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2019 MACRA Final Rule Overview

Posted on November 5, 2018 I Written By

The following is a guest blog post by Joy Rios, Health IT Consultant at Chirpy Bird.

It happened right on time this year. The 2019 MACRA Final Rule was released on Thursday, Nov. 1, the weekend of Daylight Savings Time – so those of us who track these laws carefully got one extra hour to read through the 2878-page document. Thanks CMS!

First, I’d like to point out that we expect the rules to change each year. If fact, my colleague, Robin Roberts, and I often joke that CMS starts writing the next rule before the ink is dry on the one they just released. However, this year it feels like there’s a lot more to get up to speed on than that which we’ve grown accustomed.

The expansion of the rule’s title alone, which is both comprehensive and overwhelming, hints that this year’s ruling is far-reaching and will impact a great many stakeholders across healthcare.

Look for yourself: The difference between the proposed and finalized titles:

Proposed Title:

Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program

Finalized Title:

Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; Medicaid Promoting Interoperability Program; Quality Payment Program–Extreme and Uncontrollable Circumstance Policy for the 2019 MIPS Payment Year; Provisions from the Medicare Shared Savings Program–Accountable Care Organizations–Pathways to Success; and Expanding the Use of Telehealth Services for the Treatment of Opioid Use Disorder under the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act

The subtitles from the Finalized rule that I reviewed are broken out below with the main bullet points:

1. Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2019

  1. Supports access to care using telecommunications technology.
  2. Medicare will pay providers for new communication technology-based services, such as brief check-ins between patients and practitioners, and pay separately for evaluation of remote pre-recorded images and/or video.
  3. CMS is also expanding the list of Medicare-covered telehealth services.
  4. CMS is delaying implementation of E&M coding reforms until 2021.

“Physicians will see some immediate changes in 2019 that reduce burden and even more significant burden reduction in 2021, when broader changes to the E&M framework take effect,” said Seema Verma.

2. Quality Payment Program

a. MIPS: 2019 Performance Year

General Program Changes

  1. Amount at risk to Medicare Part B services:
    1. Max 7% penalty
    2. 7x incentive, which could result in an adjustment above or below 7%
  2. Avoid a penalty: 30 points (double the 2018 threshold of 15)
  3. Earn Exceptional Performance to capture part of the $500M bonus pool: 75 points (up from 70 in 2017 & 2018)
  4. Expansion of Eligible Clinician types:
    1. PT, OT, Speech & Language, Audiologists, Clinical Psychologists, Registered Dieticians/Nutrition Professionals
  5. Low-volume threshold now includes a third criterion. To be excluded from MIPS, clinicians or groups need to meet one or more of the three criterion.
  6. New Opt-in policy for clinicians or groups who meet or exceed at least one, but not all three of the low-volume threshold criteria.
  7. Virtual Groups must designate a representative and email election to MIPS_VirtualGroups@cms.hhs.gov by Dec. 31, 2018 for the 2019 performance year.
  8. Finalizing a policy to assign a weight of 0% to each of the four performance categories and a final score equal to the performance threshold when:
    1. A MIPS eligible clinician joins an existing practice (existing TIN) in the final three months of the performance period year and the practice is not participating in MIPS as a group
    2. A MIPS eligible clinician joins a practice that is a newly formed TIN in the final three months of the performance period year
  9. Small practice bonus 5 to 6, but applied at the Quality Category level, rather than being applied to overall CPS.

Category Changes

Quality

  1. Category weight: 45%
  2. Different quality measures may now be submitted via different collection types. For example, a group or clinician may submit some measures through an EHR and some through a QCDR, and the measures will be scored together as part of one set.
  3. Claims can be reported by individuals or groups (again), but only by clinicians in a small practice (15 or fewer ECs)
  4. Groups who report 5 or fewer quality measures and do not meet the CAHPS for MIPS sampling requirements, will have their quality denominator reduced by 10 and the missing measure will receive zero points
  5. NEW: Extremely Topped-Out Measures: A measure attains this status when the average mean performance is within the 98th to 100th percentile range. Such measures will be proposed for removal in the next rule-making lifecycle for other topped-out measures.
    1. QCDR measures are excluded from the topped-out measure life cycle.

