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Between Doctors & Patients…Technology in the Treatment Room

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Editor’s Note: This article was originally published in the Spring 2016 issue of Alabama Medicine magazine

Love them or hate them, electronic records are here to stay.

Electronic health records, or EHRs, are an evolution of the electronic medical records, or EMRs, that some medical practices use internally. EMRs are a digital version of the paper charts containing the medical and treatment history of the patients in one medical practice. EMRs have advantages over paper records in that they allow physicians to track patient data over time, identify which patients are due for preventive screenings and check ups, and monitor overall quality of care within the practice.

EMRs, however, are not built to travel easily outside the medical practice should the physician need to send the patient to another physician. This is where EHRs are intended to pick up and be more effective. EHRs are built to share patient information between medical practices, laboratories, hospitals and other health facilities. Should your patient be seen in the emergency room, EHRs are supposed to allow you to view those charts and results, including all the physician’s notes, labs and any films.

That’s how the system is supposed to operate. While the EHR systems work well for some, mostly larger practices and specialty physicians, they cause more problems than they solve for others, particularly smaller practices and family care physicians.

The surgeons with Alabama Orthopaedic Specialists, PA, in Montgomery, began looking for a solution to their charting issues in 2006, long before federal regulations started to trickle down concerning electronic records. Finding the best solution for the practice didn’t happen
overnight. It was a process, according to practice manager Ron O’Neal.“It took a little while for us to discover exactly what this would mean to the practice…the good and the bad…and it needed to be something everyone was on board with,” O’Neal explained. “It took time for us to come up with a checklist of everything we wanted and needed our EHR to do. It was important we found a system that would work for our practice instead of our practice working for that system, so we took our time.”

“It took a little while for us to discover exactly what this would mean to the practice…the good and the bad…and it needed to be something everyone was on board with,” O’Neal explained. “It took time for us to come up with a checklist of everything we wanted and needed our EHR to do. It was important we found a system that would work for our practice instead of our practice working for that system, so we took our time.”

Michael Davis, M.D., a surgeon with Alabama Orthopaedic Specialists, helped lead the search to find the perfect EHR for the group and agreed with O’Neal that while the search for the best system may have seemed long, it was for a good reason.“Historically we had paper charts. So, when a patient would be seen by one of our physicians yesterday and referred to me today didn’t really have any idea why they were seeing me and would expect me to know why they were here. It would take time for me to collect the paper chart, if everything was there, and sometimes re-interview the patient. That took a lot of time. If you don’t have to filter through all those notes to get to the bottom of the problem when someone else already has, you save a lot of time. You’re not duplicating tests and x-rays, and patients aren’t exposed to more tests or irradiated more than once just because you can’t get your hands on those results,” Dr. Davis said.

“Historically we had paper charts. So, when a patient would be seen by one of our physicians yesterday and referred to me today didn’t really have any idea why they were seeing me and would expect me to know why they were here. It would take time for me to collect the paper chart, if everything was there, and sometimes re-interview the patient. That took a lot of time. If you don’t have to filter through all those notes to get to the bottom of the problem when someone else already has, you save a lot of time. You’re not duplicating tests and x-rays, and patients aren’t exposed to more tests or irradiated more than once just because you can’t get your hands on those results,” Dr. Davis said.For Dr. Davis, having the EHR in hand can make explaining a complicated procedure a bit smoother when the tool can be used to illustrate the nuances of a surgical procedure by showing the patient his or her x-rays, MRIs, and other test results. But, the EHR is just that…a tool, which Dr. Davis is quite mindful of making sure doesn’t become an intrusive object in the treatment room.

For Dr. Davis, having the EHR in hand can make explaining a complicated procedure a bit smoother when the tool can be used to illustrate the nuances of a surgical procedure by showing the patient his or her x-rays, MRIs, and other test results. But, the EHR is just that…a tool, which Dr. Davis is quite mindful of making sure doesn’t become an intrusive object in the treatment room.

Yet, Dr. Davis and O’Neal agreed EHRs work better for specialties than with family practices when considering the diagnostic possibilities family physicians face with their patients. What’s streamlined in a specialty is often wide ranging in family practice.

