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

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

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.

Frictionless Product Delivery

upgradeWhat if I told you that software deployment could be simple? You’d likely accuse me of smuggling Kahlua into my morning coffee. It seems like only yesterday that installations required CDs and that every workstation needed hands-on attention. Once you got to a particular unit, you would be greeted with an array of screens and prompts that could conceivably require hours of monitoring. Allow me to assure you that those days are over!

The term “innovation” is usually applied only to product development, but at SRS, we have pushed this approach to all facets of what we do, including procedures and processes. One of our many innovations this year has been the incorporation of a software deployment tool, which silently installs applications without user interaction.

While I would love to take all of the credit for this major advancement, I can’t. We first heard about it during our IT Round Table collaboration session at our User Summit last year when we were discussing the tools IT professionals use for software, patches, and file deployments across their infrastructure.  All were pleasantly surprised by the ease of use, consistency, reliability, and advanced options offered by this software deployment tool, and they all agreed that it was much more reliable than Group Policy deployments and other well-known software deployment tools on the market. We took this feedback and did our homework.

How does this Software Deployment Tool benefit you?

  • Quick and easy deployments – only one resource needed to create and deploy a package across multiple sites without any user interaction
  • Deployments scheduled at your convenience
  • Detailed report provided in real time during and after the deployment is completed
  • No prior technical knowledge required

In some cases, the workstation deployment time of an SRS upgrade has been reduced from 3.5 hours to 20 minutes. That is an outstanding 90% improvement! A simple adjustment to your process can have a dramatic impact on both the time and cost spent in the deployment process.

You must be wondering, “There has to be a catch!” I assure you, there isn’t! Perhaps the best part is that there’s no need to review a complex manual. At SRS, we provide training and testing, and have confirmed that non-technical users can configure the deployment and re-use it without our assistance—it’s that easy!

Whether your focus is software development or deployment, or sales or marketing, innovation designed to remove friction will always lead to increased efficiencies and better results!

The Right Tools for Relevant Results

surgical-tools-315pxThere is discussion in the industry about the effectiveness of healthcare information technology (HCIT) solutions. And so there should be; although we have seen improvements in HCIT solutions, a significant number of physicians are not happy with their current systems. Perhaps it is because some vendors feel that they know what’s better for their practice, and build the system around their vision at the expense of how the doctor likes to do things. Or maybe it’s because vendors sell practices solutions that aren’t specialized to their requirements—leading to complexity, fatigue and frustration. In either case, doctors are forced to use tools that are inappropriate to their needs and slow them down.

It’s not rocket science: doctors want tools that help them do their job effectively. Like the stethoscope—it’s one of the oldest medical tools still in use today, but it continues to perform an essential task, even in an era of high tech, and there is nothing complicated about it. Although it was originally invented to spare a young physician the embarrassment of putting his ear directly up against the chest of a young woman, it turned out to have enormous diagnostic value. Because of that, the stethoscope quickly caught on with other doctors.

Another good example is molecular breast imaging (MBI). Mammography was a good way to detect breast cancer, but MBI turns out to be three times more effective at finding tumors in dense breast tissue. MBI is simply a tool that has produced better results.

What about laser surgery? Developed at first for eye and skin surgery, it has expanded its range to include different medical and cosmetic procedures, from cosmetic dermatology to the removal of precancerous lesions. Laser surgery allows doctors to perform certain specific surgeries more safely and accurately—again, a new tool that provides better results.

When it comes to HCIT solutions, however, the reception has been decidedly less enthusiastic. Maybe that’s because, in contrast to the examples above, it hasn’t been clear what the purpose of HCIT solutions actually were. To help doctors collect data on patients, or to help administrators collect data on doctors? To make practices more efficient, or to simplify the government’s monitoring of public health? Without a clear task to perform, it’s not surprising that HCIT solutions have produced mixed results. It’s hard to assess the value of a tool when you aren’t sure what it is supposed to do.

It turns out that, like the stethoscope, electronic health record solutions were a tool designed for extra-diagnostic reasons, and then later repurposed. However unlike the stethoscope, the adoption of EHRs has been driven not by doctors who found them helpful, but by hospitals, insurance plans, and government agencies who sought to control skyrocketing costs and standardize healthcare. This disparity has been an underlying cause for ineffective workflows within the systems. And even when EHRs were designed with physicians in mind, they were designed for primary care physicians, leaving the specialist community underserved.

What is clear is that, when an HCIT solution is designed with the primary purpose of helping doctors, the industry does see value in them. According to the latest Black Book survey of specialty-driven EHRs, 80% of practices with specialty-distinctive EHRs affirm their confidence in their systems. The same survey reported that satisfaction among users who had switched to specialty-driven EHRs has shot up to 80%. And finally, 86% of specialists agreed that the biggest trend in technology replacements is specialty-driven EHRs due to specialist workflow and productivity complications.