Promoting Interoperability

  1. Category weight: 25%
  2. Requires 2015 Edition CEHRT
  3. Two new measures: Opioid Treatment Agreement & Query of PDMP
  4. PI Score based on a single, smaller set of measures, no longer divided into Base, Performance, and Bonus

Cost

  1. Category weight: 15%
  2. Adding 8 new episode-based measures
    1. Case minimum 10 for procedural episodes
      1. CMS will attribute episodes to each MIPS EC who renders a trigger service
    2. Case minimum 20 for acute inpatient medical condition episodes
      1. CMS will attribute episodes to each MIPS EC who bill inpatient E&M claim lines during a trigger inpatient hospitalization under a TIN that renders at least 30% of the inpatient E&M claim lines in that hospitalization

Improvement Activities

  1. Category weight: 15%
  2. Added 6 new activities, modified 5 existing activities, removed 1 activity

b. APM Performance Year 2019

  1. Several references to 2025 and beyond
  2. CEHRT requirements of Advanced APMs: 75% of Eligible Clinicians in each APM Entity
  3. Other Payer Advanced APMs: 75% beginning in 2020
  4. Expanding the 8% revenue-based nominal amount standard for AAPMs and Other Payer AAPMs through 2024
  5. Quality – must report at least one outcome measure
  6. All-Payer Combo Option and Other Payer AAPMS
    1. Established a multi-year streamlined determination process where payers and Eligible Clinicians can provide info on the length of the agreement as part of their initial submission, and have any resulting determination be effective for the duration of the agreement (or up to 5 years)
    2. Allowing QP determinations at the TIN level, in addition to the APM Entity and individual EC levels
    3. Allowing all payer types to be included in the 2019 Payer Initiated Other Payer AAPM determination process for the 2020 QP performance period
  7. Multi-Year Other Payer AAPMs
    1. Payers and eligible clinicians with payment arrangements determined to be Other Payer Advanced APM must re-submit all information for CMS review and redetermination on an annual basis.
      1. At the time of the initial submission, the payer and/or eligible clinician will provide information on the length of the agreement, and attest at the outset that they will submit information about any material changes to the payment arrangement during its duration.
      2. In subsequent years, if there were no changes to the payment arrangement, the payer and/or eligible clinician do not have to annually attest that there were no changes to the payment arrangement
    2. Updated the MIPS APM measure sets that apply for purposes of the APM scoring standard

c. Public Reporting via Physician Compare

  1. Quality – all measure under MIPS Quality are available for public reporting, unless the measure itself is new (i.e. in its first or second year.)
  2. Cost – subset of Cost measures is available for public reporting, except new measures
  3. PI – Include an indicator for Eligible Clinician or group “successful” performance
  4. PI – include objectives, activities, and/or measures

3. Quality Payment Program–Extreme and Uncontrollable Circumstance Policy for the 2019 MIPS Payment Year;

CMS has had to respond to some hard-to-face realities* since the proposed rule was released in July. Of note, the first policy addition to the rulemaking provides relief for ACOs, in addition to other MIPS eligible clinicians affected by fires, hurricanes, natural or man-made disasters that have a significant negative impact on healthcare operations, area infrastructure or communication systems. They will have the option to self-attest and receive a hardship exception.

*Climate Change is real.

4. Provisions from the Medicare Shared Savings Program–Accountable Care Organizations–Pathways to Success;

This policy provides a new direction for the Shared Savings Program by establishing pathways to success through redesigning the participation options available under the program to encourage ACOs to transition to two-sided models, in which they may share in savings and are also accountable for repaying any shared losses.

It also offers to:

  1. Further promote interoperability
  2. Grant voluntary 6-month extension for existing ACOs whose participation agreements expire on Dec. 31, 2018.
  3. Align CEHRT with QPP

5. Expanding the Use of Telehealth Services for the Treatment of Opioid Use Disorder under the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act

This policy outlines plans to reimburse physicians for virtually checking in with patients and remotely evaluating recorded images.

As it turns out, people treated remotely for psoriasis did just as well as those treated in person — and were much happier about not having to travel to see their doctors.

The final Medicare physician payment rule also expands payment for treatments for stroke, kidney disease, mental health and substance abuse by removing restrictions on originating sites. Those are all provisions from the budget and opioid packages.

************************

You could take any of these sections and write opinion pieces, draw dotted lines to affected stakeholders, and venture down about 1000 rabbit holes with this rule.

CMS Administrator Seema Verma acknowledges that transitioning to value-based care will require all of us to stretch and maybe sit with a bit of discomfort.

In her words, “If we’re going to move our system to a patient-centered, value-based system, change is inevitable, and change is always hard for those whose livelihood is dependent on the status quo.”