Maarten Wybenga, M.D., a family physician in Prattville, hasn’t made the switch from paper charts to EHRs and doesn’t have any plans to in the immediate future. For Dr. Wybenga, e-prescribing and electronic billing are sufficient to keep the federal mandates at bay.

“I’m always going to be ‘pro-the-patient.’ I never jump on the bandwagon when something new comes out. I want to read the research, see how it works first before I start using it with my patients. It’s the same with technology in the medical office,” Dr. Wybenga said. “I’ve wanted to stand back and watch it a little rather than jump right in. When things started getting interesting with electronic records, we talked about it. Should we do this, or should we wait and see what’s going to happen? Should we give it a year or two? As we watched the technology arena grow and grow, the software companies exploded. There were just too many offering too much. We keep watching, but I’m just not satisfied, and I haven’t made that decision. To this day, we’re still on handwritten medical records.”

According to Amy Wybenga, Dr. Wybenga’s practice manager and immediate past president of the Alliance to the Medical Association of the State of Alabama, the number of reasons against using EHRs in the practice simply outweighed the positive outcomes.“No one could give us a good, sound reason of what benefit it would be to us or our patients if we changed over. For our practice, the negative reasons definitely outweigh the positive reasons,” Wybenga said. “We would have to cut down on the number of patients we could serve for at least a year because it could take up to that long for us to switch everything over, and it would slow us down too much. Being a family practice in a rural area, there’s just no way we can cut back on the number of patients we see. Those patients have to be seen. Why would we go to a system that would slow us down even more, something that we can’t share with anybody, would still have to print off information to fax or email to other doctors because it won’t communicate with other systems…where’s the benefit?”

“No one could give us a good, sound reason of what benefit it would be to us or our patients if we changed over. For our practice, the negative reasons definitely outweigh the positive reasons,” Wybenga said. “We would have to cut down on the number of patients we could serve for at least a year because it could take up to that long for us to switch everything over, and it would slow us down too much. Being a family practice in a rural area, there’s just no way we can cut back on the number of patients we see. Those patients have to be seen. Why would we go to a system that would slow us down even more, something that we can’t share with anybody, would still have to print off information to fax or email to other doctors because it won’t communicate with other systems…where’s the benefit?”

For one gastroenterologist who just started a new practice in January using paper charts, Bradley Rice, M.D., of Huntsville, who is also a member of the Association’s Board of Censors, is working to make the transition to EHRs a seamless one for his staff and patients. “I actually try to use the computer a small amount of time while in the room with a patient. I talk with the patient and take notes on a sheet I have designed,” Dr. Rice noted. “I prefer to speak with the patient instead of talking to them while looking at a computer, so I wait until the end of the appointment to then work on the computer, then escort them up to the check-out area. My goal is to make sure the patient feels comfortable and understands that I am there to meet with them instead of focusing on the computer in the room.”

“I actually try to use the computer a small amount of time while in the room with a patient. I talk with the patient and take notes on a sheet I have designed,” Dr. Rice noted. “I prefer to speak with the patient instead of talking to them while looking at a computer, so I wait until the end of the appointment to then work on the computer, then escort them up to the check-out area. My goal is to make sure the patient feels comfortable and understands that I am there to meet with them instead of focusing on the computer in the room.”

Dr. Rice and his staff have seen both sides of the EHR coin and agree with Dr. Davis and O’Neal that the initial setup of a system can be difficult and costly. It takes time to scan and input data into a new system, but once the system is online, it can help with documentation and accountability.

Interoperability was one of the initial selling points for EHRs from the Office of the National Coordinator for Health Information Technology. Fully functioning EHRs are designed to “talk” to other systems. However, many physicians are finding this may not be the case, and after years of voicing complaints through their medical societies and associations, their concerns seem to be getting through.

Department of Health and Human Services Secretary Sylvia Burwell recently announced the nation’s top five health care systems and companies, which provide EHRs covering more than 90 percent of hospital patients, have agreed to principles designed to improve patient access to health data and eliminate the practice of data blocking. These groups have also agreed to adopt federally recognized, national interoperability standards by 2018.

