MIPS: The Maximum Positive Adjustment Ship Has NOT Sailed

sail-boat-blogYou’ve come out of your eggnog-induced holiday fog and realize that you did not organize your practice for full-year MIPS reporting. With January 1 now in the rear-view mirror, you regretfully—but erroneously—conclude that you have missed out on the opportunity to earn the maximum positive payment adjustment in 2019. This is a common misconception that has been perpetuated in many MIPS-related webinars, blogs, and other communications. (That confusion exists is not surprising, given the spate of changes to MACRA in the last few months and the inherent complexity of the program itself.)

The fact is: Full-year reporting is NOT required to earn the maximum positive MIPS incentive in 2019. Rather, it is performance that counts, i.e. the number of MIPS points you earn and the level of quality you demonstrate, not the length of your reporting period or the amount of data you submit. If you look at the most recent CMS presentations, you will see images and text that clarify this point.key-takeaway-v2

It could be argued—and representatives of CMS have done so—that it might be easier to achieve a high MIPS score with a longer reporting period, particularly on certain quality measures. Perhaps so… but this does not preclude clinicians from achieving an equally high score in a shorter period.

Of course, there is no such thing as a free lunch; and there are consequences—possibly unintended—of CMS’ largess in offering the Pick Your Pace options for 2017. Regardless of how many MIPS points an eligible clinician earns in 2017, his/her 2019 payment adjustment will, of necessity, fall short of the originally planned 4% due to the legislative mandate for budget neutrality. In the Final Rule, CMS estimated that the upward adjustment potential will now be less than 1% for the base performance and under 2.4% when the additional money for exceptional performance is included. (For an explanation and graphic that explains the required “scaling process”, see pages 77340 – 77342 of the Final Rule.)

That said, however, the good news remains: You have not missed the boat! But it is time to get to work to allow yourself the time and flexibility to maximize your performance, identify the optimal reporting period, and earn the greatest reward.

The Year’s Innovations – Wrap-up & What’s to Come!

2017-lightbulbsDepending on your point of view, 2016 was either a year to remember, or one to forget—just look at the nominations for word of the year. Pundits have proposed everything from “surreal” (Merriam-Webster’s) to “post-truth” (Oxford Dictionaries) to “unhinged” (NPR’s books editor Petra Mayer). Which is just to say, it was a year when conventional expectations were overthrown. And 2017 promises to be just as full of surprises.

For all the uncertainty, though, some trends seem sure to continue, at least in healthcare. The movement toward value-based payment is unlikely to reverse itself, which means that the optimum long-term strategy for medical practices remains the same as last year—cut costs by increasing efficiency, maximize patient base by identifying and standardizing successful treatment approaches, and stay limber by not getting locked into a cumbersome, inflexible software system.

Over the years, we have worked closely with our clients to learn what they needed from us, and to gain the sort of specialty-specific expertise that ensures that our solutions are designed around our clients’ workflows, rather expecting them to tailor their workflows to our design.

This past year, however, has been particularly transformative. We have made a quantum leap forward by upgrading our EHR into something far more—an intelligent, data-focused solution that responds to today’s industry challenges and lays a solid but flexible groundwork for the future. It’s a unique, best-of-breed, specialty-focused approach that gives users the power to define and collect whatever data points are relevant to their success while still maintaining their preferred clinical workflow options.

What we have achieved so far – 2016 recap

We entered last year determined to expand our physician-centric approach to include all stakeholders in the outpatient healthcare delivery system. Because we put our clients’ requirements first, we had to take a fresh look at what their needs actually were in this changing landscape. The biggest need? Tools to capture the data they wanted, but only that data, without anything unnecessary that would distract from their primary focus. (Click here to read my other post about how we do data differently.) We realized that, to meet those needs, we had to transform our offering into more than just an EHR.

