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!

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.

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.

The End of MU… Oh, Never Mind!

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

chameleon-315pxAccording to a recent speech by Andy Slavitt, Acting Administrator of CMS, “The Meaningful Use program as it has existed will now be effectively over.” Not surprisingly, the media picked up this news—particularly the word “now”—and ran with it, gleefully proclaiming the “End of MU in 2016,” “CIOs Celebrate End of MU,” “MU on Deathwatch,” etc. It was easy to believe that Slavitt was predicting the demise of MU to be imminent since the stated topic of his talk was “policy areas that will affect the healthcare sector in 2016.” However, in Tuesday’s CMS Blog, Slavitt—writing with Karen DeSalvo—walked his statement back a bit. That said, this is still quite significant news: CMS has formally acknowledged what Slavitt himself referred to as the frustration and burden that physicians have been dealing with since the start of MU.

The key phrase in his statement about MU is “as it has existed.” MU is to be, in Slavitt’s words, “replaced with something better”—i.e., a new and improved version of itself. It is not going away. We already knew that MU had been identified as an integral part of a new program called MIPS under MACRA, the regulations for which are still being written by CMS. MACRA, the legislation that replaces the Medicare Fee Schedule’s SGR calculation, becomes effective in 2017, with a new schedule of payment adjustments (a.k.a. incentives and penalties) beginning in 2019.

Slavitt’s “announcement” was clouded by uncertainty, but was greeted, nevertheless, with great jubilation and high expectations, some of which were dashed by the clarifications published in the subsequent CMS Blog. In his speech, Slavitt had provided little insight into exactly how MU will be restructured. It begged the questions: Will the changes to the requirements be radical enough to be perceived by physicians as “something better?” What will become of the Stage 3 Rule, which is currently undergoing finalization and is due to go into effect in no later than 2018? And, will the MU penalties scheduled for 2017 and 2018 remain in effect or be eliminated? The CMS Blog answered some of these questions, to the disillusionment of many providers:

  • The current law requires that we continue to measure the meaningful use of ONC Certified Health Information Technology under the existing set of standards.
  • We encourage you to look for the MACRA regulations this year; in the meantime, our existing regulations—including meaningful use Stage 3—are still in effect.

Despite the myriad details yet to be determined, what we do know about the future is that physicians will increasingly be rewarded for quality over quantity of care. Therefore, a critical component of the new government programs will be the demonstration and reporting of improved patient outcomes (most likely in PQRS fashion). We can also be confident that MACRA (and any new version of MU it contains) will demand heightened interoperability and patient engagement, and physicians will have to meet requirements that support these goals.

The question of timing notwithstanding, should you be excited about this announcement? I would suggest cautiously so. We are optimistic that the anticipated changes will bring some relief from the unnecessary administrative burdens with which physicians have been struggling and let them get back to focusing on the practice of medicine. But unless concomitant changes are forthcoming on ONC’s side to streamline the excessive EHR certification requirements on the books for 2017/2018, EHR developers and vendors will still not have the necessary time or freedom to focus on innovations that would deliver the efficiencies and clinical benefits that would be of maximum value to physicians and their patients.

As always, SRS will keep you up to date on all developments in this area as they are revealed over the next few months. Please feel free to contact Lynn Scheps, Vice President, Government Affairs, if you have any questions.

10 Crucial Questions to Ask EHR References

5 Star RatingToday, we are used to searching for references for everything from restaurants and hotels, to clothing labels and wearable fitness technology. Whether you are planning a party or searching for a new physician, gathering a handful of reviews can help inform your selection.

Collecting EHR references is one of the most critical steps in the EHR search process. To ensure your reference gathering is as effective as possible, make sure several members of your staff are onboard. If each employee makes a few calls, the interview process will not require a large time commitment from any one of them.

Second, both administrative staff and physicians should call and speak to several of their peers at the reference sites to collect a variety of different perspectives and opinions.

Finally, don’t just call the references provided by the vendors—find other practices using the EHRs you are considering by joining professional society listservs such as MGMA’s and AAOE’s.

Once you’ve collected 10 references of similar size within your specialty from each EHR vendor—along with a few practices that weren’t provided by the vendors—ask each reference these 10 crucial questions:

  1. When did you install your current EHR?
  2. How long was the installation/implementation process?
  3. How would you describe the installation/implementation process?
  4. Was the system as easy to use as it appeared to be during the software demonstration?
  5. How has your patient volume changed?
  6. Approximately how much more time do you devote to entering exam data into your EHR as compared to how you documented exams before you began using this EHR?
  7. What percentage of your exam notes are fully-templated?
  8. Do you like the quality of the exam note generated by your current EHR? Does it represent you well?
  9. How have your patient interactions changed?
  10. Would you recommend your EHR to a similar practice?

Asking these questions will give you a clear indication of whether or not a specific vendor will be able to deliver the success you expect from your EHR implementation.

Keep this “cheat sheet” of reference questions handy throughout your EHR search process. It will prove invaluable and provide you with the information you need to save yourself from a potential mistake.

What are some additional questions you would ask of references?

Patient Engagement: Build a Strategy for Patient Empowerment

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

dr-patient-selfie-42511727_sRemember the days when the provider-patient relationship was centered primarily on the interactions that occurred during a visit? Whether it was in the exam room, over the phone or at the hospital, these were the places where the provider-patient relationship was built. Now, patient care encompasses more than just the traditional office visit and a physician’s bedside manner. A lot more emphasis is being placed on the patients—engaging and empowering them to partner in the healthcare process.

Patient Engagement is a hot topic in healthcare – a quick google search and you’ll come up with countless references to infographics, successful approaches, and tools to help build a patient engagement strategy. You will also find articles that discuss how patient engagement can have positive effects on improved quality of care and patient outcomes. The frameworks vary from simplistic to more complex, but the common theme is partnering with your patients and building ownership of their health and healthcare. Some examples of an effective PE strategy include: providing patient-specific education, making patients’ health information available online, including the patient in developing care plans and coordinating with other caregivers.

With an increased focus on patient engagement and interoperability incorporated in Meaningful Use Stage 2, many of these suggested practices can be accomplished using your EHR. Although many providers are anxiously awaiting the Final Rule Modifying MU Stage 2 in 2015 – 2017 and hoping for lower thresholds on the patient engagement measures like Patient Electronic Access and Secure Messaging, it is safe to say these measures are here to stay and will have increasing threshold(s) over the next few years.

So if there was ever a time to start building or improving upon your engagement strategy – the time is now! Whether you go at it on your own or use your EHR to help accomplish these goals the resources are abundant. What will your strategy include? Maybe you’ve been actively engaging patients for years and have some best practices to share. What helps to empower your patients?