Holy MACRA! Patient Engagement rides again!

Regulatory-signage“What was that masked legislation? Why that, my boy was CMS! The greatest regulator in the west!” (Cue The March of the Swiss Soldiers in the William Tell Overture aka, theme song for one of my childhood heroes, The Lone Ranger).

What is MACRA?

MACRA is the abbreviated version of the “Medicare Access and CHIP Reauthorization Act of 2015” which was signed by President Obama on April 16th of this year. (Healthcare and CMS sometimes really can’t help it’s communication to the public when they make these abbreviations something that only so called “healthcare insiders” will understand).

The new law repeals Medicare’s sustainable growth rate (SGR) formula and creates a way to increased Medicare payments. At HIMSS16 this year, there was a focus was on “MIPS” or Merit Based Incentive Payment System which is the program that the SGR will be replaced with.

Physician rates are understood to be increased by 0.5% starting in July and each January through 2019 and then, bonuses could reach 12% and then 27% by 2022 (physicians could also face penalties for not meeting quality targets down the road).

On the CMS site, it asks the question, “How does the Medicare Access & CHIP Reauthorization Act of 22015 (MACRA) reform Medicare payment?”

Apparently, in a couple of ways:

It makes 3 changes to how Medicare pays those who give care to Medicare beneficiaries. The changes create a Quality Payment Program (Abbreviated to ‘QPP’).

  1. Ending the SGR formula for determining Medicare payments for health care providers services.
  2. Making a new framework for rewarding heal care providers for giving better care not just more care.
  3. Combining CMS’ existing quality reporting programs into one system.

The changes have been named QPP and replace other Medicare reporting programs with a flexible system that allows providers to choose from 2 paths that link quality to payments either MIPS or something called Alternative Payment Models (APMs)

MIPS – This combines parts of the PQRS (Physician Quality Reporting System), the Value Modifier (VM or Value Based Payment Modifier) and the Medicare Electronic Health Record (EHR) incentive program in which EPs (Eligible Professionals) will be measured on:

  1. Quality
  2. Resource Use
  3. Clinical Practice Improvement
  4. Meaningful Use of Certified EHR technology.

APMs – Alternative Payment Models give new methods to pay healthcare providers for the care they give to Medicare recipients as from the year 2019 to 2024, CMS will pay some participating healthcare providers an incentive lump sum; increase transparency of physician focused payment models and starting in 2026, offer some participating healthcare providers higher annual payments.

 

 

 

 

 

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The Wrap: Healthcare’s Look Back at 2014

Looking back on 2014As we look in the rear view mirror back on 2014, the year that was supposed to change our coding and billing systems, we see that ICD-10 dominated the news with it’s postponement in April and CMS’ subsequent new date of October 1st, 2015. Over the last few weeks though, I’ve heard rumors of yet another delay, this time due to the new political climate in Washington, D.C. These rumors are unsubstantiated, so I would keep them as such. I would record it as a risk to the program for those seeking to restart their ICD-10 initiatives.

Healthcare provider and payer organizations were in “shock and awe” (shocked and many people saying “awww”) at the same time, and high number of provider organizations deciding to postpone their programs indefinitely until the new date was announced and many just restarting the programs either late in the year or planning on doing so in the beginning of the new year, 2015.

The mission of provider IT organizations changed. Just as it was in the pre and post-Y2k days, organizations now wanted to get actual intelligence or analytics from the large systems that they had implemented at such great cost. We came full circle and Analytics started coming to the forefront during the year and it matured after all of the interest, talk and presentations  of Big Data, Business Intelligence and Analytics over the last few years. Leveraging actual data for case studies that I know of this year on Population Health Management and better response times in the ED.

In a recent article in Clinical Innovation and Technology, it was reported that ” as of November 2014, 11,478 eligible professionals and 840 hospitals have attested to Meaningful Use Stage 2. In total, 15,481 new EPs and 221 new hospitals have attested in 2014″. The healthcare provider ecosystem was able to move forward despite some inertia at the beginning of the year.