To unlock the data and make it useful to physicians, the companies have agreed to:

  • Implement application programming interface (API) technology so smartphone and tablet apps can be created, facilitating patient use and transfer of health care data.
  • Work so physicians can share health data with patients and other physicians whenever permitted by law, while not blocking such sharing either intentionally or unintentionally.
  • Use the federally recognized Fast Healthcare Interoperability Resources data standard.

In late 2015, the Medical Association led a coalition of nearly 40 Alabama specialty and county medical societies in asking to the Alabama Congressional Delegation to support the Patient Access and Medicare Protection Act, which granted the Centers for Medicare & Medicaid Services the authority to expedite applications for hardship exemptions from Meaningful Use Stage 2 requirements for the 2015 calendar year. President Obama signed the bill. Because CMS didn’t publish the MU Stage 2 final rule until Oct. 16, physicians weren’t informed of the requirement until fewer than the 90 required days remained in the calendar year, leaving most in a penalty-assured lurch. CMS extended the deadline for physicians to apply for MU hardship exemptions to EHR incentive program. The new deadline is now July 1, 2016. The extension is being granted “so providers have sufficient time to submit their applications to avoid adjustments to their Medicare payments in 2017.” The new application forms and instructions to file a hardship exemption are on the CMS website.

Because CMS didn’t publish the MU Stage 2 final rule until Oct. 16, physicians weren’t informed of the requirement until fewer than the 90 required days remained in the calendar year, leaving most in a penalty-assured lurch. CMS extended the deadline for physicians to apply for MU hardship exemptions to EHR incentive program. The new deadline is now July 1, 2016. The extension is being granted “so providers have sufficient time to submit their applications to avoid adjustments to their Medicare payments in 2017.” The new application forms and instructions to file a hardship exemption are on the CMS website.

For physicians contemplating switching from paper charts to EHRs, Dr. Rice and his office staff offer these tips:

  1. Always remember, “Treat the patient, not the computer”
  2. Think about the big picture in terms of technology and how the flow and setup will affect the office. For example, how many screens, what type of computers, scanners, etc., should I choose? Who will be using these computers? Laptops vs. desktop computers in treatment rooms? A personal analysis needs to be conducted of what type of layout/format fits your practice.
  3. Choose a good program that has excellent technology support. Make sure to choose the correct computers and equipment necessary for the EHR program that is chosen for your practice.

Article by Lori M. Quiller, APR, director of communications and social media

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Official Statement on Legalization of Non-FDA Approved Marijuana Substances

Official Statement on Legalization of Non-FDA Approved Marijuana Substances

March 18, 2016 – “The use of marijuana for the treatment of various symptoms of diseases is an evolving discussion in this state and nation. Two years ago, the Alabama Legislature wisely decided and the Medical Association supported putting the discussion surrounding the efficacy of cannabidiol (CBD) in the treatment of neurologic conditions in children to the test by establishing and funding a strictly controlled drug trial. The preliminary results of that study indicate promise for more widespread use of CBD in patients. The exact CBD drug itself and dosages administered to patients in this drug trial were strictly regulated to ensure the safety of those involved. As physicians, our Hippocratic Oath demands we ‘first, do no harm.’ As well, the practice of medicine is evidence-based whereby the treatments and procedures we use are extensively researched and tested to make certain they are as safe as possible for the patients under our care. Given these bedrocks of the medical profession, the Medical Association cannot support the expansion or legalization, whether by legislation or ballot initiative, of marijuana or marijuana products in any form that have not received the same FDA approval as other medicinal compounds. Taking any position otherwise would not be based on scientific evidence and could unnecessarily place patients at risk.”

– Buddy Smith, M.D., president, Medical Association of the State of Alabama

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Physician Groups Issue Joint Statement on Medicaid Funding Cuts

Physician Groups Issue Joint Statement on Medicaid Funding Cuts

April 8, 2016 | MONTGOMERY – Without Fully Funding Medicaid, Patient Care at Risk

With the passing of the General Fund budget, lawmakers appropriated $700 million for Medicaid next year, $85 million short of what is needed to fully fund Medicaid. Now the Medicaid Agency is left with the tough decisions of which programs to cut, and how deep to reach into the pockets of Alabama’s citizens who can already barely afford their medications and health treatments. Services at risk of being cut are prescription drug coverage for adults, eyeglasses for adults, outpatient dialysis, prosthetics and orthotics, hearing programs, Program of All Inclusive Care for the Elderly (PACE), among other programs and services that patients across Alabama need to survive.

