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QPP (Quality Payment Program) 2019 Changes, Medicare Telemedicine Reimbursement, and Physician Fee Schedule E&M Changes

Posted on July 12, 2018 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.

Today, CMS came out with some big changes as part of the 2019 Physician Fee Schedule and proposed rule for the QPP for 2019. These are some of the biggest efforts I’ve seen to try and change what Medicare has been doing for a while.

CMS has put together a fact sheet on the 2019 Physician Fee Schedule proposed rule. Plus, you can also view the fact sheet for the 2019 Quality Payment Program (QPP) proposed rule. If you like all the details, you can find the full rule for both the 2019 Physician Fee Schedule and QPP 2019 (1473 pages) on the Federal Register.

That’s a lot of information and changes to process, but here are some initial thoughts. While what CMS and HHS are saying in their announcement is directionally good, the devil is always in the details. Here are a few of the highlights that could have a big impact on the healthcare IT and EHR world.

E/M Documentation Requirement Changes
The biggest change in this announcement is the change in E/M coding requirements. As part of CMS’ goal to streamline E/M documentation requirements, they’ve proposed some of the biggest changes to E/M since 1997. The one that will likely be talked about most is the opportunity for providers to bill Medicare using “medical decision-making or time.” Here’s a description of the change:

To improve payment accuracy and simplify documentation, we propose new, single blended payment rates for new and established patients for office/outpatient E/M level 2 through 5 visits and a series of add-on codes to reflect resources involved in furnishing primary care and non-procedural specialty generally recognized services. As a corollary to this proposal, we propose to apply a minimum documentation standard where Medicare would require information to support a level 2 CPT visit code for history, exam and/or medical decision-making in cases where practitioners choose to use the current framework, or, as proposed, medical decision-making to document E/M level 2 through 5 visits. In cases where practitioners choose to use time to document E/M visits, we propose to require practitioners to document the medical necessity of the visit and show the total amount of time spent by the billing practitioner face-to-face with the patient. Practitioners could choose to document additional information for clinical, legal, operational or other purposes, and we anticipate that for those reasons, they would continue generally to document medical record information consistent with the level of care furnished. However, we would only require documentation to support the medical necessity of the visit and associated with the current level 2 CPT visit code.

There are other changes to E/M that could be a big deal as well including having providers focus their documentation on what’s changed since the last visit as long as they review and update the previous information. Plus, providers can now just review and verify the information entered by ancillary staff or the patient rather than having to re-enter it.

The goal is quite clear. CMS is trying to battle against the bloated notes that are getting generated by EHRs today to justify a certain billing code level. Doctors will no doubt celebrate this as most doctors describe notes from their peers as awful and difficult to use because of all the note bloat. I don’t know how many times I heard from my medical billing friends at AHIMA that it doesn’t matter what’s actually done if it’s not documented. With the changes mentioned above, CMS is looking to change this.

Of course, EHRs aren’t going to be able to change their interfaces overnight. The new E/M changes are going to take a while to incorporate into EHR software. Plus, we’ll have to see how the non-Medicare payers react to these changes. If they don’t follow Medicare’s lead, that puts the EHR vendors in a tough position. We’ll have to see how that plays out.

Many doctors complain about hating their EHR software. I’ve long argued that the EHR is just the whipping boy for doctors’ ire. What doctors really hated was the crazy billing documentation requirements that were reflected in the EHR. If the changes above go far enough, maybe we’ll finally see if the EHR vendor really is to blame for provider burnout. However, as I mentioned, it will take some time for this to happen.