We achieved this by creating a  connected software system that lets practices distribute the data-collection process over the entire treatment encounter—before, during, and after the patient visit—in whatever way is most efficient and sensible for them. Here is what we have delivered:

  • Flexible Data Platform (FDP) – Discrete data collection and reporting, free from a forced template-based environment.
  • Smart Workflows (SWF) – Guided workflow to help practices optimize their daily schedules by letting them determine who does what best, where and when.
  • Patient engagement platform – A patient-portal solution that seamlessly engages the patient pre-visit. Success is measured by higher patient compliance, lower check-in costs to practices, and greater patient engagement in their own health post-patient visit.
  • Interoperability – An Application Program Interface (API) that allows for efficient data exchange between systems, and that gives practices the flexibility to choose the best solution to any given problem (e.g., clinical, financial) without sacrificing cost and/or productivity.

What’s next? – Even more data!

We have already laid the foundation for what is required today and tomorrow. The next step is to ensure that we maximize the value of what we offer by providing the following additions to fulfill our vision:

  • Regulatory compliance – Prepare clients to understand, comply, and succeed while retaining productivity and efficiency focus (e.g., MU / MIPS, AMC, PQRS reporting).
  • Outcomes – Invest in solutions and technologies to help practices drive, improve, and document clinical outcomes to improve patient care and increase reimbursements
  • Data and AI – Continue to optimize SRS’s recently released SWF and FDP solutions to leverage data and artificial intelligence to optimize clinical workflows.

We understand that no two practices are alike—they all have different rates and style of data collection. One practice may need to automate everything immediately, while another may only automate elements that will drive down costs, and decide to keep other processes manual. Our solution is designed with this level of flexibility in mind—to satisfy each practice’s requirements for today while having the functionality to support their evolving needs in the future.

Wrapping it up

The underlying SRS strategy is a physician-centric approach we call “practical innovation.” We are more than just a solutions vendor . . . we focus on finding a solution to the specific challenges facing specialists. We partner with practices to solve their actual business problems—we help them stay independent, drive revenue growth, lower costs, stay compliant with regulations, and demonstrate clinical quality.

If you’re looking for a partner who will really listen to you and understand your needs, who will help engage your patients and produce better clinical outcomes, who will keep your practice competitive in a changing environment, then SRS is your partner of choice—for today, and for whatever unpredictable tomorrow awaits us down the road.

What Are Specialists Faced With Today? Uncertainty and Change!

Changes AheadRecent Nobel-recipient Bob Dylan wrote “The Times They Are A-Changin’” in 1963—a time of growing social upheaval reflected in the song’s lyrics, which called for listeners to acknowledge and embrace the transformations taking place around them. As I listened to this song over the past weekend, I couldn’t help but draw a correlation to the radical transformations we are currently experiencing in our industry. The past several years have epitomized the term “change” as the nation has taken big steps to transform the delivery of healthcare.

The American Recovery and Reinvestment Act, signed in 2009 by President Barack Obama, was one of the catalysts for this transformation by requiring the “meaningful use” of digital systems in healthcare. Since then, change has been the only constant that we have been able to count on. Government regulations, payment models, and product innovations have continued to evolve in disruptive ways—both good and bad. As soon as we become comfortable with one wave of change, another wave is already threatening to drench us to the bone (for us, the next big one is MACRA & MIPS).

So, coming off nearly a decade of constant uncertainty, what’s next? Well, you guessed it—more change! Starting in 2017 we will have new policy leaders in place who have promised to significantly restructure the incumbent’s healthcare programs. President-elect Donald Trump’s appointment of Tom Price as the head of HHS may be indicative of the changes on the horizon. Price, a 6-term congressman from the Atlanta, Georgia, area, was formerly an orthopedic surgeon. Will a specialist at the helm help make government programs, that have typically been focused on primary and in-patient care, more meaningful for specialists?

Time will tell, but the one thing that is certain is that, as the song says, the wheel is still in spin. In other words, the times they are still a-changin’.