Medicaid is a critical component of our health care system, covering the young and elderly. More than half the births in Alabama and 47 percent of our children are covered by Medicaid, as well as 60 percent of Alabama’s nursing home residents. Without full funding, the Medicaid program will collapse, leaving these individuals without coverage. While uncompensated care is delivered every day in all 67 counties of this state, without Medicaid, charity care needs could skyrocket, crippling the health care delivery system and potentially placing the burden on those with private health insurance through higher premiums and co-pays.

Alabama Medicaid is the backbone of our state, supporting the health and welfare of the young and elderly citizens that physicians have pledged to protect during their medical careers. Consequently, we cannot support any solution other than fully funding a program that touches so many lives. Allowing Alabama Medicaid to continue with adequate funding is a smart investment in Alabama and her citizens. The current appropriated budget will have dire consequences.

Physician practices, hospitals and nursing homes are among the economic engines driving many Alabama communities. Closure of these health care providers will have a devastating impact on the state of Alabama and the health and prosperity of its citizens. The ripple effect will be felt from Mobile to Huntsville.

Therefore we call on the legislature and the Governor to work toward a permanent revenue solution to fully fund Medicaid.

Our organizations strongly believe that Medicaid matters … to all Alabamians.

For more information or comment, please contact:

Mark Jackson, Medical Association of the State of Alabama, (334) 954-2500
Linda Lee, Alabama Chapter, American Academy of Pediatrics, (334) 954-2543
Jeff Arrington, Alabama Academy of Family Physicians, (334) 954-2570

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Official Statement on the Medicaid Funding Crisis

Official Statement on the Medicaid Funding Crisis

May 5, 2016 – Alabama’s physicians are urging our state lawmakers and Gov. Bentley to start now to find a permanent revenue solution to fully fund Alabama Medicaid before the next fiscal year.

“Alabama already runs the most bare-bones Medicaid program in the country,” said Medical Association Executive Director Mark Jackson, “so to end this legislative session without an appropriate funding solution is more than heartbreaking. It’s dangerous. In just five months, one-quarter of our state’s population will be at risk of losing their access to health care because of the legislature’s inability to come to an agreement on funding options that would have helped close the $85 million gap in Medicaid’s budget. More than half the births in Alabama and 47 percent of our children are covered by Medicaid, as well as 60 percent of Alabama’s nursing home residents. Without full funding, the Medicaid program will collapse, leaving these individuals without coverage. We are asking Gov. Bentley and our legislators begin work today to find a permanent funding plan to secure Medicaid and reassure our residents that the medical care they need will remain within their grasp. The Medical Association remains ready to work with our elected officials to find a permanent solution to the Medicaid funding crisis.”

The Medical Association believes Alabama Medicaid is more than an insurance program for the poor and underinsured and must be fully funded as it is critical to the health care infrastructure of our state. Alabama Medicaid provides health coverage for eligible children, pregnant women, and severely disabled and impoverished adults – about 1 million Alabamians.

Alabama’s physicians strongly believe that Medicaid matters … to all Alabamians.

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Statement Opposing VA Proposed Rule on APRNs

Statement Opposing VA Proposed Rule on APRNs

Alabama Delegation Supports AMA Resolution Opposing Proposed VA Rule

UPDATE June 16, 2016: This week at the AMA Meeting the Association’s AMA Delegation joined others in support of a resolution opposing the proposed Department of Veterans Affairs rule that would expand the role of all Advanced Practice Registered Nurses, including nurse anesthetists.

The AMA resolution in opposition to the VA proposal follows earlier statements in opposition to the rule, and is in line with the Association’s position, and reads that the policy in the rule is “antithetical to multiple established policies of our AMA and thus should not be implemented.” The resolution directs AMA staff to assess feasibility of pursuing federal legislation to prevent the rule, calls on Congress to disapprove the rule, and suggestion collaborations between the AMA and other medical professional organizations to oppose the final adoption of the rule.