Medicare Telemedicine and Telehealth Reimbursement
The next biggest thing in today’s announcement was Medicare’s plans to reimbursement for what we would call Telemedicine or Telehealth services. 2 G codes (HCPCS code GVCI1 and GRAS1) were announced that seem like they could present a lot of opportunity for healthcare IT companies to finally get paid for the services they can provide:

Brief Communication Technology-based Service, e.g. Virtual Check-in (HCPCS code GVCI1)

Remote Evaluation of Recorded Video and/or Images Submitted by the Patient (HCPCS code GRAS1)

Practitioners could be separately paid for the Brief Communication Technology-based Service when they check in with beneficiaries via telephone or other telecommunications device to decide whether an office visit or other service is needed. This would increase efficiency for practitioners and convenience for beneficiaries. Similarly, the Remote Evaluation of Recorded Video and/or Images Submitted by the Patient would allow practitioners to be separately paid for reviewing patient-transmitted photo or video information conducted via pre-recorded “store and forward” video or image technology to assess whether a visit is needed.

Travie Broome offered some interesting insights into these codes:

CMS also proposed a number of CPT codes for “Chronic Care Remote Physiologic Monitoring” and “Interprofessional Internet Consultation” as follows:

We are also proposing to pay separately for new coding describing Chronic Care Remote Physiologic Monitoring (CPT codes 990X0, 990X1, and 994X9) and Interprofessional Internet Consultation (CPT codes 994X6, 994X0, 99446, 99447, 99448, and 99449).

The also proposed adding HCPCS codes G0513 and G0514 for Prolonged preventive service(s) which seems to include ESRD (end-stage renal disease) patients who receive dialysis at home and mobile stroke units.

QPP (Quality Payment Program, better known as MACRA and MIPS) Changes
I have to admit that the changes to the QPP program didn’t feel nearly as substantial. The QPP 2019 Fact Sheet seemed short on details and I haven’t had a chance to fully digest the full rule. A few highlights though:

  • 2019 QPP will remove the MIPS process-based quality measures
  • MIPS Expands to PTs, OTs, CSWs and clinical psychologists (which was required by law)
  • It will overhaul the “Promoting Interoperability” category (pretty generic and haven’t figured out what this really means, but they say it will focus on interoperability, imagine that!)
  • The Promoting Interoperability scoring has changed and so has some of the weighting, but nothing major
  • Many of those excluded from MIPS in 2018 can opt in to participate if they want in 2019
  • $500 million pool is available for exceptional performance (whith is now at 80 points vs 70 in 2017)
  • Must use a 2015 Certified EHR (officially a 2015 Edition CEHRT)

Those are some of the big changes I saw offhand.  I’d suggest that this is mostly business as usual for the most part.  Significant if you’re in the MACRA and MIPS weeds, but isn’t likely going to change your MACRA and MIPS strategy.

One change I’m still processing is this one:

Changing the application of MIPS payment adjustments, so that the adjustments will not apply to all items and services under Medicare Part B, but will now apply only to covered professional services paid under or based on the Physician Fee Schedule beginning with 2019, which is the first payment year of the program.

Does this change the analysis that Jim Tate did previously that MIPS Penalties (and incentives for that matter) included Medicare Part B drugs? Sounds like it to me. If I’m reading it right, this change means that the penalties will be less for those getting penalized, but the payments will be less for those participating in the program as well. Not a good thing for a program that already has incentive problems. Is that right or am I reading it wrong?

On that note, this explains why the final rule is 1473 pages long. Time to do some reading of the final rule and see what all the experts find as they analyze it. Let us know what we missed in the comments or any analysis of this that we got wrong. We can all learn what this means together.

Plus, remember that this is just the proposed rule and CMS even asked for comment on if it should go into effect in 2019 or 2020. I encourage you all to provide your feedback on the proposed rule so it can be improved when it goes final.

How Are Ambulatory Practices Going to Compete with Health Systems?

Posted on July 9, 2018 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’ve all seen the stories about the explosion of data and the way healthcare is getting more personalized. However, David Chou recently pointed out how the data is one thing, but figuring out the role everyone plays in your healthcare organization is just as important as the data itself. It gets complex quickly as this graphic David shared shows:

This is a great graphic of the healthcare analytics roles and responsibilities that will be needed to make the personalized medicine future a reality. Plus, it will be key to getting a lot of the value out of our past EHR investments. Many hospitals and health systems already have these roles filled or are working to have them filled. We’ve seen this first hand when we see data jobs being posted to our healthcare IT job board.

