Hot Topics for Orthopaedics

Diane Beatini

Diane Beatini

Vice President, Sales at SRS Health
Diane Beatini is the Vice President of Sales. She oversees the Sales, Account Management, and Sales Operations teams. She works to promote the complete SRS product suite of HCIT solutions to medical practices of varied sizes and specialties. Diane’s background includes an MBA in marketing and finance with 15 years of executive sales and customer service management experience in the radiology, medical device, and pharmaceutical industries.
Diane Beatini

Latest posts by Diane Beatini (see all)

SRS Health attends the annual OrthoForums and AAOS meetings as a way of remaining in sync with the topics that are top of mind for our clients. As an HCIT solutions partner, we are continually striving to provide our clients with relevant solutions, training, and advice on resources so that they can meet challenges head on while remaining productive and focused on the practice of medicine. The forums and academy meetings provide us with additional insight outside of our day-to-day interactions, and often serve as springboards for our collaborative efforts.

This year, the prominent topics in the orthopaedic community include:

  • prescription safety
  • data mining/outcomes;
  • cost reduction/operational efficiencies; and
  • MACRA/ MIPs readiness.

Prescription safety has gained increased focus as numerous studies and reports focus on the increased use and abuse of opioids. As a result, individual states are beginning to enact laws addressing the prescribing of controlled substances. Electronic prescribing of controlled substances (EPCS) is currently legal in all 50 states. New York State was the first to pass mandatory I-Stop legislation requiring ePrescribing of all drugs, with stringent identity authentication requirements for controlled substances as of March 27, 2016. Maine has followed suit with the Act to Prevent Opiate Abuse by Strengthening the Controlled Substances Prescription Monitoring Program, requiring prescriber participation in the Prescription Monitoring Program and setting limits for the strength and duration of opioid prescriptions, beginning January 2017. The law also called for prescribers to undergo addiction training every two years. On February 23, 2017, New Jersey issued a bulletin regarding State Opioid Prescribing Information, alerting prescribers to components of a law governing opioid prescribing that takes effect in May. Minnesota also has a similar CDS law on its books, although not as strictly enforced. The expectation is that stringent monitoring will only become more prevalent, with mandatory requirements that will include patient education. As a result, many providers have voluntarily adopted EPCS practices, and the American Academy of Orthopaedic Surgeons has created a multimedia public service campaign, including display and radio ads, urging physicians and patients to exercise caution in prescribing and taking opioids.Painkillers Campaign Image2

As we embrace the value-based payment model, data mining and patient-reported outcomes are top of mind. The critical piece to the puzzle is the ability to collect and report on pertinent and meaningful data to demonstrate improved outcomes. Many physicians are currently considering the selection of an outcomes solution to integrate within their existing HCIT ecosystem. There is no firm consensus across the orthopaedic space of what constitutes full outcomes data requirements, and many are focused on choosing an optimal solution that delivers minimal PRO requirements—i.e., HOOS (Hip disability and Osteoarthritis Outcome Scores) and KOOS (Knee injury & Osteoarthritis Outcome Scores)—at the right price point.

As the payment model shifts and practices are faced with additional reporting complexities, the ability to drive operational efficiency and reduce costs is a critical focus. Integral to all related topics—prescription safety and the ability to demonstrate outcomes, drive down operating costs and meet regulatory requirements under MACRA/MIPs—is the ability to streamline the patient intake process, satisfy the VDT, meet secure messaging requirements, and integrate patient reported data through a quality patient-portal solution. Core functional capabilities such as ease of use and access; ability to request appointments; facilitated patient communication through notifications; integration of patient information within the EHR; and the enabling of secure messaging/exchange allow orthopaedic practices to reduce the time and resources devoted to patient intake and data input, as well as to limit appointment cancellations and/or no shows. Adoption of a patient-engagement solution supports 20 points under MIPs in 2017 and up to 40 points in 2018 with the addition of patient education. The portal also becomes a critical focal point to enhancing patient care through an ongoing dialogue and supporting patient education.

MACRA/MIPs readiness and the assurance that the EHR software employed by the practice will be 2015 certified is also a topic of interest as the marketplace continues to consolidate and EHR solutions sunset. At the outset of the MU program formulated through the HITECH Act of the American Recovery and Reinvestment Act (also known as the 2009 Economic Stimulus Plan), there were over 500 EHR solutions vendors. Today there are fewer than 300, with continued consolidation expected as companies decide whether to further invest and develop to the 2015 certification requirements. Practices should have regular dialogue with their HCIT solutions vendors regarding their investment and plans to certify; and also the availability of MACRA/MIPs training programs to support their regulatory goals.

Your First MACRA Decision: AAPM or MIPS?