Dr. Carolyn Clancy, the VA’s Assistant Deputy Under Secretary for Health Quality, Safety and Value, spoke before the AMA reference committee encouraging members to submit comments during the 60-day public comment period, which ends July 25. Comments may be submitted online at www.SafeVACare.org.

It is the opinion of the Medical Association that this proposed rule change would undermine the delivery of care within the VA system. Our country’s health care system relies on physician-led teams to improve care and reduce costs. Physicians receive more than 10,000 hours of education and training and bring a wealth of value to the health care team. To deny any patient access to qualified physician-led, team-based care is simply inadequate, and our nation’s veterans deserve more from our health care system. In 2014 the Medical Association spearheaded a registry of physicians willing to treat veterans outside the VA system hoping to shorten the amount of time our veterans face before getting appropriate medical care.

Protecting Veterans’ Access to Physician-Led Medical Care

UPDATE June 10, 2016: As previously reported, the Medical Association is joining various medical associations and societies in opposition to the Department of Veterans Affairs’ proposed amendment to its medical regulations to permit full practice authority of all VA advanced practice registered nurses (APRNs) when acting within the scope of their VA employment.

Now, there is a letter being circulated by U.S. Rep. Dan Benishek (R-MI) expressing his “deep concern about the potential impact of this change to the long-standing best practices on the veterans the VHA serves.” Rep. Benishek, who is Chair and Ranking Member of the House Veterans’ Affairs Subcommittee on Health, began circulating his letter of support to continue physician-led health care in the VA medical system in late May, wrote “a sudden change to the status of nurses and the abandonment of the care team model would be extremely disruptive, leaving many of us with inappropriate staffing ratios which would directly compromise patient safety and limit our ability to provide quality care to veterans.”

To date, Alabama Reps. Martha Roby and Mo Brooks have signed on in support of Rep. Benishek’s letter. The Medical Association will be calling on all of Alabama’s Congressional Delegation to do the same. While the Medical Association applauds the VA for addressing the challenges that face the patients inside the VA health care system, the Association is drafting comments to submit opposing the proposed rule because we believe a physician-led team is the best approach to improving quality care for our nation’s veterans.

UPDATE June 3, 2016: The Medical Association will be joining the American Medical Association and other state medical associations and societies in opposition to the Department of Veterans Affairs’ proposed amendment to its medical regulations to permit full practice authority of all VA advanced practice registered nurses (APRNs) when acting within the scope of their VA employment. While the Medical Association applauds the VA for addressing the challenges that face the patients inside the VA health care system, the Association is drafting comments to submit opposing the proposed rule because we believe a physician-led team is the best approach to improving quality care for our nation’s veterans.

This rule proposed by the Department of Veterans Affairs is intended to increase veterans’ access to VA health care by expanding the pool of health care professionals who are authorized to provide primary health care and other related health care services to the full extent of their education, training, and certification, without the clinical supervision of physicians. The proposed rulemaking would establish additional professional qualifications an individual must possess to be appointed as an APRN within VA. The proposed rulemaking would subdivide APRNs into four separate categories including certified nurse practitioner, certified registered nurse anesthetist, clinical nurse specialist, and certified nurse-midwife. The proposed rulemaking would also provide the criteria under which VA may grant full practice authority to an APRN, and define the scope of full practice authority for each category of APRN.

It is the opinion of the Medical Association that this proposed rule change would undermine the delivery of care within the VA system. Our country’s health care system relies on physician-led teams to improve care and reduce costs. Physicians receive more than 10,000 hours of education and training and bring a wealth of value to the health care team. To deny any patient access to qualified physician-led, team-based care is simply inadequate, and our nation’s veterans deserve more from our health care system. In 2014 the Medical Association spearheaded a registry of physicians willing to treat veterans outside the VA system hoping to shorten the amount of time our veterans face before getting appropriate medical care.

Therefore, the Medical Association urges the Department of Veterans Affairs to maintain the integrity of the physician-led health care team model within the VA health system to ensure greater integration and coordination of care for our veterans and improve health outcomes.