While this work is extremely exciting and shows a lot of promise, I imagine a graphic like the one above is just completely overwhelming to consider for a small ambulatory practice. Even a large group practice would likely find the above graphic challenging to consider in their relatively small healthcare organization. How can they compete with a large health system with that kind of complexity? Do graphics like the one above just provide one other illustration of why small practices are going to soon be extinct?

I don’t think so and I hope not. However, graphics like the one above do illustrate the tremendous challenges that ambulatory practices face when they don’t have a massive health system behind them. What’s the path forward for smaller practices then?

The first thing to remember is that even though a health system is large, it doesn’t mean it’s going to do things well. In fact, it’s easy to argue how large organizations are much less efficient. It’s not hard to see how a large health system will focus all of their analytics work on the acute care environment and leaves out ambulatory practices. Smaller healthcare organizations are going to have to use this to their advantage.

While it’s unlikely that ambulatory practices will do all of the healthcare analytics work on their own, it is possible for ambulatory practices to tap into third party vendors that do the work for them and hundreds of other ambulatory practices. Smaller healthcare organizations partnering with corporate and entrepreneurial vendors is going to be the best way for these healthcare organizations to compete with the large health system. In fact, it’s a huge opportunity for them to show why patients should visit their practice instead of the large health system.

One thing that’s holding these efforts back is EHR vendors’ decision to close the doors to outside vendors. There are a few EHR vendor exceptions and areas where every EHR vendor is more open (ie. labs, pharmacy, etc), but it won’t be enough going forward. My friend Jeremy Coleman recently described why in this series of tweets:

I don’t see any healthcare future where centralization will survive. Sure, it will put up a good fight for a while, but the number and variety of applications that are coming out in healthcare are going to be so varied and dramatically important for doctors to incorporate into the care they provide that EHR vendors won’t have a choice but to create APIs that facilitate all of these applications.

An EHR vendor that embraces this approach is going to be essential for every ambulatory practice. Eventually, ambulatory practices will be stuck with the need to switch EHR systems or sell to the health system (which generally means switching EHR systems too). However, an ambulatory EHR that provides an open ecosystem for the latest and greatest in health IT will allow ambulatory practices to thrive even against the much larger health systems.

Early Lessons from the Front Lines of Value-based Care: How One APM Has Impacted Community-Based Oncology Practices

Posted on June 11, 2018 I Written By

The following is a guest blog post by Dr. Charles Saunders, CEO, Integra Connect.

The Oncology Care Model (OCM) – an alternative payment model introduced in July 2016 by the Center for Medicare and Medicaid Innovation – launched with the ambitious goal to further delivery of higher quality, more coordinated cancer care at a lower cost. Participants include 184 practices representing approximately one-third of community oncologists in the US. They receive a so-called “MEOS” (monthly enhanced oncology services) payment of $160 per beneficiary per month for the duration of a qualifying 6-month chemotherapy period, plus the opportunity to earn a share of savings if they exceed a target threshold. In return, oncologists are expected to take on increasing accountability for patient outcomes and well-being, while also generating sustainable cost savings across all co-morbidities and care settings, into the patient home.

OCM Performance Period 1 Results Exposed an Unexpected Misalignment   

As part of the OCM program, CMS tracks practices during 6-month intervals – so-called “performance periods” – then shares results back about one year later. In February 2018, practices participating in the OCM program received visibility into Performance Period 1 (PP1) data, including savings achieved, aggregate quality score, and effectiveness of identifying eligible patients. While most practices were unsurprised by their performance scores, many did not anticipate the extent to which CMS would recoup MEOS payments that it deemed paid in error. The most common scenario involved patients with co-morbidities who, while receiving chemotherapy and related services, also visited other providers regularly. Therefore, the oncology practice did not represent the required plurality of E/M codes for that beneficiary. It was not uncommon for practices to be asked to return up to 30% of the sum they had been paid – a major financial hit.