The Final MACRA Rule: Free Pass or Risk-Free Opportunity

opportunity-ahead-blogCMS has given providers an early holiday present with the Final MACRA Rule, affording everyone the opportunity to easily avoid a penalty in 2019. This is surely reassuring news and has been widely received with a huge sigh of relief—but before you let your guard down, it is important to acknowledge that the program will build back up to an only slightly modified version of its originally proposed self, with many of the complexities and challenges intact. CMS is calling 2017—and to a lesser extent 2018—“transition years.” Treating them as such offers an opportunity to prepare for the future, while treating them as a free pass only delays the inevitable.

In 2017, eligible clinicians who participate in MIPS can protect their 2019 Medicare fee schedule by merely reporting any ONE of the following:

  • 1 quality measure, or
  • 1 Improvement Activity (formerly called Clinical Practice Improvement Activities), or
  • The 4 required Advancing Care Information (formerly Meaningful Use) measures.

Anyone who has participated in Meaningful Use and/or PQRS has already far exceeded these requirements, and will find this an extremely low bar. So why not aim for one of the more advanced “pick your pace” participation options and potentially benefit from an upward adjustment to your fee schedule? All it takes is reporting anything more than the above for a period of at least 90 days, and you could earn a “small” adjustment in 2019. Participate more fully—for anywhere from 90 days to a full year—and you could be eligible for the maximum, albeit “modest,” payment adjustment. (Note that it is performance that drives the payment adjustment, not the length of the reporting period.)

The downside of this new flexibility is that these “small” and “modest” adjustments for successful MIPS participants will now be very small or modest in 2019—far short of the originally planned 4%. Congress mandated that MACRA be budget neutral, so with dramatically fewer losers in 2017 to fund the gains of the winners, bonuses will be scaled down. Near-term financial rewards are unlikely to be a strong motivator of compliance this year.

However, by 2020, the difference between the most and least successful providers will exceed 18% (i.e., 2022 payment adjustments will range from -9% to +9% with potential additional bonuses available for the highest performers). So while it might be tempting to sit back and relax next year, consider using 2017 instead as it was intended—as a transition from MU and PQRS to MACRA. If you have been successful in the past, now is a good time to experiment with new workflows, new technologies, and/or alternate measures or reporting methods that might improve your performance. If you’ve never participated in these programs before, you can start now and get off the penalty track.

You can view the 2017 Final Rule as a free pass or as an opportunity—the choice is yours.

What We’re Grateful for—Our Clients!

we-give-thanks

I joined the SRS Sales Management Team in 2012. One of the attractions to join the SRS Team was the corporate culture — an environment that fostered cross-functional communication, interdependency, and most importantly, client evangelism. At the time, SRS employees were referred to as ETPs, which is an acronym for Eager to Please. This attitude permeated the entire organization from the top down and is still present today. In fact, under our CEO Scott Ciccarelli, this founding principle has been taken a step further by involving the voice of the SRS client in our design and development process. Through our Client Advisory Board and User Centric Design Groups, our clients work with our development teams to provide valuable feedback, clinical insight, and recommended enhancements to our software. This process allows SRS to truly serve our clients as a business partner and ensure they are pleased as we release new innovations.

All of us at SRS are grateful for our clients, not only for their valued support, but for their invaluable feedback, which has allowed SRS to evolve from an expertise in transitioning high-volume specialty practices from paper into being a flexible, data-driven, full-HCIT-solutions partner. Through the voice of our clients, SRS continues to evolve, improve, and thrive!

So as Thanksgiving approaches, we would like to give thanks for our clients and recognize how much they have given back to the SRS Team throughout the year.

Our clients keep us human. Many of the departments within SRS are client-facing and work with clinicians and staff on a daily basis to answer questions, interpret government regulations, solve workflow issues, and support the SRS product suite. The SRS Account Management Team serves as a single point of contact and will often act as the advocate for the practice, ensuring all of their needs are met and they get the information they need without having to speak with several people. Through this consistent contact, we develop close working relationships with our clients and truly care about them, not only on a professional level, but on a personal level as well. Our clients keep us human when they share stories about the challenges and triumphs they face in their clinics and in their personal lives. These working relationships allow us to take pride in our work and feel a connection that makes our jobs more meaningful.