If you’re looking for some direction with MIPS, ACOs, or your place in the value-based care ecosystem, get in touch.

If you want to hear Robin and I geek out over this rule, be on the lookout for a special episode of the HIT Like a Girl podcast, to which you can subscribe here.

Revenue Cycle and Patient Communication Dominates MGMA18 Exhibit Hall

Posted on October 3, 2018 I Written By

Colin Hung is the co-founder of the #hcldr (healthcare leadership) tweetchat one of the most popular and active healthcare social media communities on Twitter. Colin speaks, tweets and blogs regularly about healthcare, technology, marketing and leadership. He is currently an independent marketing consultant working with leading healthIT companies. Colin is a member of #TheWalkingGallery. His Twitter handle is: @Colin_Hung.

Two themes emerged from the exhibit floor of this year’s MGMA annual conference (1) Practices are spending money on improving Revenue Cycle Management – RCM and (2) Practice managers are looking for more comprehensive ways to communicate with patients.

The exhibit hall of the 2018 MGMA Annual Conference (#MGMA18Annual) came to a close today and as the booths were quickly deconstructed, I took time to reflect on 25 pages of notes that I took from the various conversations I had. As I flipped through my blue-ink chicken scratches, I kept seeing two words in the margins: “PtComm” (my short hand for Patient Communication) and “RCM” (Revenue Cycle Management). On page after page, I scrawled these words to summarize the conversations.

In the Health iPASS booth, I had the chance to speak with one of their customers – Judith Basile, MSM, FACMPE, Practice Administrator at Associates in Orthopedics. Basile told me that implementing Health iPass’s RCM platform made “a huge impact on the financial health” of their practice and that it allowed them to “catch up to the consumer experience patients have outside of healthcare, where they can make payments quickly and easily”. With Health iPASS, Associates in Orthopedics experienced a 35% improvement in patient payments. They had only been on the platform for 18 months.

Over in the Pulse Systems booth, I spoke with Dar Griffeth, the company’s new SVP of RCM Services. Griffeth’s role was created because the company recognized the need their customer had for expert RCM advice. His job is to work with customers to identify how components of the Pulse solution can be adapted to improve the RCM process. This is in contrast to the common approach of deploying technology and then redesigning the workflow to fit – an approach that often results in slow adoption or outright failure. Griffeth’s role would not exist if RCM was a low priority for physician practices.

Matthew Hawkins, CEO of Waystar, the company that resulted from the combination of ZirMed and Navicure, shared where they had been focusing some of their development efforts. “Lately we have been focused on helping reduce or eliminate claim denials,” said Hawkins. “Having a claim denied is terribly inefficient. Practices have to spend precious time and effort investigating and correcting the claim. We thought – why does it have to be this way? What if we could eliminate denials altogether? That’s what we’ve been working on and our customers are happy we have made significant strides in this area.”

The exclamation point was Waystar’s announcement that it was acquiring Ovation – a claims monitoring technology from UPMC to further enhance Waystar’s claims processing platform.

The conversation turned to patient communications when I stopped to speak with Rick Halton, VP of Product and Marketing at Lumeon. I was unfamiliar with Lumeon and was curious to find out more. Halton argued convincingly that the current paradigm of care coordination was flawed – that the top-down approach where a central care coordinator is expected to shoulder the work to gather data from patients and keep patients adherent to their care programs. was doomed to fail. Instead, an approach where patients are full partners in their care was needed. In Halton’s opinion, the key was two-way communication between patients and their care teams.

Lumeon’s Care Pathways Management platform allows for a more automated and orchestrated approach to care delivery. One that is centered on the ability for patients and care teams to communicate in a seamless manner via text and in-app messages. “Everything from discharge to pre-operative readiness to lifestyle coaching is possible through the platform,” said Halton.

In prior years at MGMA, whenever I talked to people about patient communications my conversations were only about sending out appointment reminders and links to patient educational materials. What Lumeon was showing me was true 2-way communication with patients across many care scenarios.

Further evidence of this shift in patient communications came from my conversations with Well Health, Rhinogram and CareCloud.

Well Health makes a platform that consolidates all patient communications in one place – and allows for seamless transition from broadcast message delivery to real-time two-way communication with patients. Their interface looked intuitive and because they system stored all prior communications, it allows practices to quickly reference prior conversations, helping staff get to the heart of the issue more quickly than having to search through the EHR.

“It’s all about making it easy for both the patient AND the staff in the healthcare organization,” said Bill Kinner, President of Well Health. “We have to realize that in the world of value based care, effective 2-way communication with patients is the cornerstone to keeping people healthy. It’s the last mile of any population health, medication adherence or mental health program.”

