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!

MIPS: 5 Things You Can Do Now to Prepare

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

5-things-mips-blogEven though the final MACRA rule is not expected until November 1, 2016, you would be well advised to start putting an action plan in place now. As proposed, the first performance year begins on January 1, 2017, a mere 2 months after the expected release of the Final Rule—you won’t have sufficient time to prepare if you wait until then. Yes, CMS has hinted about a possible delay or a shortened reporting period (in response to numerous concerns expressed in the 4,000 comments to the proposed rule), but you cannot bank on that until it is finalized. There are things you can do to start planning your strategy and improve your chances of success when this first regulatory foray into value-based payment begins:

  1. Focus on 2016 PQRS reporting: Quality reporting carries a 50% weighting next year, which makes it the most important of the 4 MIPs performance targets, (the others being Advancing Care Information, aka MU; Clinical Practice Improvement Activities; and Resource use, aka cost). Take advantage of the next 4 months to improve your quality measure workflow and reporting.
  1. Think about whether to report MIPS as individual physicians or as a group: It’s important to look at your practice’s current MU and PQRS performance as a predictor of which option might be more beneficial. You may already be reporting PQRS as a GPRO—success here makes a strong argument for reporting all categories as a group. (Remember, as proposed, you must report consistently across all 4 MIPS categories.)
  1. Develop workflows to support success: Identify the ACI patient engagement and health information exchange (HIE) measures that are of most interest or relevance to your practice. Analyze and try to enhance the workflows that support these measures. Ask your EHR vendor for a professional services evaluation—they may be able to offer assistance in this regard.
  1. Review the list of Clinical Practice Improvement Activities: Review the list provided in Table H of the Proposed Rule. Are there activities that fit your practice or possibly some that you were considering, even before MACRA?
  1. Evaluate your current technology resources: Is your EHR up to the job—or is it killing your productivity, particularly when you use it to meet the government requirements? If you are not satisfied, now is a good time implement new technology.

The most important step to take now and in the coming months is to keep yourself educated and up to date as the regulations evolve and the start date approaches, (But you clearly know that, since you’re reading this post!) On cms.gov, you will find Quality Payment Program Resources pages. You can also consult your professional societies/academies for specialty-specific guidance or reach out to your EHR vendor for training. I invite you to watch (or watch again) my webinar titled, “MACRA/MIPS: 962 Pages in 30 Minutes”, which is available on demand.

90-Day MU Reporting: Deja-Vu All Over Again!

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

flag-money-stethLast week, in keeping with what seems to have become a mid-year tradition, CMS issued a proposed rule that—amidst its 700-plus pages related to hospital payments—reduces the 2016 MU reporting period from the full calendar year to any 90 consecutive days. (Note that this applies only to providers participating in the Medicare, not Medicaid, EHR Incentive Program, and has no effect on PQRS reporting.) Would it have been better if the announcement had come in a more timely fashion—i.e., at the beginning of the year instead of the middle? Absolutely! But don’t let that keep you from taking advantage of this opportunity.

This is good news for providers who had given up on MU for 2016—or who got off to a slow start on the program this year. Here’s an opportunity to get back in the game and avoid the 2018 payment adjustment (3% or 4%, to be set at the discretion of the Secretary of HHS). It also provides a bit of a breather for those who are successfully demonstrating meaningful use and may be able to identify an already-completed 90-day period during which they met all the requirements. These providers can now turn their attention to preparing for MACRA, which is proposed to be effective on January 1 and in which MU (renamed “Advancing Care Information”) is only one of the four components.

So, what accounted for this change? Is it an indication of a kinder and gentler CMS to come? The CMS Fact Sheet states that CMS is trying to “assist health care providers by increasing flexibility in the program.” Was it in response to the deluge of comments to the MACRA rule that screamed “Help!,” or to the repeated requests for relief submitted by providers, organizations, and members of Congress? Let us know below what you think brought about this change of heart.

Buzzword of the Day: Value-based Payment

ekg-moneyThe buzzword of the day is “Value-Based Payment”, and everyone is talking about the transition from volume to value. Recently, Becker’s—the leading source of cutting-edge business and legal information for healthcare industry leaders—interviewed SRS’ Lynn Scheps and Lester Parada as part of an article exploring this very important subject. The article discusses what “value-based” means, how the recently proposed regulations supporting the implementation of the MACRA legislation will impact orthopaedists, and how EHRs must evolve to facilitate practice success in the future. Read Value-based payments are coming for orthopedics: Are you ready?