Our clients make us feel as if we are making a difference. It’s no secret that physicians and their clinical staff prefer to focus their efforts on their patients rather than on HCIT solutions. Our clients make us feel valued when they express excitement over our efforts to streamline a clinical workflow, develop and improve a form, or drive efficiencies through the creation of clinical protocols. As we improve their user experience and interaction with the software, we also feel as if we have helped to improve the doctor/patient experience.

Our clients advocate for us. The hallways at SRS corporate headquarters are lined with framed letters of recognition from clients. Most were written following the implementation and go-live process, and they recognize the dedicated Implementation Specialist assigned to the project who made everything come together—allowing for a smooth transition. Our clients have been, and continue to be, the best form of advertising for SRS, promoting their individual experiences and referring their colleagues and affiliates. This recognition is invaluable and allows us to grow and continue to innovate to support them.

For all that you do, we are forever grateful to the SRS client family and extend our best wishes to you and your families for a wonderful Thanksgiving holiday!

Sincerely,

Diane Beatini

The Hills Are Alive…With the Sound of a New SRS!

mountain-blogI love that our annual event is called the SRS User Summit – because this year, the news was so good that I wanted to shout it from the top of the tallest mountain! (Or, maybe sing it, but I’m no von Trapp family member…) Every member of the SRS team felt the same way. Thankfully, after hearing our big news, so did the clients who attended.

Here’s the shout-worthy news: SRS has completely transformed into an intelligent data-focused solutions provider. Our days of being a document management company are behind us. And rather than tweaking existing template-based systems as many of our competitors have chosen to do, we pioneered a specialist-oriented solution that simply doesn’t exist elsewhere. We have invented a new approach to data that is totally revolutionary – balancing speed, efficiency, data collection and sharing.

Why? Demands on medical practices have become even steeper, and the main path followed by other HCIT vendors won’t help specialists reach their goals. That’s why SRS is carving out new trails in order to provide the level of partnership that is needed today and tomorrow. Together, we will achieve:

  • Better patient engagement
  • Better clinical outcomes
  • Better operational efficiency

I know that’s a lot to claim. That’s exactly why I was so excited to unveil the new SRS at the User Summit: because as someone with a high say/do ratio, I’m thrilled to say that we can back up every claim we are making! Here are a few examples of what’s available now, and what is coming soon:

TODAY

  • Patient Engagement Platform– streamline the registration process by enhancing the digital intake experience and reduce appointment “no shows” with automated reminders. Influence patient behavior through meaningful engagement in both pre and post visit by customizing patient forms to practice requirements, and leveraging patients to complete forms online before their appointment.
  • Smart Workflows –our revolutionary patent pending Smart Workflows allow you to collect more data and quickly document patient encounters with customizable workflows, provide standardized care efficiently through protocols, drive compliance with regulatory and quality improvement initiatives, and demonstrate the value of your services through analytics and outcomes.
  • Data Interoperability – capture then share discrete clinical data with other information systems across all parts of the healthcare network through the use of our APIs.

TOMORROW

  • Flexible Data Platform –capture the data you want, when you want, and how you want with our data capture platform. It empowers users to drill down and capture and report on any discrete data point that is truly relevant to them.
  • Integrated Best of Breed – enjoy the seamless user experience of our tightly integrated healthcare IT ecosystem—including EHR, Practice Management, Patient Portal, and Transcription—each selected for their ability to serve high-performance specialists and to easily integrate with your practice’s other HCIT solutions.
  • Patient Population – improve patient outcomes through tailored outreach campaigns that educate them post encounter, as well as setting up reminders and sending out surveys to collect more relevant data.

Of course, some things about SRS remain the same – and we promise, they won’t change! For example, we will continue to guide you through regulatory compliance, thanks to our own governmental Sherpa, Lynn Scheps, who has already dug into the 2,398 pages of the new MACRA rule released a week ago.  Plus, the superb client service for which we are known will continue to be core to the SRS experience.

We understand that the future will continue to be an uphill climb. But with SRS by your side, you’ll have the right tools on the right paths. Now that is something to sing about!