Lynn Scheps

Lynn Scheps

VP, Government Affairs & Consulting Services at SRS Health
Lynn Scheps is a leading resource on MACRA, MIPS, and Meaningful Use. She is the SRS liaison with government policy makers. Representing the voice of specialists and other high-performance physicians, she develops strategies to respond effectively to government initiatives.
Lynn Scheps

Clinicians have two options for MACRA participation—an Advanced Alternate Payment Model (AAPM) or the Merit-Based Incentive Payment System (MIPS).MACRAs-2-Tracks-final

CMS has structured MACRA to encourage AAPM participation, offering clinicians a 5% lump-sum bonus on top of a share in the savings achieved by the organization. The following questions will help you determine whether you qualify for the AAPM option: 

  • Do you participate in an APM? (An ACO or other risk-based healthcare delivery program?)
  • Is your APM an AAPM? The APMs identified in the image above qualify as AAPMs by virtue of the fact that:
    • the hospital and the clinicians use certified EHR technology,
    • the organization bears both upside and downside financial risk, and
    • the providers report quality measures.

NOTE: The CMS CJR (Comprehensive Care for Joint Replacement) program is now considered an AAPM. (According to the CMS Fact Sheet, this program was recently added to the list of 2017 AAPMs.)

  • Do you meet the participation volume thresholds, i.e., do you derive 25% of your Medicare revenue or see 20% of your Medicare patients through one of these channels?

If the answer to all the questions above is “Yes,” you may be a QP (qualified participant) in an AAPM. Talk to the organization’s sponsor (typically a hospital) about your participation in MACRA.

If the answer is “No,” to all, or some, of these questions, your route to MACRA success will be via MIPS, or a MIPS APM, respectively.

For more information about MIPS and MIPS APMs, see the CMS QPP website or contact me at SRS Health. I also invite you to watch (or watch again) my webinar titled, “MACRA/MIPS: The Future Starts Now.”

MIPS: The Maximum Positive Adjustment Ship Has NOT Sailed

Lynn Scheps

Lynn Scheps

VP, Government Affairs & Consulting Services at SRS Health
Lynn Scheps is a leading resource on MACRA, MIPS, and Meaningful Use. She is the SRS liaison with government policy makers. Representing the voice of specialists and other high-performance physicians, she develops strategies to respond effectively to government initiatives.
Lynn Scheps

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 Final MACRA Rule: Free Pass or Risk-Free Opportunity

Lynn Scheps

Lynn Scheps

VP, Government Affairs & Consulting Services at SRS Health
Lynn Scheps is a leading resource on MACRA, MIPS, and Meaningful Use. She is the SRS liaison with government policy makers. Representing the voice of specialists and other high-performance physicians, she develops strategies to respond effectively to government initiatives.
Lynn Scheps

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.

MACRA News: CMS Yields to Pressure with “Pick Your Pace”

Lynn Scheps

Lynn Scheps

VP, Government Affairs & Consulting Services at SRS Health
Lynn Scheps is a leading resource on MACRA, MIPS, and Meaningful Use. She is the SRS liaison with government policy makers. Representing the voice of specialists and other high-performance physicians, she develops strategies to respond effectively to government initiatives.
Lynn Scheps

yieldAs everyone is in the midst of anxiously trying to prepare for MACRA while awaiting the Final Rule, (due November 1), CMS announced yesterday that it is stepping back the requirements and the timetable to make it easier for providers to avoid the 2019 negative payment adjustments set out in the Proposed Rule. This decision comes in the wake of 4,000 comments and subsequent pressure from professional groups and from Congressmen/women pleading for relief from the rushed implementation of a complex and overly aggressive set of requirements that would negatively impact many practices, particularly small groups.

Andy Slavitt, Acting Administrator of CMS, published a blog that gave an overview of the new options that allow providers to “pick their pace” of complying. It appears that the only way a provider would receive a negative adjustment in 2019 would be if they do almost nothing in 2017. He outlined 4 options for participation:

  1. Do something! Avoid a negative payment adjustment in 2019 by submitting some data in 2017. This begs the question: what constitutes “some data?” Does this mean some data in each MIPS category, some data in one category, quality data only? (To me, the wording in Slavitt’s blog is reminiscent of CMS’ past MU shift to “capability enabled” or “met for 1 patient”.)
  2. Report for a short reporting period (“a reduced number of days”) could qualify you for a “small” positive payment adjustment.
  3. Comply with MIPS as defined in the Proposed Rule—or I assume, as it will be defined in the Final Rule— for the full calendar year and you could qualify for a “modest” positive payment adjustment.
  4. Participate in MACRA’s Advanced Alternate Payment Model option. CMS is hinting that it may broaden the definition of an APM.

This news will no doubt be greeted with relief and cheers by most providers, but I wouldn’t be surprised if they are left feeling more uncertain now of what will be required in 2017 than they did before the announcement! What constitutes sufficient reporting in options 1 and 2 above? How many days are in a short reporting period—90 perhaps? How do the revised “small” and “modest” payment adjustments compare to the potential 4% proposed for 2017 and to each other? Will performance still be evaluated relative to other providers? And what happened to budget neutrality, i.e., where is this money coming from if hardly anyone will receive a negative adjustment?

Please let us know what you think of this latest MACRA news, and stay tuned as we learn more!