Lack of Data Hinders Practices’ Ability to Accurately and Proactively Identify Beneficiaries

In May 2018, practices received their Performance Period 2 (PP2) Attribution Lists, which summarized which CMS beneficiaries met OCM eligibility criteria, which episodes were attributed to each respective practice, and episode start dates from January 1, 2017 through June 30, 2017. Unfortunately, because there is a significant lag between actual Performance Period and delivery of CMS findings – delayed up to nearly a year after each performance period has ended – OCM participants were unable to retroactively apply PP1 learnings to PP2.

Why is this especially problematic? Practices are faced not only with MEOS recoupments for erroneous payments but, with only a 1-year window to submit claims, are often unable to bill in full for patients who were missed. Indeed, there are many opportunities to miss appropriate patients, as practices needed to have an accurate view of: 1) all beneficiaries; 2) those with a qualifying diagnosis; 3) those with a new chemo episode; 4) those not only prescribed an oral agent, but those who subsequently filled it; 5) those not in a hospice; and more. Given all the dimensions to track and measure, practices without advanced tools face delivering enhanced services that they cannot correctly bill for.

Best Practices from Community-Based Oncology Practices Include Robust Data

What best practices arose to get attribution right? A vanguard of OCM practices realized that they would need to take proactive steps to enable near real-time visibility into their patient populations, embracing the tenets of population health management. Below is an example of the best practices adopted by several of these community-based oncology practices:

  • Increased transparency into oral chemotherapies: Existing practice protocols did not open an episode when oral agents were prescribed, since there was no in-office administration. To address this, the practice introduced a rule-based algorithm to identify all OCM eligible patients, including those who had been prescribed orals. In addition, they enlisted a combination of automated and personal follow-ups to validate qualification and ensure orals had been filled.
  • Avoidance of duplication: To identify missed billing opportunities while also reducing the risk of duplicated claims, practice leadership invested in a robust analytics tool that enabled personalized queries at the patient level. These reports compared eligibility against their practice management report to identify gaps, from unpaid and unbilled to denied.
  • Targeted patient intervention: To balance the practice’s financial and clinical objectives while optimizing OCM performance, the practice introduced complex care management services and employed a series of triage pathways. This approach ensured engagement with attributed beneficiaries and decreased avoidable high-cost events among at-risk patients, such as inappropriate ER visits and inpatient stays.
  • Optimized treatment choices. As part of its commitment to ensure each patient received the most effective treatment for his or her disease, the practice provided increased transparency around the availability of equally effective generic or biosimilar drugs. They also supported better end-of-life planning for patients facing second or third-line therapies not expected to provide any clinical benefits, but that could significantly degrade remaining quality of life.
  • Continuous performance improvement: To track the effectiveness of these quality improvement initiatives, the practice leveraged its analytics tool to monitor resource utilization and care management performance, then intervened to address outliers in real-time.

In short, to optimize performance under the OCM, practices are beginning to leverage the data to which they already have access – both clinical and financial – to risk-stratify their patient populations; identify OCM eligible patients; and gain near real-time visibility into quality and cost performance. Practices are also investing in better data integration and analytics that enable rules-based identification of eligible patients.

Population Health Analytics Help Practices Be Proactive and Succeed Under the OCM

Oncology is on the forefront of value-based care adoption and these early experiences from the OCM have provided a guide for other specialties. Based on their early results, what has come to the forefront is the need for a combination of comprehensive data management and robust analytics, coupled with the principles of population health management, which enable practices to step up and take control of the cost and quality for their attributed populations.