Rhinogram had a similar philosophy. A relative newcomer to the ambulatory space, the company has enjoyed years of success with dental practices. I asked Dr Keith Dressler, Chairman & CEO of Rhinogram what set their system apart from all the others on display at MGMA: “Quite simply we see ourselves not as a communication platform, but as an asynchronous telehealth platform that uses text, Facebook Messages and other channels rather than real-time video to connect with patients”

Dressler’s response was a great way to reframe the entire patient communication space and showed me that vendors were moving away from their provider-initiated communication roots to include patient-initiated communication as well.

Nowhere was this shift more apparent than in the CareCloud booth. A year ago I wrote a post about the launch of the company’s then-new Breeze platform – a patient experience platform built in partnership with First Data. Breeze was designed to be the backbone for all sorts of new patient engagement applications. At MGMA18, CareCloud announced the launch of a customizable survey tool for capturing patient satisfaction information on Breeze.

“Our new survey capability is very exciting,” said Juan Molina, Vice President of Strategy and Business Development at CareCloud. “The surveys are customizable by the practice without the need for development resources. This allows our customers to quickly construct surveys that can gather patient feedback on anything – new programs they want to offer or changes they want to make to the practice itself. The sky is the limit. But at the core, this survey capability means our customers have another way to engage patients in a 2-way conversation about their experience.”

I must admit, prior to MGMA18 I had thought the patient communication space was played out. But having spoken with every patient communication vendor on the exhibit floor, I have a new appreciation about where the technology is headed. I’m actually excited to see what advancements will be made in the next 12 months.

PS: I also had great conversations with Kevin Pho MD – founder of KevinMD.com, Todd Evenson – COO at MGMA, Corinne Proctor Boudreau – Senior Manager at MEDITECH and Niko Skievaski – cofounder & President at Redox. Those conversations will be the subject of upcoming articles.

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.

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

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.

Optimizing Your EHR for MIPS and Other Quality Payment Programs – MACRA Monday

Posted on October 9, 2017 I Written By

The following is a guest blog post by Meena Ande currently acts as Director of Implementation for Advantum Health. 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 quality reporting requirements ramp up under value-based payment programs like MIPS, healthcare organizations are busy retrofitting their EHRs to make way for new measures. In some settings, not much has changed by way of tech utilization since initial EHR investments were made. Many outpatient settings still lack the internal expertise needed to optimize their implementations.

The truth is many EHRs have the functionality providers need for quality reporting, but many providers don’t know that due to limited exposure to the system. Couple that stunted tech knowledge with the well documented lack of familiarity with MACRA and the recent rise of the service model in healthcare is no surprise. Many practice administrators are relying on their EHR vendor or engaging outside experts to help lead the charge on system reconfiguration to meet Quality Payment Program demands.

There are several EMR capabilities providers can take advantage of to support QPP reporting efforts. Here are a few tips to keep in mind as you customize your EHR for MIPS and other value-based models.

Don’t boil the ocean when selecting CQMs.

Most EHRs give the option of tracking more than what is required for quality reporting. Initially, track applicable measures that exceed reporting requirements. After three to four weeks you’ll know which are your strong areas. Pick the best of the litter and proceed.

Providers can be overwhelmed by too many measures, particularly in multi-specialty practice settings. While it can be difficult to find overlap in measures between specialties, taking advantage of shared metrics whenever possible can reduce reporting burdens. Sit down as early as possible and develop an EHR configuration that works for your practice’s various clinicians.

Case in Point:

A gastroenterologist and a cardiologist may work in the same multi-specialty organization and on the same EHR, but the clinical quality measures they care about differ. There is no reason to give the gastroenterologist access to the cardiology problem list in the EHR. Specialty views improve ease-of-use and support more complete documentation.

Most EHRs offer role-based and specialty-based customization. Administrators can enable or disable EHR features related to some quality measures at the practice level and sometimes at the individual provider level. Clinical quality measures are based on details about the patient, but what is captured at each point of care should be tailored to the specific provider role.

Consider the roles impacted by different CQMs.

Keep the role of the person who may be responsible for different quality measures and Advancing Care Information workflows in mind when selecting and carving out space for CQMs in your EHR. Select measures that spread reporting work across multiple roles to relieve clinicians of unnecessary burdens.         