Many organizations also realized that their infrastructure needed to be updated with projects such as XP to Windows 7 migration; something that needed to occur due to the end support in April by Microsoft of their well known Microsoft XP Operating System.

Consumer health devices starting to get mainstream traction with products like Fitbit and Google Glass starting to look at possible mHealth applications for providers in the future.

The vision and ‘utopia’ of an Interoperable Healthcare ecosystem received a major boost with The Office of the National Coordinator for Health Information Technology releasing it’s “10-Year Vision to Achieve An Interoperable Health IT Infrastructure” by 2024. This would be a baseline for future infrastructure development across the United States and possibly even a starting point for world leadership in healthcare systems and infrastructure interoperability.

What a year it has been and we have so much yet to come in 2015 and beyond.

The Day that could have been. ..One More Year to Go!

Today, would have been the day for ICD-10 Go Live if Congress had not been swayed by the plans of the minority of healthcare providers. Instead, we have (hopefully if someone else doesn’t do the same thing) we are looking at October 1st, 2015 as the new Go Live date.

Be ready. I’m sure many people will start planning mid way through April; 6 months prior to go live. Until then, there will be a build up of managers, analysts and IS teams wondering what their year will be like and what impact ICD 10 will have. Good luck to all of you. You’ll need it!

We don’t “Lobby” in Healthcare IT, we “Advocate”

As someone who grew up in other countries before becoming a naturalized American, there’s always been some kind of fascination when it comes to what is called “lobbying” in the United States. I’ve never been able to understand it as it always seems that it goes against the grain of what I’ve always thought of the United States through history books and the Founding Fathers, whom I so admire for their simple vision that has overcome the tests of time. Yet, hiring professional lobbyists in the United States is perfectly legal and healthcare has been leveraging this legal loophole for sometime now. Just this year as an example, lobbying has come into the news through the change in the regulatory date for ICD-10 from October 1st, 2014 to October 1st, 2015. Most believe that this was the result of pressure from care delivery professionals that wanted more time to get their act together (I for one was against this).

Recently, it was reported in “Modern Healthcare” (September 10th, 2014) that Epic retained a lobbyist and as it was reported the filing said that it was “to educate members of Congress on the interoperability of Epic’s healthcare information technology.”

Last week, HIMSS delegates from across the country had their yearly visit to Washington D.C. for their HIMSS Policy Summit, held during National Health IT week where (as reported by Healthcare IT News) HIMSS had certain asks of the nation’s representatives, which were:

  • Minimize disruption in our nation’s health delivery system emanating from federally mandated health IT program changes.
  • Fund the National Coordinator for Health IT to achieve interoperability, improve clinical quality and ensure patient privacy and safety.
  • Expand telehealth services to improve patient access and outcomes and decrease healthcare costs.

The role of politics and healthcare will remain inextricably tied to one another. As we continue to move through this paradigm shift, these areas will ultimately focus on the future of our country’s care delivery and outcomes and the way that we, the patient, will receive our care.

MU gets a Breather! Healthcare Providers heave a sigh of relief!

MU breather1 Marilyn Tavenner, the CMS Adminstrator announced last Thursday at HIMSS ’14 in Orlando that CMS would be flexible on “hardship exemptions” for meaningful use requirements, which I am sure the healthcare industry heaved a collective sigh of relief.

Expectations were high for this to happen as it had been suggested earlier that this was to come.

In reviewing the CMS document titled “Payment Adjustments & Hardship Exceptions Tipsheet for Eligible Professionals” that was last updated in  October 2013 has hardship exemptions for eligible professionals with the following information:

EPs can apply for hardship exceptions in the following categories:

*Infrastructure — EPs must demonstrate that they are in an area without sufficient internet

access or face insurmountable barriers to obtaining infrastructure (e.g., lack of broadband).

