Achieving Value-Based Care – Making the Right Partnership for Success

Christine Schiff

Christine Schiff

Government Affairs Specialist at SRS Health
Christine has been with SRS for over 5 years, working in Government Affairs and serving as the HIPAA Privacy Officer. She is devoted to providing excellent customer service, and she translates this passion into the work she does to support government program compliance. She has an expert understanding of MU and PQRS and serves as a valuable client resource.

Prior to joining SRS, Christine worked at NYU for 11 years where she also obtained her Bachelor of Science in Healthcare Management.
Christine Schiff

There are many factors that contribute to achieving “value-based care,” some of which your practice may already be targeting—patient engagement, interoperability, outcomes, and efficiency, just to name a few! The reality is that the shift to value-based care has been underway for some time, but the change-over is accelerating with the implementation of MACRA. Whether through Alternative Payment Models or the Merit-Based Incentive Payment System (MIPS), the emphasis is now on improving quality and reducing cost.

For most doctors, of course, delivering quality care has always been a priority, so the question really is how to document that while maintaining practice efficiency, containing costs, and continuing to provide excellent patient care. Let’s look at some of the components of Value-Based Care:value-based-care-infographic

 

Whether you focus on all or some of these components, there will likely be a shift in how you use your EHR. To be effective in your pursuit of value-based care, you need your HIT vendor to be a true partner. Here are some questions to consider as you determine your goals and your technology needs:

  • What am I doing to drive value-based care, and how are my partners supporting me?
  • Where do I need more assistance?

And more specifically:

  • Do I have the capability to effectively engage and maintain communication with my patients—both pre- and post-visit—to better manage their care?
  • Can I track outcomes and set standards of care/protocols?
  • Can my current technology improve my practice efficiency?

Don’t settle for only what is imposed by regulatory requirements—decide what is truly valuable for the care of your patients and then implement it. The right technology partners will help you to develop a strategy for achieving your patient-care goals. Remember: How to efficiently deliver the highest quality patient care is an ongoing conversation—make sure your technology partners are holding up their end of it.

Let’s continue the conversation – tell us what you are doing to drive value-based care.

Patient-Reported Data Collection and Return on Investment

ROI-300x300-screenDetermining ROI Metrics

The determination of when an investment recoups its costs is in many instances a fairly straightforward matter. In other instances however, it isn’t quite that simple. As the transition to value-based healthcare advances, providers are keenly looking for ways to assess the impact of patient-reported outcomes data on their bottom line.

The identification of a specific ROI metric to the cost of deploying a patient-reported outcomes data platform deployment is dependent on a number of factors that are not always easily quantifiable. Much depends upon what kind of data is being collected, the purposes for which it is being collected and both the qualitative and quantitative nature of the data.

To ensure a credible and reliable calculation of the ROI of patient-reported outcomes data collection, providers should rely upon a rigorous systematic approach for evaluation. One such methodology can be found in the work of the ROI Institute, through their “evaluation framework,”1 which categorizes results in a prescribed, logical order. This recommended sequence represents a chain of impact that can attribute and account for benefits realized. This framework consists of 5 levels of information to consider:

  1. Reaction to the program, particularly the perceived value of the program.
  2. The extent of learning such as skills, competencies, knowledge, and insights in the program.
  3. The extent of application and use of knowledge, skill, and insights acquired during the process.
  4. The program’s effect on the data such as, sales, productivity, quality, time, and costs.
  5. The ROI, the net monetary benefits compared to the cost of the program.

Patient-reported outcomes data collection offers its users a myriad of ways to generate value. For researchers, the data analysis tools provide powerful opportunities to analyze deep data sets. Practice managers are enabled to follow physician members to uncover best practices. And of course physicians can optimize their CMS reimbursement adjustment amounts by monitoring their performance scores throughout a performance year. The point is each user has a unique basis from which to evaluate and determine the overall benefit Patient-reported outcomes data collection contributes to a provider’s practice. Any valid assessment of an ROI must be tailored to the specifics of each user. Any generalized metric is clumsy at best and more than likely misleading.

Value Return to Physicians

The value of any patient-reported data collection platform to a physician must be measured by an array of considerations requiring objective and deliberate analysis. Each aspect of a physician’s practice that is impacted, whether directly or indirectly, necessarily needs to be factored into the equation. Failure to pursue such diligence in the assessment process will more than likely produce an incomplete and misleading result.

Application of the ROI Institute’s evolution framework offers a substantive foundation on which to assemble a meaningful appraisal. The framework is flexible enough to enable application to each unique practice configuration, yet establishes cumulative benchmarks that result in a succinct and useful metric. The sequential nature of the framework reinforces an approach that captures seemingly disparate variables and leverages them collectively to reveal a deeper and more nuanced valuation of deploying a patient-reported outcomes measurement system.

