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MACRA Final Rule Is Out – MACRA Monday (on Friday)

Posted on October 14, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

We usually wait until Monday to do our weekly MACRA Monday blog posts. However, today the MACRA final rule dropped and so we thought we’d do MACRA Monday on a Friday. Since the rule just came out this morning, we haven’t had a chance to do much analysis. No doubt we’ll do a lot more analysis, summarizing, etc in the future. For this post, I just wanted to share with you the various places you can go to find the final rule and summaries of the final rule that will be helpful.

The first resource you need is the MACRA final rule itself. Yes, it’s 2398 pages, but remember that CMS is required to respond to the feedback that was given in the proposed MACRA rule. The rule itself is much shorter, but the explanation of the rule is quite long. As Andy Slavitt noted, it’s long in the interest of transparency.

The reality is that most of you will only want to check out the MACRA Final Rule Executive Summary. It’s only 24 pages and should give most people what they need to know about the MACRA final rule. You can leave the 2398 page final rule to the health IT policy wonks.

Along with the executive summary, CMS has put out a new website with resources, education, and tools for the Quality Payment Program (Or as we call it, MACRA). The Education and Tools page has some great resources for those wanting to learn more about MACRA.

If you plan to participate in MIPS, then you’re likely going to use the Explore Measures page. Considering MACRA’s increase in the number of measures, this page will help you navigate through the various measures and decide which measures you’re going to do as part of MACRA.

If you want a higher level look at what CMS did to put together the MACRA final rule, take a second to read through Andy Slavitt’s letter to Clinicians. We might disagree with the details of MACRA, but after reading letters like this it’s hard to argue that Andy Slavitt and his team aren’t listening to providers and healthcare’s feedback on these rules.

That’s all for today. Happy reading this weekend! Over the next months and years we’ll be diving into the details of the program. If you’re reviewing the final rule like us, share any insights or findings you find interesting in the comments. It takes a large community to understand new rules like this.

President’s Message for National Health IT Week #NHITWeek

Posted on September 27, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This week is National Health IT Week. I’m not sure why we need a week for it. Some of us celebrate health IT all year round. That said, at least it’s an opportunity for some people that could impact healthcare IT to take some time to think about it. A good example of this was that President Obama put out a letter for National Health IT Week (Side Note: It’s kind of funny that it’s still a “letter” and not a blog post or Tweet or Snap or something else. It’s interesting how letters keep subsisting in electronic format. Hmm…sounds a bit like healthcare.). Here’s an excerpt of what he said:

During National Health IT Week, we recommit ourselves to improving the health of our citizenry using the breakthrough technologies of our time and reaching for the next frontier of innovation…Because of our collective efforts, 97 percent of our Nation’s hospitals and three-quarters of doctors are using electronic records to care for their patients…These efforts help advance our Administration’s goal of fostering the seamless and secure flow of electronic health information when and where it is needed most. Though there is more to be done to realize a healthcare system that fits each of our needs, I am confident that if we continue working together, we can build a future of greater health and prosperity for coming generations.

While I’d like to think that this week has caused the President to spend some time thinking about healthcare IT, I’m not sure it really makes any difference. Besides the fact that some staffer or ONC itself probably did most of the work for the letter, the letter illustrates to me that the President doesn’t really understand the challenges that face healthcare IT. That’s unfortunate because it means we won’t see any real push to change things from him.

Just to be clear, I’m not saying the President should be an expert on healthcare IT and I’m certain that few people in Congress know much more about it than he does. They’re all likely in the same position the President is in with too many challenges and limited time. They can only dive in deeply on so many of them.

The thing that disturbs me about this letter is that it’s likely the same position that our government has had for health IT since pre-meaningful use. In fact, it’s likely why meaningful use was included so easily in the ARRA stimulus package. Is Health IT good? Well, electronic has been good in every other industry. So, that sounds good. Can you transfer bits and bytes of health data better than paper? Yep! So, EHR should make sharing data easier. Conclusion: Let’s keep doing more EHR and healthcare will be better and healthcare data sharing will happen.

It’s this naivety that’s gotten us where we are today.

My cause for optimism is that the people in government positions over healthcare like Andy Slavitt, Acting Director of CMS, do have a much better pulse on what’s happening in healthcare IT. They understand physician burnout. They understand overwhelming doctors with unnecessary and useless documentation. They understand data blocking and the pressures healthcare organizations face to not share health data. I’m not saying they have all the solutions. These are challenging problems, but I’m hopeful because they do understand these problems much better than most people give them credit.