 New EPs

— Newly practicing EPs who would not have had time to become meaningful users can apply for a 2-year limited exception to payment adjustments. Thus EPs who begin practice in calendar year 2015 would receive an exception to the penalties in 2015 and 2016, but would have to begin demonstrating meaningful use in calendar year 2016 to avoid payment adjustments in 2017.

Unforeseen Circumstances

—Examples may include a natural disaster or other unforeseeable barrier

Patient Interaction:

1.  Lack of face-to-face or telemedicine interaction with patients

2.  Lack of follow-up need with patients

Practice at Multiple LocationsLack of control over availability of CEHRT for more than 50% of patient encounters 

With the number of initiatives currently under way at every single care delivery organization, ICD-10, optimization, Patient Portals, Patient Engagement, workflow optimization and so on, we continue to move at, what can only be considered, lightening pace through this decade as we regain American dominance in the healthcare technology sector and then shift our focus to lowering the cost of care delivery and leverage process improvements, better preventative care options.

With current clinician retirement trends the way that they are, I also foresee a great need for qualified physicians and clinicians over the next few years and migration to the United States for technology savvy medical professionals from other countries could assist with this demand in major population centers across the country.

Looking back at 2013

As we come to yet another year end, we reflect back on the year. There is a new leader at ONC, the ICD-10 transition is truly happening, Meaningful Use Stage 2 has had some changes, more healthcare provider organizations in the United States have implemented an Electronic Health Record and Patient Engagement initiatives are off to the races. IT Departments within provider organizations are busier than ever and many EMR experienced resources continue to turnover as the industry slowly matures.

With 2014’s imminent arrival and initiatives culminating during that time, good advice would be to stay focused, remember that stay ahead of the game and make sure to try and get as much done in advance as possible so that there is time for adjustments as you get closer to the dates that projects are required for completion. For ICD-10, vendors really need to bear in mind that they are holding up project completions across the country and need to be aware that if they want to charge customers to be ICD-10 compliant with their software, they risk potential loss of relationships with those customers. Most vendors have not charged their provider customers with an ICD-10 compliant version and that is the best thing that they could have done. If you don’t have an ICD-10 compliant version of your software by now or have a statement of readiness, recommendation would be to re-evaluate your vendor and product and think about alternatives.

Think about the cloud, think about what it would take to get there. This year is also about analytics. With all of this information now at your fingertips, think about how the organization can leverage this information to achieve better outcomes. XP to Win7 migration is around the corner. Be mindful of the risks associated with HIPAA. Think about the enterprise architecture your organization has. In 2014, this blog will discuss these topics, including a topic covering areas that cover the patient experience and security as well.

Until then, stay safe, enjoy your New Year’s celebrations and see you in 2014.

HIPAA and the Art of Security Maintenance

After the HIPAA Omnibus Rule went into force on September 23rd, 2013, the focus on security and compliance became that much more important for healthcare organizations around the country.

The U.S. Department of Health and Human Services Office for Civil Rights announced the final rule that asked for the implementation of a number of provisions of the HITECH Act, enacted as part of ARRA in 2009, to strengthen the privacy and security protections for health information established under HIPAA.

The press release said that the changes that were announced expanded on many of the requirements to business associates of entities that receive protected health information, such as contractors and subcontractors. Some of the largest breaches reported to HHS have involved business associates. Penalties are increased for noncompliance based on the level of negligence with a maximum penalty of $1.5 million per violation. Also patients can request a copy of their electronic medical record in an electronic format and when you pay by cash you can ask your provider not to share information about your treatment with their health insurance payer.

In addition, the Omnibus rule makes it is easier for parents, guardians and others to give permission to share proof of their child’s immunization records with a school and gives covered entities and business associates up to one year after the 180-day compliance date to modify contracts to comply with the rule. Security Officers and legal departments within healthcare organizations have certainly been occupied with this and other compliance initiatives including proper discarding of paper documentation within an organization. Initiatives such as shredding of unused paper copies of manuals which do not need to be around an organization in this day and age and usage of electronic copies of documentation, would assist in streamlining organizational workflows and start to see the true benefits of electronic medical records.