We will also continue to directly support these clinicians now and in future years of the program.”

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HHS Secretary Azar: HHS Is Planning New Mandatory Bundled Payment Models

November 8, 2018
by Heather Landi, Associate Editor
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The Centers for Medicare & Medicaid Services (CMS) is revisiting mandatory bundled payment models, possibly for radiation oncology and cardiac care, according to Health and Human Services Secretary Alex Azar, which signals a strong about-face in the Trump Administration’s policy about bundled payment initiatives.

HHS is reexamining the role that mandatory bundled payment models can play in the transition to value-based care, Azar said in a keynote speech at the Patient-Centered Primary Care Collaborative Conference on Thursday. HHS published Azar’s comments.

In the published remarks, Azar said the Trump Administration is revisiting mandatory bundled payments and exploring new voluntary bundled payments as part of the Administration’s goal of paying for outcomes, rather than process.

“We need results, American patients need change, and when we need mandatory models to deliver it, mandatory models are going to see a comeback,” Azar said.

In his speech, Azar said, “Imagine a system where physicians and other providers only had to worry about the outcome, rather than worrying about their staffing ratios and the individual reimbursements for every procedure they do and every drug they prescribe. That kind of payment system would radically reorient power in our healthcare system—away from the federal government and back to those closest to the patient.”

He continued, “One way we can do that is through bundling payments, rather than paying for every individual service. This is an area where you have already seen testing from CMMI for several years now—and I want to let you know today that you are going to see a lot more such ideas in the future.”

Azar highlighted the Bundled Payments for Care Improvement (BPCI), which, he said, has shown significant savings in several common inpatient episodes, including joint replacement and pneumonia.

During his speech on Thursday, Azar said, “I want to share with all of you for the first time today: We intend to revisit some of the episodic cardiac models that we pulled back, and are actively exploring new and improved episode-based models in other areas, including radiation oncology. We’re also actively looking at ways to build on the lessons and successes of the Comprehensive Care for Joint Replacement model.

“We’re not going to stop there: We will use all avenues available to us—including mandatory and voluntary episode-based payment models,” he said.

One industry group, the American Society for Radiation Oncology (ASTRO), already has voiced concerns about a mandatory payment model. In a statement issued Thursday afternoon, Laura Thevenot, CEO of ASTRO, made it clear that the organizaiton strongly supports a radiation oncology alternative payment model (RO-APM). "ASTRO has worked for many years to craft a viable payment model that would stabilize payments, drive adherence to nationally-recognized clinical guidelines and improve patient care. ASTRO believes its proposed RO-APM will allow radiation oncologists to participate fully in the transition to value-based care that both improves cancer outcomes and reduces costs."

Thevenot said ASTRO has aggressively pursued adoption of this proposed model with the Center for Medicare and Medicaid Innovation (CMMI). However, Thevenot said the group has concerns "about the possibility of launching a model that requires mandatory participation from all radiation oncology practices at the outset."

Further, Thevenot said any radiation oncology payment model will represent "a significant departure from the status quo." "Care must be taken to protect access to treatments for all radiation oncology patients and not disadvantage certain types of practices, particularly given the very high fixed costs of running a radiation oncology clinic," Thevenot stated.

Back in January, CMS announced the launch of the voluntary BPCI Advanced model, noting that it “builds on the earlier success of bundled payment models and is an important step in the move away from fee-for-service and towards paying for value.” The BPCI Advanced model includes more than 1,000 participants that are receiving episode-based payments for over 30 clinical areas, Azar said.

“BPCI Advanced is a voluntary model, where potential participants can select whether they want to join. But we’re not going to stick to voluntary models. Real experimentation with episodic bundles requires a willingness to try mandatory models. We know they are the most effective way to know whether these bundles can successfully save money and improve quality,” Azar said.

The Obama Administration introduced mandatory bundled payment for care for heart attacks and for cardiac bypass surgery in July 2016.

In the past, CMS Administrator Seema Verma has said that she does not support making bundled payments mandatory, and former HHS Secretary Tom Price, M.D. had strongly opposed mandatory bundles, going so far as to direct the end of two mandatory bundled payment programs—one existing and one previously announced. In November 2017, CMS finalized a rule, proposed in August 2017, that cancelled mandatory hip fracture and cardiac bundled payment models.

As per that final rule, CMS also scaled back the Comprehensive Care for Joint Replacement Model (CJR), specifically reducing the number of mandatory geographic areas participating in CJR from 67 areas to 34 areas. And, in an effort to address the unique needs of rural providers, the federal agency also made participation voluntary for all low-volume and rural hospitals participating in the model in all 67 geographic areas.