Meaningful Use Becomes Advancing Care Information Becomes Promoting Interoperability – MACRA Monday

Posted on May 7, 2018 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 (QPP) and related topics.

I’m quite sure you’ve all seen the news coming out from CMS about the name change for the various Medicare EHR Incentive and MACRA programs. I decided to not dive into it in depth here since so many organizations are already doing it. Plus, this is just the proposed rule. However, if you want some light reading, here’s all 1883 pages of the Promoting Interoperability proposed rule.

The name change of Meaningful Use/Advancing Care Information to Promoting Interoperability is an interesting way for CMS to signal what they want these programs to accomplish. It’s always been clear that ONC has wanted to find a way to promote interoperability. Now they literally have a program that will work to drive that goal.

I’ll admit that I’ve been a fan of this idea since May 15, 2014 when I suggested that ONC and CMS blow up meaningful use and just focus it on interoperability. It only took 4 years for them to figure this out.

While I still think this is directionally an interesting way to go, I’m afraid that the current programs aren’t a big enough incentive for CMS to really move the needle on interoperability. Plus, can CMS really create a rule that would push effect interoperability? I’m skeptical on both counts.

What’s interesting is that CMS could really push interoperability if it wanted. It could just say, if you want to get paid for Medicare, then you have to start sharing data. No doubt there are some complexities to this idea, but if CMS is really serious about promoting interoperability, that’s what they’d really do. That would move the needle much better than thousands of pages of rule making that won’t cause doctors and healthcare organizations to change.

What are your thoughts on the proposed rule? Were there big pieces of it that you saw and you think others should be watching? Are these changes going to relieve doctors of the massive reporting burden they should today? Please share your thoughts in the comments or on Twitter with @HealthcareScene

Potential 2015 Edition EHR Certification Logjam

Posted on March 23, 2018 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.

If you’ve read these blogs for any amount of time, you know how I feel about EHR certification (Not a fan!). I think EHR certification has wasted a lot of EHR programming cycles and in many ways killed EHR innovation that would have occurred without it. That said, EHR certification is still a cost of doing business given the current regulations.

My friend Jim Tate from EMR Advocate described it even better:

Certification has become embedded in the evolving field of healthcare technology. Whether it is MACRA/MIPS, recognition of Medical Home status, or the requirements of a Request for Proposal (RFP), there is an ongoing need for vendors to achieve and maintain certification of their products. The ONC certification system may contain some flaws, but it is the cost of doing business in this domain. If a vendor does not achieve ONC Certification their business model is at great risk.

Jim and I have had many conversations about EHR certification. While we might disagree on the value of EHR certification (or lack therof), we both agree that EHR certification is embedded in the EHR market and every EHR vendor has to do it (Yes, I know about DPC and a few other elective practices that don’t have to worry about it). Do I see it going away? Not in the near future, so we just have to grin and bear for now.

That said, Jim Tate also made a really strong prediction about what EHR vendors can expect in the 2nd half of 2018 in regards to EHR certification. Let’s just say that a number of EHR vendors aren’t likely to be grinning if they’ve put off 2018 Edition EHR certification. Here’s how Jim describes it:

ONC has rolled out three editions of CEHRT. The first, the 2011 Edition, has long gone into the history books. The 2014 Edition can still be used throughout 2018. 2019 is altogether another story. Originally 2018 was the year that vendors had to roll out their certified 2015 software editions. A one-year grace period was thrown into the mix and vendors were given an extra year to achieve the 2015 Edition certification and roll out their products to providers. With only 9 months left to accomplish that task, they may be running out of time.

The Certified Health IT Products List (CHPL) maintains the ledger of all active and withdrawn certifications. There is some fascinating data there to review. There are over 4000 entries for active 2014 Edition Certification. For the 2015 Edition there are less than 300 active certifications. Now I admit there is a bit of an apples to oranges comparison here. For 2014 many vendors active certification is shown for different versions of the same product. Nonetheless it is apparent to me that many vendors have yet to achieve certification even with a deadline staring them in the face.