Free-Flow Workflow: How Did This Help with Data Collection?

Adam Curran

Adam Curran

Product Marketing Manager at SRS Health
Adam Curran is a Product Marketing Manager at SRS. He oversees marketing intelligence to support the development of strategic marketing plans. Prior to joining the organization, he was a key member of a pharmaceutical software company’s Clinical Development Business Unit, specializing in the clinical data management elements of the drug development lifecycle. He was also the editor for their microsite’s blog. Adam has also held roles at the UK’s National Energy Foundation and Skills Funding Agency.
Adam Curran

data-flow“Being flooded with information doesn’t mean we have the right information or that we’re in touch with the right people” – Bill Gates

We are able to collect a wealth of information today, thanks to technological improvements over the last couple of years. For a long time, specialists struggled to get the most out of earlier EHR solutions due to the limited data available. This was not so much the fault of EHR vendors but rather of the inherent limitations of the technology at the time. Additionally, the first “templated” EHR systems were specifically designed for primary care and family practice doctors. These systems were not suitable to meet specialists’ different data needs and handle a much higher volume. I did a post recently on the evolution of data capture (read it here).

When it comes to submitting meaningful use data to CMS, however, with all this data available, identifying and collecting it generally takes a long time. There are studies that show an increase in the number of physicians who spend more than one day a week on paperwork, and that indicate many physicians still feel that EHRs do not save time. Although this technology is allowing practices to comply with meaningful use requirements, the cost seems to be too high.

What are we seeing here? Physicians are spending more time capturing data due to regulations, and this is taking up the time available to see patients. How did we get to a point where the physician is spending more time staring at the screen than looking at the patient? I’m not a doctor, but I can imagine that they went into the profession to actually help people as much as they can, so more face-to-face time with the patient is the end goal here.

What is the solution to handling this volume of data? Certainly not reducing the amount of data—it would be hard and time-consuming to distinguish which data to get rid of. The solution must focus on making it quicker to handle this data. This is where free-flow workflow comes into play. Rather than having to go through the laborious process of submitting the data to each application, it essentially reduced the repetitive steps involved, thereby streamlining the submission of data.

This big time saver helps to alleviate the pain, but there are still limitations. Fortunately, we are now at a point where we can get a workflow that isn’t just free-flow, but also adaptive. To find out more about this development and other future trends, you can read our white paper.

MACRA and MIPS: They Promised Simpler!

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

open-book-formulaThe proposed MACRA rule is here. With the goal of changing the way physicians are paid, this rule proposes how CMS intends to move toward increasingly rewarding value—meaning high quality care at a cost-effective price—over volume.

CMS claims that MACRA will simplify life for providers, (although I’m a little suspicious since it took 962 pages to explain the “simplification”). However, there is no question that the world is about to change. These proposed regs are scheduled to be finalized in November and then be effective on January 1, 2017—a rather ambitious schedule which leaves little time for planning your approach to compliance.

While I haven’t read the entire rule yet, MACRA—Medicare Access and Chip Reauthorization Act—provides two paths for physicians and other clinicians. In the long-term, APMs (Alternate Payment Models, like ACOs) will be a popular route—higher risk/higher reward—but for now, most physicians will participate in the MIPS (Merit-Based Incentive Program) option. So let me provide a few teasers about MIPS, as currently proposed:

  • If you expected an end to Meaningful Use, PQRS, and the Value-Based Payment Program, you will be disappointed for certain. MIPS just changes the names, rolls them up into one program, and adds (yet another) set of required activities.
  • Providers will be scored on a 100-point scale and compared to other providers—this year’s weighting would be 25% MU-type measures, 50% quality measures, a la PQRS, 10% cost, and 15% Clinical Practice Improvement Activities. (The rule spells out how a provider’s score is calculated and the payment adjustment is determined, but you might need an advanced math degree to follow that discussion!)
  • MU is now “Advancing Care Information”. It will have fewer required measures (proposing to eliminate CPOE, CDS, and multiple Public Health reporting requirements), no longer be all or nothing, and will provide some choices to clinicians for how they demonstrate success. CQM reporting will not be part of this component.
  • Quality measure reporting (like PQRS) will be the bulk of the score, but only 6 measures will be required. Like under the Value-Based Payment Program, performance will count, i.e., impact the provider’s score.
  • Assessment of cost will be done by CMS—providers won’t have to report anything. This is similar to how CMS currently attributes a cost factor to providers in calculating the V-BPM.
  • The new category, Clinical Practice Improvement Activities, offers providers a choice of approximately 90 activities from which to choose to earn points in that category.
  • MIPS would be reportable as an individual provider or as a group.