On Thursday, Azar acknowledged that his statements signaled HHS was reversing course on its previous stance, noting that last year the administration reduced the size of the CJR model and pulled back the other episode payment models, including those on cardiac care, before they could launch.

Azar, who was confirmed as HHS Secretary earlier this year, signaled early on that he diverged from Verma and Price on his views about mandatory bundled payments. During a Senate Finance Committee hearing in January on his nomination for HHS Secretary, he said, on the topic of CMMI [the Center for Medicare and Medicaid Innovation] pilot programs, “I believe that we need to be able to test hypotheses, and if we have to test a hypothesis, I want to be a reliable partner, I want to be collaborative in doing this, I want to be transparent, and follow appropriate procedures; but if to test a hypothesis there around changing our healthcare system, it needs to be mandatory there as opposed to voluntary, then so be it.”

During his speech Thursday, Azar pointed to the Administration’s first mandatory model, which was unveiled two weeks ago, called the International Pricing Index (IPI) Model for payments for Part B drugs. Azar said the model is a “mandatory model that will help address the inequity between what the U.S. and other countries pay for many costly drugs.”

Further, Azar said CMMI also will launch new primary care payment models before the end of the year, with the aim of introducing a spectrum of risk for primary care providers, Azar said.

“Before the end of this year, you will see new payment models coming forth from CMMI that will give primary care physicians more flexibility in how they care for their patients, while offering them significant rewards for successfully keeping them healthy and out of the hospital,” he said.

“Different sizes and types of practices can take on different levels of risk. As many of you know, even smaller practices want to be, and can be, compensated based on their patients’ outcomes,” he said. “We want to incentivize that, with a spectrum of flexibility, too: The more risk you are willing to take on, the less we’re going to micromanage your work.”

Azar also noted HHS’ efforts to examine impediments to care coordination, such as examining the Stark Law, the Anti-Kickback Statute, HIPAA, and 42 CFR Part 2. CMS has already launched and concluded a request for information on the Stark Law, and the Office of the Inspector General has done the same on the Anti-Kickback Statute, he noted.

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Dr. Sanjay Gupta’s Heartening Speech at CHIME18 Should Inspire U.S. Healthcare Leaders

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The story of an Amazonian tribe could serve as a motivational lesson for U.S. healthcare stakeholders

It was inspiring to hear Sanjay Gupta, M.D., the well-known neurosurgeon and medical reporter, give the closing keynote at the College of Healthcare Information Management Executives (CHIME) 2018 Fall CIO Forum in San Diego last week. Dr. Gupta, who serves as associate chief of the neurosurgery service at Grady Memorial Hospital in Atlanta, while also best known as CNN's multiple Emmy Award-winning chief medical correspondent, discussed the fascinating balance that he strikes between medicine and media.

“Oftentimes, I see people at their best, and sometimes at their worst. I get to travel the world, where I learn so much, but also teach others. Sometimes the dance between medicine and media can be awkward and emotionally challenging. But almost always, the stories we do have a significant impact,” Gupta told the Fall CIO Forum attendees.

What was perhaps most captivating about Gupta’s speech was when he spoke about visiting a primitive Amazonian tribe that appears to have the best heart health in the world. The Tsimane people of Bolivia do not speak a language, live a simple existence, and are disease-free, explained Gupta. So he went to visit the tribe with the goal to understand its lifestyle and what led to its members having such healthy hearts.  

Sanjay Gupta, M.D.

“I went spearfishing with one [tribe member], who thought he was 84-years-old, but he really didn’t know for sure. His shirt was off, and he was ripped, balancing himself on the canoe, just looking at the water, spearing fish. His eyesight was perfect. The entire indigenous tribe was just like this,” Gupta recalled.

After examining the Tsimane tribe’s diet, Gupta noted it was a hunter-gatherer society, meaning there was nothing technological. “The most mechanical thing I saw was a pulley for the well,” he said. Seventy percent of what they eat is carbohydrates—unrefined and unprocessed—while 15 percent of their diet is protein, and 15 percent fat, he added. “You need farmed food because oftentimes you don’t have successful hunting days, so the farmed food was the food in the bank. And they would do intermitting fasting, too. These are the people with the healthiest hearts in the world,” Gupta exclaimed.