The statistics show what we already knew; doctors want the technology and tools that give them relevant results. Like earlier great medical inventions, HCIT can play a vital role too. One positive development is that EHRs, like the lasers used in surgeries, have evolved to serve a variety of specific purposes. Just as there isn’t a single type of laser that is used by both ophthalmologists and dermatologists, EHRs are increasingly specialty specific.

This means that specialists are no longer forced to use systems designed for primary care physicians that collect every piece of data that every type of doctor might possibly need. That sort of all-inclusive data collection doesn’t lead to better results; if anything, too much data causes unnecessary clutter, making analysis more difficult. What is crucial is having more RELEVANT data. Specialists need EHRs that collect the data that is relevant to them, and only the data that is relevant to them. They need an HCIT solution that is driven by their specialty, that respects their workflow, and that has the flexibility to handle their practice’s unique requirements.

To find out more about developments in HCIT solutions that are improving patient care, check out our latest whitepaper, “Healthcare: How Moving from Paperless to Frictionless is Improving Patient Care”.

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

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.

The ABCs of APIs

APIIt seem that everywhere you look in today’s tech industry, you hear the term APIs, and healthcare IT is no exception. Healthcare has recently joined the frenzy by promoting emerging interoperability standards like FHIR. Regulators believe that APIs will support this interoperability so much that APIs are included in meaningful use Stage 3. So, you might now be asking, what are APIs, and why are they so important?

In the simplest terms, APIs are a doorways that allow developers to create bridges between different applications. API stands for Application Programming Interface. APIs are sets of rules that govern how one application can communicate with another. APIs do all this by “exposing” some of a program’s internal functions to the other developers in a limited capacity. This makes it possible for products to share data and take actions on one another’s behalf without requiring developers to share all of their software product’s code.

APIs have been around for decades, so why all of the publicity now? Over the last 10 years companies have started to make their APIs publically available, which has been a catalyst for the spin-off of new business models, innovative solutions, distribution channels, and synergies between business partnerships.

A recent example of this can be found with your smart phones. What do you think fueled the recent app revolution? If companies like Apple and Google did not provide APIs, app developers would not be able to use the functionality found on your phone. Ever wonder how SnapChat has access to your phone’s camera? You guessed it, APIs!

In the end, APIs are a wonderful tool that provides you with flexibility and complete control over your healthcare IT ecosystem.

Now that you know a bit about APIs, how do you see your organization leveraging them in the future?

OBSERVATIONS FROM AAOE 2016

alcatrazAAOE was nothing short of amazing—and not just because the show took place in beautiful San Francisco. In fact, what happened inside the expo halls rivaled many of the sights of the City by the Bay.

As always, attendees were excited about the opportunity to network, learn from industry experts, and be inspired by the keynote speakers. The exhibit hall was crowded, giving us a chance to meet new AAOE members along with spending time with old friends and valued clients. The majority of orthopaedic executives we spoke with were concerned with the same challenges: How do they

  • remain profitable in a value-based world?
  • collect more data without being slowed down?
  • unravel the complexities of regulatory compliance?
  • demonstrate the value of their services through analytics and outcomes?

This made the introduction of our new patent-pending Smart WorkflowsTM Data Platform a big hit. More than simply our latest release, this revolutionary technology helps high-volume specialists bust out of the cage of traditional data capture and practice medicine the way they believe is best. For some, that is as liberating as escaping from Alcatraz itself.

How can an HCIT solution provide such freedom? By putting specialists back in charge of the data capture process instead of allowing them be held hostage by it.  The Smart Workflows Data Platform is designed to capture relevant data at the point of care—based on role, specialty, or practice requirements. In other words, it lets the specialists decide when, where, and by whom data should be collected. The result? Dramatic increases in productivity and efficiency, and an enhanced ability to focus on patient care rather than data input. In addition, Smart Workflows gives specialists the power to determine exactly which discrete data points are relevant to their practice, and to change those data points if and when desired. This eliminates the risks of being locked into one system in a constantly changing regulatory and compliance landscape.

Orthopaedists at AAOE didn’t have to take our word for it—as they visited our booth, they saw first-hand the difference Smart Workflows can make in their practices, and it felt good to see the reactions of physicians and executives as they learned more about Smart Workflows. The platform is the first major achievement of our client-collaborative development process, which makes it a significant leap forward, but it’s also just another step by SRS in helping to prepare our clients for success, both now and in the future.

Of course, we are more than just a technology company, as many AAOE attendees learned when they heard our own Lynn Scheps unravel the complexities of MACRA/MIPS. One of the foremost experts in the industry, Lynn is constantly diving into the ever-changing rules surrounding compliance. Her knowledge helps inform our updates from a regulatory standpoint, and she also provides our clients the human guidance they need to ensure their compliance.

A lot has happened since my last blog post. At AAOE, we were finally able to share the latest breakthrough innovation we’ve been alluding to for months. I was truly proud to unveil our Smart Workflows Data Capture Platform. I hope that, like a lot of the AAOE attendees who stopped by our booth, you are ready to unshackle yourself from the cognitive-data burden that has been dragging you down and coming between you and your patients. If so, we’ve got the key