Data mining technology, such as OBERD’s “Mountain,” can factor prominently in generating value out of the data being collected. With it, physicians have the power to slice and dice information in a myriad of ways for infinite uses. For example, providers may measure effectiveness of care, by specific procedure as well as in aggregate. These insights, which can be generated on-demand, can empower physicians with invaluable and actionable information. No longer is a physician constrained to wait for an annual, boilerplate report.

The capacity to robustly leverage data enables insightful benchmarking for both patient and practice analysis can fortify operational best practices. By incorporating efficiencies and successful procedures revealed through tools such as Mountain, new competitive and productive gains can be realized.

A byproduct of this ability to mine data is to provide physicians the opportunity to license newly uncovered knowledge to manufacturers for research and development by the medical and pharmaceutical industries.

Patient Engagement

Patient portals and other technologies that identify and fortify patient touch-points provide opportunities to encourage patient participation in their own care. Heightened patient engagement can lead to better healthcare outcomes at a lower cost by increasing the efficiency of the healthcare system/care offered. In addition, the deployment of patient defined outcomes instruments offers to maximize clinician-patient communication by facilitating an environment that involves patients in their care leading to a better understanding of their conditions and quality outcomes.

Tracking patient reported outcomes for research purposes provides an exceptional marketing tool to showcase your advancement in medical treatments/surgical practices. OBERD’s powerful analytic tool, Mountain, offers providers a platform to analyze and mine the data you collect, and to benchmark against other data sets, global or local.

MIPS Compliance

The determination of any unambiguous ROI regarding MIPS compliance relies upon several factors that presently are premature to firmly assess and are simply not available. No reliable computations can be made until CMS has aggregated Composite Performance Scores (CPS) of all physicians participating in MIPS performance year one, 2017. All scores achieved during this initial year will be used to determine a “CPS Threshold” against which providers will be compared in order to assign reimbursement adjustments that will affect payment year one amounts in 2019. Until that threshold is published, it is simply impossible to identify express ROI expectations.

That said, close monitoring of CMS communications are beginning to reveal benefits through the thoughtful and strategic usage of patient-reported data measurement for the collection, analysis and reporting of patient-reported outcomes data.

CMS has published guidelines to demonstrate how reimbursement will work through the Quality Payment Program (QPP) but has yet to provide specific monetary values. The program has allocated $833 million dollars yearly for the next 5 years that will be distributed based on eligible clinician merit with a focus on quality outcomes, which is reflected in one’s CPS.  The better one’s CPS, the higher the probability that positive reimbursement adjustment will follow. Beyond the funding set aside to incentivize performance merit, here is an additional $500 million dollars available annually for the next 5 years reserved for those with an overall composite score of 70 points or above.

OBERD continues to closely monitor CMS announcements and regulatory developments. As each iteration of QPP rules are revealed, OBERD will continue to refine its products to optimize results for its customers.

Reinforcing a Practice’s Marketing Message

The publication of CMS’s Physician Compare website, by publishing clinician measure scores, allows patient to embody the role of a consumer in shopping around for the best healthcare and for providers that demonstrate higher quality outcomes. CMS has further advanced the promotion of provider score transparency by empowering qualified clinical data registries (QCDR) to supplement Physician Compare website information with enriched content that will further empower patients to see additional information about providers and their practice. OBERD, as a CMS-approved QCDR, is developing multi-modality scorecards to showcase a provider’s best qualities, identify top performers, identify best practices and establish additional practice marketing opportunities.

Summary

As the transition from a fee-for-service to a value-based care system continues to evolve and accelerate, the ability to efficiently and economically collect, analyze and communicate patient-outcomes data will be foundational to a provider’s success. Evidence-based healthcare decisions will rely on leveraging a patient’s involvement in their own healthcare. By increasing the role of a patient to communicate on their own individual situation and progress, that patient is afforded a more active role, which promotes better patient experience and satisfaction. Better performance scores directly impact reimbursement computation.

Of the ROI Institute’s five point evaluation framework mentioned earlier, it needs to be underscored that the first three elements address subjects that do not lend themselves to quantifiable measurement. The perceived value derived from acquired knowledge, skills and insights precludes the value received in the application of those newly realized observations. Application of the new knowledge in turn can directly impact and drive a provider’s best practice.

The ROI evaluation framework begins to address quantifiable activities in step four only after the first three steps of the process are accomplished. These activities, such as sales, productivity and costs can only be accurately assessed in the context of framework steps 1-3. The ROI Institute’s framework requires that all four steps are necessary, a condition precedent, before any actual ROI, the net monetary benefit compared to cost, can be accurately assembled.

OBERD understands that providers desire to be free from the routine task of data collection. Providers can now harness exceptional new methods to gather information from their patients, learn from them and to apply those insights towards that patient’s care. A healthcare provider should be able to practice medicine, and not have to monitor every single regulatory change. OBERD is set up to do just that. Be assured that OBERD will continue to advance solutions that address the latest in compensation strategies that generate optimized benefit to its customers.