If that’s not a definition of a logjam, then I don’t know what is. Plus, Jim notes that there’s been some contraction of the EHR certification bodies as well. There just aren’t as many out there to get your EHR product certified. Jim would know since he’s helped over 300 health IT systems get certified. Do you see the problem that’s coming?

What can you do?
The first thing you can do is to go to the Certified Health IT Products List (CHPL) and see if your EHR vendor is 2015 Certified. If it’s not, then you may want to ask your EHR vendor what their plan is to become certified. Knowing the answer to that question will be important to your organization. If it’s not 2015 Certified, then you’ll have issues with MACRA and MIPS in 2019.

Thanks Jim Tate for always staying on top of this stuff and being the wise words of warning about impending issues.

Allscripts to Pay $100 Million Cash to Acquire Practice Fusion

Posted on January 8, 2018 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.

Today, Allscripts announced that it would pay $100 million cash to acquire EHR vendor, Practice Fusion. I wouldn’t quite say this is a fire sale, but in Silicon Valley it’s pretty close when you consider that according to CrunchBase Practice Fusion had raised over $157 million. These seem to be the kind of transactions that Allscripts likes to do. I’ve heard it said that Allscripts is the place where EHR software goes to die. That’s a corrupt way of describing what I think has been their strategy.

The press release said that Practice Fusion supports 30,000 ambulatory practices and 5 million patients. I wouldn’t be surprised if the practices number is inflated since it’s a free EHR and a lot of ambulatory practices signed up to check it out, but don’t actually use the software. I’m at least 2-3 of those practices and haven’t touched my accounts in years. The July 2017 meaningful use attestation data listed 8,440 providers using Practice Fusion software. So, Practice Fusion still has a good size user base, but it’s probably closer to 12-15k practices in my opinion.

As I’ve looked at the ambulatory EHR market, I’ve often been describing EHR vendors as distribution channels as opposed to EHR software vendors. If you go around any exhibit hall, EHR vendors aren’t really selling EHR software much anymore. In most cases, EHR vendors are catering to their existing user base and then using them as a distribution channel for other products and services. With this in mind, Allscripts acquisition of Practice Fusion expands their distribution channel. That’s a valuable thing.

One other piece of this transaction which I believe many won’t understand is Practice Fusion’s relationships with life science organizations. Those relationships are how Practice Fusion was funding their free EHR. I’ve heard mixed reviews on those relationships, but no doubt Allscripts is hoping those relationships can generate more revenue for their company when they add Allscript’s large userbase.

Fierce Healthcare also found in the SEC filing for this acquisition an interesting note about Practice Fusion receiving a request from the US Attorney’s office:

The SEC filing also noted that Practice Fusion received a request from the U.S. Attorney’s Office for the District of Vermont in March 2017 requesting information and documents as part of a civil investigation into the company’s EHR certification. Allscripts stated that although Practice Fusion has complied in “a cooperative, thorough and timely manner,” any legal proceedings, damages or settlements could “adversely impact” future operating results.

No doubt these requests are an extension of the $155 million eCW Whistleblower lawsuit. I expect most major EHR vendors have had some sort of inquiry after the eCW lawsuit. Hopefully, the team at Allscripts vetted the inquiries well especially given Practice Fusion’s past history of pushing the envelope. Considering Practice Fusion’s FTC Charges and Settlement, I’d think that they’d have been careful about their EHR certification, but it’s hard to take the Silicon Valley mentality out of your culture.

The other obvious tie into this story is Allscript’s previous acquisition of McKesson’s HIT software business. I’ll admit that it’s hard for me to keep up with all the EHR software that exists under Allscripts umbrella, but with the addition of Practice Fusion, Allscripts certainly has an EHR software for healthcare organizations of every shape and size. Plus, I expect they run their EHR businesses at break even while they make most of their money off of other lines of business they can sell to their EHR customers. It’s not just Allscripts that’s seen how much money can be made doing revenue cycle management and providing other services to their EHR users.