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Physician Groups Issue Joint Statement on 2016 Special Session Announcement

Physician Groups Issue Joint Statement on 2016 Special Session Announcement

July 27, 2016 | MONTGOMERY – Our organizations applaud the Governor and are encouraged that he has taken the first step toward fully funding Alabama Medicaid by announcing his intention to call a special session.

As for his proposal for a lottery, we support the passage of new revenue that will provide for a long-term fix for Medicaid. As with any legislation, we will need to see the details of what he is proposing to ensure that it does in fact fully fund Medicaid’s needs for the long term before we can take a formal position.

In addition to the need for long-term funding, there is also a critical need to fix the $85 million shortfall in the 2017 budget, which the lottery will not do because of the time necessary for implementation. Consequently, it is important that the Governor and lawmakers find both a solution for 2017 and a long-term a revenue stream for Alabama Medicaid. We are concerned that the Governor did not address a short-term funding solution in his announcement today.

Alabama Medicaid is the backbone of our state, supporting the health and welfare of the young and elderly citizens that physicians have pledged to protect during their medical careers. Consequently, we cannot support any solution other than fully funding a program that touches so many lives. Allowing Alabama Medicaid to continue with adequate funding is a smart investment in Alabama and her citizens.

Physician practices, hospitals and nursing homes are among the economic engines driving many Alabama communities. Closure of these health care providers will have a devastating impact on the state of Alabama and the health and prosperity of its citizens. The ripple effect will be felt from Mobile to Huntsville.

Our organizations strongly believe that Medicaid matters … to all Alabamians.

For more information or comment, please contact:

Mark Jackson, Medical Association of the State of Alabama, (334) 954-2500
Linda Lee, Alabama Chapter-American Academy of Pediatrics, (334) 954-2543
Jeff Arrington, Alabama Academy of Family Physicians, (334) 954-2570

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Official Statement on Special Session/Medicaid Funding

Official Statement on Special Session/Medicaid Funding

Sept. 7, 2016 – The Medical Association of the State of Alabama would like to thank the members of the Alabama House of Representatives and Senate who supported the passage of the BP legislation today, which will provide much needed additional funding for Alabama Medicaid. We are pleased that our lawmakers have worked together for a solution for FY 2017 as well as providing additional funds for FY 2018. We are hopeful this additional funding will allow physician practices that were forced to lay off individuals to resume normal operations and continue to provide access to care to their Medicaid patients.

“Alabama already runs the most bare-bones Medicaid program in the country,” said Medical Association of the State of Alabama Executive Director Mark Jackson. “Without this additional funding, the cuts that Medicaid had implemented beginning Aug. 1, would have been dangerous to the infrastructure our state’s health care system. This additional funding will provide some stability to the system which covers more than half the births in Alabama, 47 percent of our children, and 60 percent of our nursing home residents.”

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MACRA 911: Getting Started

On April 16, 2015, President Obama signed into law the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), significantly changing the health care financing system for the first time since 1965. The details of these sweeping changes are still being worked out, but all physicians should make plans for the new payment system.

MACRA repealed the Sustainable Growth Rate (SGR) payment system, which governed how physicians were paid under Part B of the Medicare program, and replaced its fee-for-service reimbursement model with a new two-track system requiring physicians to accept a certain amount of risk: Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs).

While MACRA only impacts Medicare payments, commercial payers typically follow Medicare’s payment models, and it is likely that risk will be more prominent in the commercial setting over the next several years. This is just the beginning of the official rulemaking process, but it is already clear that physicians will have a choice in whether to participate in MIPS or meet requirements for an APM.

The Medical Association is studying the proposed rule and may provide comments particularly on those provisions of the rule of most significance to smaller practices. The timeline of the implementation of MACRA is of the utmost importance in that physicians will begin reporting Jan. 1, 2017, which will affect Medicare payments in 2019. The Association will provide more information as it becomes available.

Here are the steps you can take to prepare your practice for one of the two new Medicare paths:

Review your quality measurement and reporting. Understanding current quality reporting requirements and how you are scoring across both the Medicare Physician Quality Reporting System (PQRS) and private payers will help your practice be better suited for the upcoming changes.