Will we see much change? The jury is still out. Those at HHS only have so many levers they can pull. I do hope they can find ways to encourage without stifling innovation. I hope they focus on collecting useful data as opposed to possibly useful data. I hope they stop wasting money on EHR certification which provides no benefit and causes a lot of harm and they instead focus on a meaningful EHR interoperability certification.

Most of all, I hope they’re not afraid to focus on one thing that’s extremely valuable and doable (ie. interoperability) and set aside the 100s of other things which have questionable value. Wouldn’t we all rather have CMS do 1 thing really well as opposed to doing 100 things poorly?

Today I focused on some government health IT perspectives. Tomorrow I’ll talk about some of the other healthcare IT trends that get me excited and a few that scare me. Happy National Health IT Week!

Modifications to the MACRA 2017 Reporting Period #PickYourPace – MACRA Monday

Posted on September 12, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

As we mentioned near the start of the MACRA Monday series, many were predicting a delay or at least a modification to the MACRA timeline. While we’re still waiting for the MACRA final rule to come out with the official changes, Andy Slavitt, Acting Administrator of CMS, has announced some of the changes that will be in the MACRA final rule. Here’s the introduction to why they’re making these changes to MACRA (or the Quality Payment Program as they like to call it now):

We heard from physicians and other clinicians on how technology can help with patient care and how excessive reporting can distract from patient care; how new programs like medical homes can be encouraged; and the unique issues facing small and rural non-hospital-based physicians. We will address these areas and the many other comments we received when we release the final rule by November 1, 2016.

It’s comforting to many to know that they hear doctors pleas for help with all the reporting. We’ll see if the changes in the MACRA final rule will be enough.

As part of the announcement, Andy Slavitt said that the MACRA and MIPS program will still begin on January 1, 2017 with payment adjustments (ie. incentives or penalties) being paid in 2019 like we’d noted before. However, CMS now plans to provide multiple options to eligible physicians and other clinicians to avoid the negative payment adjustments in 2019.

There will now be 4 options available:

Option 1 – Test the Quality Payment Program.
For this option, you just have to submit “some data” to the Quality Payment Program and you’ll avoid the negative payment adjustment. Basically, CMS just wants to make sure you’re connected and ready to participate in future years. While you won’t get a negative payment adjustment, you always won’t get a positive adjustment either. It will be interesting to see what the final rule defines as “some data.” I expect it will be pretty minimal.

Option 2 – Participate for part of the calendar year.
This option allows you to submit information for a reduced number of days in 2017. In other words, your performance period could start after January 1, 2017 and you could just do MIPS reporting for part of the year. This would qualify you for a small positive payment adjustment. I’ll be interested to see the details in the MACRA final rule which outlines how much smaller the payment adjustment will be and how it will be calculated.

Option 3 – Participate for the full calendar year.
This option is basically what’s in the MACRA proposed rule. You can take part for the full 2017 calendar year and potentially qualify for a modest positive payment adjustment. CMS suggests that many will be ready for this. We’ll see if that’s the case given the compressed timeline from when the final rule is published and the release cycles of EHR software companies.

Option 4 – Participate in an Advanced Alternative Payment Model in 2017.
It seems that participation in an Advanced APM is the same as the proposed rule. Of course, if you’re participating in an Advanced APM, then you avoid the penalties and don’t have to worry about MIPS. Nothing new there.

It’s no surprise that fewer penalties and looser requirements has been applauded by many in the healthcare community. It’s pretty rare that people complain about a loosening of government regulation and wish they would require more. Personally, I think the changes are a good thing. CMS will still be able to get data from organizations that participate for the full year. Hopefully, they’ll use that to guide any modifications for future years. However, they also aren’t penalizing those organizations who won’t be fully ready in 2017 because of the short timelines.

Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA Quality Payment Program.

CMS Opens Door to Possible MACRA Delay

Posted on July 15, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

In related news to yesterday’s meaningful use REBOOT relief legislation, Andy Slavitt, Acting Administrator of CMS, testified about MACRA before the Senate Finance committee. In his hearing, Senator Orrin Hatch (R-Utah), chairman of the committee commented “Physicians will only have about two months before the program goes live. This seems to be a legitimate concern. Considering the MACRA law does give CMS flexibility as to the start of the physician reporting period, what options is CMS considering to make sure this program gets started on the right foot?”

In response to this Slavitt responded that CMS was open to options such as postponing implementation and establishing shorter reporting periods (both of which were widely requested during the MACRA comment period).