Stay tuned to EMR StraightTalk for more in-depth analysis of MACRA in upcoming posts. We welcome your initial comments.

 

Top 5 Observations at HIMSS16

Adam Curran

Adam Curran

Product Marketing Manager at SRS Health
Adam Curran is a Product Marketing Manager at SRS. He oversees marketing intelligence to support the development of strategic marketing plans. Prior to joining the organization, he was a key member of a pharmaceutical software company’s Clinical Development Business Unit, specializing in the clinical data management elements of the drug development lifecycle. He was also the editor for their microsite’s blog. Adam has also held roles at the UK’s National Energy Foundation and Skills Funding Agency.
Adam Curran

HIMSS16

With a conference that draws over 50,000 attendees, 1300+ vendors, 300 educational sessions, and interesting keynote speakers, there is always plenty of food for thought. So much so that it can take a while to really assimilate all the information and process it into key observations.

Our team has just returned from the show, so I just wanted to quickly share our top 5 observations at HIMSS16:

  1. Value-based payments: There was much discussion on the shift to value-based payment. The MACRA/MIPS regulations are expected in the spring, which could mean as early as March or as late as June, with the Final Regulations mandated to be published by November 1. While the goal of MIPS is to simplify life for providers (by rolling up all the various current programs into one streamlined program), it’s a good bet that things will get more complex before they get easier. All of this begs the question: How will physicians be ready to comply beginning on January 1, 2017?
  1. Interoperability: No surprise that everyone was talking about this! This was reinforced when big-name healthcare technology providers promised to use standardized APIs to make access to patient information easier. Interestingly enough, this also ties in with the HHS wanting to expand its oversight of electronic health record vendors. The proposal they released on March 1 would allow the agency to review how certified health IT products interact with other products, with the aim to prevent data blocking, and to review certified HIT vendors if required (and even to take away their certification if necessary!) The comment period for the ONC rule ends on May 2.
  1. Population Health: This is increasingly becoming one of the top buzzwords at this show. More and more people are talking about it, but there does not seem to be a clear definition about what value this brings. After discussions with different attendees and vendors, it was clear how unclear it was: everyone was providing different answers. The term population health is much more widely used than it was back in 2003 when it was defined by Greg Soddart and David Kindig as “the health outcomes of a group of individuals, including the distribution of such outcomes within the group.” The management element is using the aggregation of patient data to devise actions that improve both clinical and financial outcomes. But what data should be used, especially when it comes to specialty practices? Clearly this is something that needs to be defined to ensure we are getting real value from these solutions.
  1. HHS and CMS: There was an interesting session with Karen DeSalvo (National Coordinator for HIT, Asst. Secretary HHS) and Andy Slavitt (Acting Administrator, CMS) where the barriers to data sharing was discussed, and 3 commitments were announced:
    1. Consumers will be able to easily and securely access their electronic health information and send it wherever and to whomever they want.
    2. Providers will share information for patient care with other providers and will refrain from information blocking.
    3. The government will implement national interoperability standards, policies, and practices and will adopt best practices related to privacy and security.

This further reinforces the 2nd observation in this post about HHS wanting to expand its oversight of electronic health record vendors. This session also brought up an interesting point about data blocking; DeSalvo pointed out that a year ago there were a “host of organizations who denied that blocking even was happening,” and now these same groups are “willing to publicly say that they want to engage in something now they’ve acknowledged info blocking can exist.” Hopefully, these same groups will follow with their pledges. As Slavitt advised, “I strongly encourage you to recognize those that don’t [live up to their pledges]” (FierceHealthIT).

  1. EHR collides with NFL: Denver Broncos quarterback Peyton Manning, the reigning Super Bowl Champ, gave a speech at the show thanking the health IT community. For a man who has gone through 3 potentially career-breaking, neck surgeries, I think it is fair to say he can “fully appreciate the value of information systems to keep hospitals functioning.” A physician joined Manning on stage, discussing the NFL’s EHR system and their portals, allowing players access to their medical details. Manning put it like this: “Football is a game. Revolutionizing healthcare is a mighty endeavor.” He also mentioned that leaders in any field need to evolve to match circumstances (HealthcareIT News).

Of course, HIMMS is a huge show where other topics were discussed too, such as patient engagement and RCM. The points mentioned above were only our key takeaways from it. We want to understand the latest regulations and trends, and how these will impact healthcare specialists. What were your key takeaways?