When it comes to activity, when hunters are hunting, they’re never outrunning their prey, but rather outlasting it, noted Gupta. “We found that they walked about 17,000 steps per day. But they didn’t run; they only walked. They are active, but not intensively active. They also hardly every sit—they are either lying or standing all the time. And they would get nine hours of sleep per night, waking up to the rooster’s crow. There are no devices. Again, these are the people who have the healthiest hearts in world. They don’t have a healthcare system and don’t spend a dollar on healthcare,” Gupta stated.

What’s even more interesting about this tribe is that each of its members lives with some degree of a parasitic infection, which they usually get it early in life, have a few days of illness, and then just live with these parasites in their bodies for their entire lives. “The belief is that so much of the disease we talk about—that leads to this $3.3 trillion price tag [the total cost of U.S. healthcare spending in 2016]—is actually ignited or worsened by our immune systems. So the parasitic infections could be part of the reason they are protected from all types of diseases,” Gupta offered.

Essentially, it’s living this basic, undeveloped life that “inadvertently provides them extraordinary protection against heart disease,” noted a report in HealthDay last year. “Thanks to their unique lifestyle, most Tsimane [members] have arteries unclogged by the cholesterol plaques that drastically increase the risk of heart attack and stroke in modern Americans,” Gregory Thomas, M.D., medical director of the Memorial Care Heart & Vascular Institute at Long Beach Memorial, in California, said in that report.

Tsimane tribe (source: University of New Mexico)

You might be asking what the story of the Tsimane tribe has to do with U.S. healthcare since its lifestyle would obviously never be replicated in a developed country. And while that is true, it’s tough to ignore the $1 billion per day that our healthcare system spends on heart disease—compared to the Tsimane tribe that doesn’t spend a single dime, yet has the healthiest hearts in the world.

In this sense, perhaps we can use the Tsimane story to push ourselves to develop a greater understanding of why we spend so much money on healthcare and don’t have the results to show for it. Gupta asked this $3.3 trillion-dollar question in his speech—why does healthcare in the U.S. cost so much and what do we get in return?

“If you look at the statistics, it’s not impressive. More people die from preventable disease in the U.S. than in 12 other nations. People live longer in 30 other countries compared to the U.S.—including places like Chile and Costa Rica. We still have tens of millions of people who don’t have access, and we still spend all this money on healthcare. Why?” he asked.

Gupta explained that the nation’s high healthcare costs come down to the following: high administrative costs, technology, new drugs and development, and the cost of chronic disease—the last which is incredibly self-inflicted. About 70 to 80 percent of chronic disease is self-preventable, he said.

Indeed, as most of us know, about 5 percent of the U.S. population accounts for 50 percent of the healthcare costs. These are folks who are defined by illness, not by health, Gupta stated. This is why the modern-day healthcare system has proactively taken to targeting that 5 percent to improve their chances of preventing disease and staying healthy. “Data shows that home visits, nutritional counseling, one-on-one coaching, and diligent follow-up care can go a long way in preventing someone from getting sick in the first place, and from turning a disease into something more chronic. Some of these interventions can actually reverse disease. The die is not cast,” Gupta said.

For me, Gupta’s keynote highlighted the need for efforts around value-based care, care management, and population health to be intensified. A big part of that, as noted in the speech, is addressing patients’ social and environmental factors. It’s not at all surprising to see studies such as this one from earlier this year, conducted by researchers at the University of South Florida (USF) College of Public Health, Tampa, and WellCare Health Plans, and published in Population Health Management, which found that healthcare spending is substantially reduced when people are successfully connected to social services that address social barriers, or social determinants of health, such as secure housing, medical transportation, healthy food programs, and utility and financial assistance.

And with that, there is also an enormous opportunity for data and IT to play a role. Information sharing, so that providers have access to the right information at the point of care—no matter where the patient is—will be critical to reducing unnecessary costs. As will the robust use of data analytics, so that patient care organizations can be proactive in predicting which patients are at highest risk, when they might need services, and how to intervene at the appropriate time.

But to this point, Gupta, who noted that our society can get too caught up in high-tech, also suggested that “medicine seems to play by slightly different rules when it comes to innovation as opposed to other sectors. Sometimes, innovation moves painstakingly slow in respect to medicine.” At the end of the day, he said, it will be “the innovations that make us, [as a society], healthier, happier, and connect us in frictionless ways, that will be the biggest winners.”

So, will the U.S. population suddenly turn off their iPhone alarms, wake up to the rooster’s crow, and become a hunter-gatherer society? No, I would say that’s quite unlikely to happen. But hearing stories such as the one of the Tsimane tribe might just serve as good enough motivation to bring down the astronomical and unsustainable costs of U.S. healthcare.

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