Case in Point:

The insurance eligibility verification required under Meaningful Use is managed by the front office. Front-office staff members should be made aware of the processes they need to complete before a patient checks in, and where to document that task in the EHR.

Control what is included in MIPS denominators.

Like Meaningful Use, patient encounter volume is important under MIPS. The size of the patient pool under any given quality measure directly impacts your adherence percentage. While most primary care encounters do meet patient visit requirements under MACRA, that is not always the case in specialty settings. Clinicians can exercise some control in determining what is included in patient denominators when reporting under MIPS.

Case in point:

Some primary care visits can be omitted. Let’s say a two-physician practice sees 50 patients a day. Only 15 of those patients might be seen by a physician. The rest of the patients may be there for a simple procedure like a blood pressure screening, stress test, or echocardiogram, where quality reporting elements are not verified. Such visits should be excluded.

Evaluate your reporting paths.

MIPS offers both EHR-based and registry-based reporting paths. Most specialties can submit CQM data via their EHR while others will have to rely on paid registry reporting. Additional reporting options might include submitting through associations that member clinicians are affiliated with, or through registries created by large hospital affiliates to help related providers.

Another hurdle for clinicians is deciding whether to submit data as a group or independently. Groups interested in participating in MIPS via the CMS web interface or administering the CAHPS for MIPS survey had until June 30, 2017, to register. Beyond that, clinicians have until the March 31, 2018, MIPS submission deadline to decide whether to report independently or as a group.

Case in point:

Big groups with different levels of EHR proficiency among providers may be better suited reporting at an individual level. Individual reporting takes more time for attestation, but the advantage is that higher-performing clinicians can avoid a penalty if the group doesn’t collectively meet reporting criteria.

Each month, sample 10 percent of EHR CQM data, including instances where criteria have been met and where it has not. Catch outliers with trouble following through on processes and extend targeted training to the team members bringing numbers down.

Conclusion

Optimizing the EHR and other tech resources providers have in place can be a huge MIPS enablement factor. Up-front customization work helps providers meet reporting requirements and save time over the long run. EHR optimization also enables future value-based care initiatives and lays the groundwork for population health management programs. Gains made in EHR use benefit the life of the practice through increased efficiency and, at the end of the day, better patient care.

About Meena Ande
Meena Ande currently acts as Director of Implementation for Advantum Health where she manages Implementation of services along with EHR optimization, with emphasis on workflow management for value-based reporting.

Should We Return to the Move from EMR to EHR?

Posted on April 8, 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.

Over the 10 years I’ve been blogging about EMR/EHR, it’s been amazing to watch the evolution of the terms and how people use them. Based on most people’s usage, I’ve long been an advocate that the two terms should and are used interchangably. If you say one or the other, most people are assuming the broadest use of the term. Although, the HITECH Act’s use of the term EHR has certainly made it more popular and in vogue (even if most doctors I know still call it an EMR).

Semantics aside, now that meaningful use has matured, I believe that healthcare is ready for a return to the conceptual differences between an EMR and an EHR. Conceptually an EHR was a record that included the patient provided data along with the clinic’s data (ie. EMR data). This concept was partially included in meaningful use, but not in a very meaningful way.

What are some patient features that would constitute an “EHR”?

Medical Record Access – Patient access to the EMR data should be a core feature of an EHR. Most EMR/EHR vendors provide this feature and more and more doctors are excited to give their patients digital access to their medical record. However, along with access to the medical record we need to build features that allow the patient to submit corrections to the medical record.

Secure Messaging – Patients are increasingly demanding electronic access to their doctor’s office. This secure messaging is often done through the EHR. Most EMR/EHR software have this as an option, but many doctors are afraid of what this messaging will mean for their workflow. Luckily, more and more doctors are sharing the experience that this type of messaging makes their workflow faster and better. High maintenance patients are going to be high maintenance regardless of options they have available to access you.

Patient Generated Data – This feature is still something that many are trying to figure out. Can they allow patients to submit their own health data to the doctor? If they do, what’s the doctor’s liability for that data? How can/should the doctor use the data that’s being shared with the clinic? There are plenty of questions about how this should be executed, but there are also a lot of opportunities. It’s time we start working through these challenges.

There’s a whole suite of other services that we should look at offering patients as well such as: online appointment scheduling, online patient payment, refill requests, etc etc. However, if we could start with just the above 3 items we could truly start calling our systems an Electronic Health Record and not just an Electronic Medial Record. Regardless of what we call it, I believe these types of features and even more patient focused access are going to be the future wave of what patients will expect from their doctor.