Both Slavitt and Senator Hatch talked about the importance of the MACRA legislation not killing the small practice physician. A delay and shorter reporting periods would be a great start. However, so many small practices have been burned by meaningful use that it might be too late for MACRA. It seems that MACRA is dead on arrival for many physicians based on historical experience with meaningful use and certified EHR. I’m not sure CMS could do anything with MACRA to really stem the tide.

This is reflected in a survey that Deloitte recently did to assess physician’s awareness of MACRA. The survey found that 21% of self-employed physicians and those in independently owned medical practices report they are somewhat familiar with MACRA versus 9% of employed physicians surveyed. 32% of physicians only recognize the name.

Basically, physicians barely even know about MACRA. Although, I’m quite sure if we asked them if they liked the MACRA government legislation they’d all say an emphatic No! (Kind of reminds me of Jimmy Kimmel’s Life Witness News) It’s too bad, because if doctors have already been participating in PQRS and Meaningful Use, MACRA won’t be that bad. Of course, the same can’t be said for those that haven’t participated in either program.

During the hearing mentioned above, Senator Hatch highlighted Andy Slavitt’s comment that “the focus must be focused on patients and not measurement.” Plus, he suggested that more needed to be done in this regard. Andy Slavitt responded that they need to reduce the documentation requirements so doctors can spend more time with patients.

Take those comments for what their worth. They’re hearing the right messages and I think they’re heading the right direction. Let’s hope we see that in the MACRA final rule.

Meaningful Use Relief from New REBOOT Legislation

Posted on July 14, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

John Thune has introduced a new legislation called the Electronic Health Record (EHR) Regulatory Relief Act (S. 3173) to provide some relief to hospitals and eligible providers participating in the Medicare EHR Incentive Program (Better known as Meaningful Use). You can find the legislative text (ie. legalese) and the summary document (ie. readable).

This legislation was written by the “REBOOT members” John Thune (S.D.), Lamar Alexander (Tenn.), Mike Enzi (Wyo.), Pat Roberts (Kan.), Richard Burr (N.C.) and Bill Cassidy (La.) who previously released a white paper on their Health IT concerns.

Here’s a short summary of what the legislation would do:

  • Codify the 90-day reporting period for meaningful use
  • Remove the All-or-Nothing approach to Meaningful Use and set a 70% threshold
  • Increased flexibility in Hardship Exceptions

If I’m reading the legalese right, it also opens the door for the HHS Secretary to allow a 90 day reporting period for MIPS as well. It’s interesting that it wasn’t highlighted in the summary document.

Regardless, these are all changes that will be welcomed by the healthcare community. What I like most about these proposals is that I don’t think any of them will impact how a hospital or doctor was previously planning to use their EHR. At least it won’t impact care in any sort of adverse way. Doctors will still be using an EHR. However, it will provide some reporting relief and will open the door of meaningful use to organizations that wouldn’t have been able to comply previously. Of course, I’m sure there are a few people out there that will settle for nothing less than a repeal of meaningful use completely. I predict that such a thing will never happen.

What do you think of this proposed legislation? Are they enough? Should they be providing more relief? Will this change your meaningful use plans?

Physician Data Paradox

Posted on June 29, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

“[Doctors] are overloaded on data entry and yet rampantly under-informed.”
-Andy Slavitt at Health Datapalooza

This quote from Andy Slavitt at Health Datapalooza has really stuck with me. He calls it the physician data paradox. It’s an ugly paradox and is at the heart of so many doctors discontent with EHR software. Andy Slavitt is spot on with his analysis. Doctors spend hours entering all of this data and get very little return value from that data or the volume of health data that is being captured.

My friend Dr. Michael Koriwchak has made an interesting request. In a recent blab interview he was on he said that CMS should only require the collection of data they’re actually going to use.

My guess is that the majority of meaningful use data would not need to be collected if Dr. Koriwchak’s rule was in place. CMS hasn’t really even collected the data from doctors, so they’re certainly not using it. Some of the principles of meaningful use would still exist like interoperability and ePrescribing, but we wouldn’t be turning our doctors into data entry clerks of data that’s not being used.

Think about the reality of meaningful use data collection: CMS doesn’t use the data. Clinicians don’t use the data.

We’ve basically asked doctors and other medical staff to spend millions of hours collecting a bunch of data that’s not being used. Does that make sense to anyone? You could make the argument that the data collection is creating a platform for the future. There’s some value in this thinking, but that’s pretty speculative spending. Why not do this type of speculative data collection with small groups who get paid for their efforts and then as they discover new healthcare opportunities? We can expand the data collection requirement to all of healthcare once doctors can do something meaningful with the data they’re being required to collect.