I will be interested to see what Allscripts chooses to do with Practice Fusion long term. Will they eventually sunset the Practice Fusion EHR and encourage users to migrate to one of their other EHR? Will they start charging Practice Fusion EHR users for the EHR? You can imagine the outrage that would come if they did start charging, but EHR switching isn’t a simple process. So, I’d imagine that many practices would just start paying and it would take months and years for them to finally switch EHR vendors and many would probably just decide to stay with “the devil they know.” That would be a big gamble on the part of Allscripts, so it will be interesting to see if they make it. Then again, maybe they have enough revenue from being a distribution channel to Practice Fusion users that they’ll be able to continue the free EHR model. Time will tell.

Those are some initial thoughts on the acquisition of Practice Fusion by Allscripts. I should also note that the acquisition isn’t complete. It still has to go through the standard ant-trust evaluation process, but I don’t expect that to be an issue. What do you think of this acquisition? Is this a good move by Allscripts? What does this mean for Practice Fusion users?

An EHR Designed for Doctors at the Anti-Aging World Congress

Posted on December 19, 2017 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 recently attended the Med Tech Impact Expo and Conference in Las Vegas. The event was colocated with the A4M (American Academy of Anti-Aging Medicine) World Congress. I was a judge at the Quadruple Impact startup competition that was organized by Medstro where I enjoyed hearing a number of promising startup companies pitch their ideas. They were all pretty early stage, but I couldn’t help but appreciate their passion and creativity.

While not my normal area of expertise, I had to take a trip around the Anti-Aging medicine exhibit hall. There were a large number of pharmaceuticals, neutraceuticals, body toners, etc etc. However, I was of course attracted to the booths that talked about technology.

The first category of company I saw was the practice marketing companies. Most of them were offering the full service soup to nuts offering to these medical practices. It makes a lot of sense for them to target this market since many of the doctors attending the anti-aging conference offer a lot of products and services direct to consumer. So, all of the direct to consumer marketing, SEO, social media, etc can be really effective for these practices. Of course, at this show they mostly send their salespeople, so they didn’t really want to talk with me much since I wasn’t representing a medical practice.

The second category of technology companies I found was the EHR vendors. I think I found 3 of them placed throughout the floor and I stopped and talked with 2 of the companies. Both of them focused solely on this market and so their approach was quite different. They designed the EHR to cater to the doctor and the practice instead of EHR certification and meaningful use regulations.

One of them talked about how they approached the sale of supplies much differently than a traditional EHR might do. In fact, it was an integral part of their system. This made a lot of sense since many of these medical practices have a huge retail sales component.

I did find that each of these EHR was still straddling the billing line. Many of them had practices that still needed to bill insurance companies rather than billing the patient directly for everything. At least one of them admitted that their insurance billing engine wasn’t that great and you could tell that they were a little bit torn on whether they should go all in on the insurance billing side of things or not.

In fact, one of them I talked to was pondering whether to go after EHR certification. I advised them to not do it since it will likely alienate their existing users. Although, I’m sure they’ll look at their addressable market and the potential medical market and be really tempted to not listen to my advice. It’s a powerful thing to say that you have an EHR that’s focused on the doctor and the practice as opposed to regulations. Why would they want to give that up?

I asked to get a full demo of their EHR after the conference. There wasn’t enough time at the event. Once I do, I’ll give you a full report on these hidden EHR. I’ll be interested to see what an EHR that was designed for the doctor and the practice looks like. I’ll let you know what I find.

MIPS Twitter Roundup – MACRA Monday

Posted on December 11, 2017 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 (QPP) and related topics.

As we near the end of 2017, I found a number of tweets from CMS and other people that I thought would be useful to those that are interested in MACRA and MIPS.