As seen in OBERD’s Insights Blog.

Learn how you can take your value-based care to new levels with our new outcomes solution in partnership with OBERD.

2018 MACRA (MIPS) Proposed Rule: The Abridged Version

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

lynns-notesThe proposed rule is here, and it’s another long one! So for those who don’t have the patience (or the time) to read through the 1,000+ pages, here are some highlights from what CMS is suggesting for the second year of MIPS. Bear in mind that these are proposals; they must be confirmed in the Final Rule, which will be released by November. (What had already been set in stone within the MACRA legislation itself is the maximum penalty and related incentive: 5% in 2020 based on performance in 2018, up from 4% in 2019 based on performance in 2017.)

  • CMS would allow clinicians to use either 2014- or 2015-Certified EHR technology to report for 2018. Acknowledging the slower-than-anticipated pace at which EHRs are achieving the next required certification, this accommodation will facilitate more successful, non-rushed upgrades and provide sufficient time for training on the new capabilities and associated requirements. To encourage the move to 2015 CEHRT, 10 ACI bonus points would be awarded for its exclusive use.
  • The Quality reporting period returns to full year, but ACI (Advancing Care Information) and Improvement Activities remain at a minimum of 90 days. Cost is still unscored, but performance in this category will be evaluated by CMS and feedback will be provided to clinicians to prepare them for 2019 when, by law, the cost category must account for 30% of the MIPS score.
  • The proposed performance threshold separating “the winners” from “the losers”, (i.e., recipients of positive vs. negative payment adjustments), would increase from 3 points out of 100 in 2017 to 15 MIPS points in 2018—still an eminently achievable bar.
  • CMS would implement increased protection for small groups (≤15 eligible clinicians)—these are the practices that had been predicted to be the most vulnerable to penalties.
  • Many more clinicians would be exempt from MIPS altogether because the eligibility threshold would increase from $30,000 to $90,000 in annual Medicare revenue and from at least 100 to at least 200 Medicare patients.
  • Small groups that do participate in MIPS would receive 5 bonus points toward their score, in an attempt to level the playing field.
  • And my favorite proposal is one that specialists, in particular, will appreciate: the elimination of the restriction that all 6 quality measures had to be reported by the same submission method. In 2018, clinicians would be able to mix and match submission methods within a category. Specialists, who have typically been faced with an insufficient number of relevant eCQMs, would be able to continue reporting those measures which are available by EHR submission, but could supplement them with registry or claims measures that are also specialty specific. The result would be more meaningful reporting and more equitable scoring. This is a request that SRS has included in its comments to each of the previous proposed and final MACRA rules, so we were very happy to see this change.

MIPS is only one of the two MACRA participation options, and CMS has also proposed some changes designed to accelerate the shift from MIPS to Alternate Payment Models. More on that topic in a future post.

CMS Overpaid $729MM in MU Payments: What Does That Mean for You?

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

overpaid-blogIt’s been all over the press for the past week—CMS paid a lot of money in the form of EHR incentives (Meaningful Use) to providers who did not truly earn them. These inappropriate payments were revealed in a report by the OIG (Office of the Inspector General) that reviewed CMS’s compliance with Federal requirements in the Medicare EHR Incentive Program for eligible professionals from 2011-2014. Although the subject of the OIG’s audit was CMS—in contrast to the audits of providers (pre- and post-payment) that have been conducted by Figliozzi and Company—there are some important implications for providers.

Here are two of the OIG’s major conclusions:

  • 14 EPs (Eligible Professionals), out of a sample of 100 who attested to having met MU one or more times did not actually meet the MU requirements. They either could not support their attestation with sufficient evidence or had errors in their attestation. Affected payments to these providers totaled $291,222. Extrapolating on this data, the auditors estimated that CMS inappropriately paid over $729 million.
  • In addition, 471 payments to EPs who switched between the Medicare and Medicaid incentive programs were incorrectly calculated, accounting for another $2.3 million.

The report recommended that CMS:

  • recover the $291,222 from the EPs who had the unfortunate luck to have been sampled [editorial comment is mine, not the OIGs!] and found to be non-compliant;
  • recover the $2.3 million in overpayments to EPs who switched programs; and
  • try to recover some of the estimated inappropriate payments made to other providers.

It’s likely that CMS will pursue the first two recommendations, but yet to be determined what—if anything—they will do about the third. That said, however, one thing is certain: CMS will intensify its oversight going forward. (This was another of the OIG’s recommendations.) Does this mean you should abandon your plans to participate in MIPS and/or MU (Medicaid program)? Absolutely not! It does, however, imply that it will now be more important than ever to keep full documentation to support everything you submit. And, make sure to keep it somewhere that will survive any future changes in software, hardware, and/or practice staff.

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

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.