In fact, what if we paid docs for telling CMS or their EHR vendor how EHR data could be used to benefit patients? I’d see this similar to how IT companies pay people who submit bug reports. Not using health data the right way is kind of like reporting a bug in the health system. Currently, there’s no financial incentive for users to share their best practices and discoveries. Sure, some of them do it at user conferences or other conferences, but imagine how much more interested they’d be in finding and sharing health data discoveries if they were paid for it.

If we finally want to start putting all this health data to work, we’re going to have to solve the physician data paradox. Leveraging the power of the crowd could be a great way to improve the 2nd part of the paradox.

Government Involvement in Healthcare IT – How Meaningful Use Went Wrong

Posted on June 15, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I have about 150 draft blog posts on EMR and EHR. Most of them are ideas for future posts. Unfortunately, I get so many new ideas, a lot of the drafts remain draft blog posts for long periods of time. I probably should create a better process for tracking my blog post ideas, but this was worked so far. Plus, it’s fun to go back and see what past ideas I had for posts and then think about how things have changed or whether that insight has stood the test of time.

This post is an example of that and the draft blog post contained a tweet that Greg Meyer shared during a #HITsm Twitter chat back in December 2014. Here’s the tweet:

No doubt Greg’s tweet resonated with me back in 2014 and still resonates with me today. In meaningful use, the government got way too deep into the how and caused all sorts of unintended consequences. We’d be in a much better position if the government would have just defined the measures and functions and not how you actually got there.

What’s interesting is that this is more or less what I’ve been hearing from Andy Slavitt in regards to MACRA. I’m not sure CMS has executed this vision well, but it’s at least hopeful that their leader is espousing a similar approach to what Greg describes above.

I’d also point out an insight I believe I first heard from Dr. Michael Koriwchak. He espoused the principle that CMS shouldn’t require the collection of any data which it wasn’t going to actually use. Think about how meaningful use would have been totally different if they’d employed this rule. What value is there to healthcare if we collect a whole bunch of data that’s never actually used to improve care?

Do you think CMS will get this right with MACRA? Share your thoughts in the comments.

Is CMS Listening to Doctors’ Thoughts on MACRA?

Posted on June 10, 2016 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

I have to admit that I have a lot of respect for Andy Slavitt. He’s doing a really hard job as Acting Administrator of CMS and he’s been very vocal and open about his view of what they’re doing and their efforts to listen to those of us in healthcare. I’ve really appreciated his willingness to engage the community on challenging topics. Did you ever see this from previous CMS administrators?

This tweet illustrates Andy’s efforts to really listen to doctors when it comes to MACRA:

This illustrates why I previously wrote that Andy Slavitt was very much in touch with the pulse of what doctors are feeling and experiencing. Although, with that comment I also said that I hoped that the policies and programs they implemented would match that understanding.

I realize that this concept is much easier said than done. Andy Slavitt and his team at CMS are sometimes not able to make changes to things like MACRA even if they know it’s the right thing to do. They aren’t the ones responsible for making the legislation. Their jobs are to implement the legislation. It’s a tough balance which always leaves people wanting.

The only thing awkward about Andy Slavitt’s tweet above is that he says CMS has “trained nearly 60,000.” It’s quite interesting that he views these MACRA sessions as trainings. I thought they were more listening sessions than training sessions, but I guess I was wrong. Certainly you have to train a doctor on the MACRA legislation if you want to get the right feedback from them. So, I guess training and listening aren’t mutually exclusive, but it’s not surprising that many doctors don’t want to be “trained” on MACRA. For some doctors, anything less than a full repeal of MACRA will be less than satisfying and that’s not going to happen.

While you can complain about the way Andy might phrase things in a tweet, I don’t think that’s very productive. Although, I don’t think listening to (or should I say training) 60,000 physicians’ thoughts about MACRA is very useful either if we don’t see that feedback incorporated into the final MACRA rule. This tweet gives me some hope that the feedback has been heard and we’ll see some important changes to MACRA:

When the MACRA final rule comes out, I hope that along with the changes that were made we also get a look into the changes that people requested that CMS was unable to make because of the way the legislation was written. I’m not sure if CMS is allowed to be that transparent, but if we’re going to help push for better legislation it would be great to know which feedback was thwarted by legislation so that doctors can push for better legislation.