First up is this tweet from CMS that it’s not too late to still participate in MIPS and collect some performance data before the end of 2017. This is them promoting the Test Option which would allow you to avoid the 4% penalty:

Next up is a fact sheet from CMS which outlines the different between 2017 and 2018 when it comes to MACRA/MIPS. I particularly like page 6 of the document. As you go through it, you’ll realize why 2018 is going to be much harder than 2017.

Next up is a stat from MGMA. I’d be interested in learning about the 14% of practices that think that their value-based reimbursement is going to decrease. Are these people going to direct primary care? I don’t see it going down for almost anyone. What do you think?

Finally, Matt Fisher asks a question about whether MIPS should be voluntary. I don’t think they can make it any more voluntary given the current legislation and do any of us think that congress is going to take up this topic? I don’t. So, it’s kind of a moot point. However, there is a lot of doctor angst about MIPS/MACRA. I just don’t see enough of it to really move the needle on things. I think we’re stuck with MACRA/MIPS for the forseeable future.

MIPS Penalties Include Medicare Part B Drugs – MACRA Monday

Posted on November 13, 2017 I Written By

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

I’m sure most regular readers can tell that we’re pretty worn out and tired of MACRA, MIPS, and related government regulation. No doubt you’ll see us posting fewer MACRA Mondays going forward, but we’ll still try to cover major MACRA events as they occur. We just won’t be publishing MACRA Monday every Monday like we’ve been doing.

Jim Tate recently posted about the Real MIPS Timeline which included:

  • Phase 1 – Denial
  • Phase 2 – Shock/Anger
  • Phase 3 – Acceptance

You should read his full writeup, but he’s right. There’s a lot of denial that’s going to lead to shock and anger until the majority of healthcare have to finally accept that MIPS and MACA aren’t going anywhere.

Jim Tate also wrote another important piece related to the MIPS penalties and Medicare Part B drugs. You can read the full details of the change, but for those too lazy to click over, here’s the summary:

  • Many organizations argued that Medicare Part B Drug Costs Shouldn’t be Included in the MIPS Penalties (I mean…payment adjustments)
  • The MACRA Final rule still includes Medicare Part B drug costs (for the majority of people) in the MIPS reimbursement and eligibility calculations

If you’re a practice with a high volume of part B drugs, you better start figuring out your MIPS strategy now! Otherwise, that payment adjustment is going to hit pretty hard.

Thanks Jim for the great insights into MACRA and MIPS. If you need help with MIPS, be sure to check out Jim’s company MIPS Consulting.

MACRA Twitter Roundup – MACRA Monday

Posted on October 30, 2017 I Written By

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

We took last week off from our MACRA Monday series of blog posts. It seems like we’re in a kind of lull period for the program. Either you’ve started collecting the data you’ve needed or you haven’t. Plus, we’re kind of waiting for the next MACRA Final rule to drop for more details.

With that in mind, I did want to see what some of the latest things that were being shared on Twitter when it comes to MACRA. I found a lot of strong opinions about the program, some good resources, and some forward-looking thoughts on what could be coming in the next MACRA final rule.


It’s hard to argue with John. Not just because he’s a smart guy, but because he’s right that it’s hard to imagine a path forward that’s fee for service and doesn’t include a shift to value based care in some form or fashion. At least given the current market dynamics.


This caution from Workflow Chuck should have us all nervous about the shift. I see a lot of healthcare organizations going after the target as opposed to the goal of value based care.


MACRA is going to impact your biz. I liked the way Kelly broke it out into 4 areas. No doubt some of these things could be argued both ways.


This is still how most doctors I know feel about MACRA and even meaningful use before it. They feel like they’ve been thrown under the bus.

Here are two forward looking resources that look at what we might get from the MACRA Final Rule:

What else are you hearing about MACRA? Would love to hear your thoughts, insights, questions, perspectives, rants, etc in the comments.