Access and review your Medicare Quality and Resource Use Reports (QRUR) to see where you can make improvements related to cost ahead of time. Two particularly important components to identify as you prepare for meeting the care coordination requirements are: (1) your most costly patient population conditions and diagnoses, and (2) targeted care delivery plans for these conditions.

Tip: You can access your 2014 annual PQRS feedback reports and QRURs on the CMS Enterprise Portal using your Enterprise Identify Data Management account. Learn more about how to access these reports. If you are part of a large practice, you may need to talk to your administrator about accessing your QRUR.

Understand your patient data and benchmarks. Data registries can streamline reporting and improve performance scores. You can view a list of 2016 CMS-approved qualified clinical data registries and contact information on the CMS website.

Check on your electronic health record (EHR). If you use an EHR, contact your vendor to discuss how its product supports adoption of new payment models.

Make sure your EHR is certified to the Office of the National Coordinator for Health IT’s (ONC) 2014 or 2015 certification requirements. Using a 2014 or 2015 edition EHR is essential for participation in either MIPS or APMs.

Ask your vendor when it will update your software to the 2015 certified edition and whether reporting quality measures through the EHR is a viable option based on the proposed MIPS quality requirements.

Tip: You can check your product’s certification in a listing by the ONC.

For more information on how to prepare for the new Medicare payment systems, review this MACRA checklist.

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MACRA 911: MIPS vs. APM

While the ink is barely dry on the 962 pages of proposed regulations issued in April by CMS, the ripples of the Medicare Access and CHIP Reauthorization Act (MACRA) is already being felt throughout the health care industry. Keeping in mind this is still a proposed rule with comments to CMS due at the end of June, the final rule could very well look much different from what has been proposed. One thing is very clear – MACRA, in whatever form it finally takes, formally replaced the Sustainable Growth Rate (SGR), which would have continued to cut physicians’ reimbursement by 21 percent each year had it not been eliminated last year.

The Medical Association is studying the proposed rule and may provide comments particularly on those provisions of the rule of most significance to smaller practices. The timeline of the implementation of MACRA is of the utmost importance in that physicians will begin reporting Jan. 1, 2017, which will affect Medicare payments in 2019. The Association will provide more information as it becomes available.

MACRA repealed the SGR payment system, which governed how physicians were paid under Part B of the Medicare program, and replaced its fee-for-service reimbursement model with a new two-track system requiring physicians to accept a certain amount of risk: Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs).

It’s estimated that in 2017, about 90 percent of practices will fall into the MIPS category, and it will serve as a stepping stone for some of those practices to join APMs in subsequent years. The data collected during the 2017 calendar year reporting period will be reflected in 2019 payment adjustments.

While MACRA only impacts Medicare payments, commercial payers typically follow Medicare’s payment models, and it is likely that risk will be more prominent in the commercial setting over the next several years. Initially, physicians can choose MIPS or join an APM such as an accountable care organization or patient-centered medical home. If they make no choice or are deemed to be ineligible for an APM incentive payment, they will be assigned to MIPS.

Merit-based Incentive Payment System (MIPS)

The majority of physicians today participate in one or more of three existing payment incentive and quality improvement initiatives – Physicians Quality Reporting System, Meaningful Use and the Physicians Value-Based Payment Modifier – which will be dissolved as separate programs and melded into MIPS.

Under MACRA, physicians under MIPS will have to report their performance measures to CMS to be graded on four factors:

  1. Quality of Care – 30 percent
  2. Use of Resources – 30 percent
  3. Meaningful Use of EHRs – 25 percent
  4. Clinical Practice Improvement Activities – 15 percent

High-scoring physicians will get a bonus while low-scoring physicians will see a reduction in their fees. Physicians will be allowed to choose the quality measures upon which they will be evaluated. For the calculation of payment bonuses and penalties (and for ease of eventual consumer use through public reporting on Physician Compare), the Department of Health and Human Services (HHS) will be tasked with developing a composite score for each physician based on these factors. Maximum bonuses and penalties will be 4 percent in 2019, 5 percent in 2020, 7 percent in 2021, and 9 percent in 2022 and beyond. Additional funding of up to $500 million a year will be provided for separate bonuses for “exceptional performance,” from 2019 through 2024.

Alternative Payment Models (APMs)

Physicians choosing an APM will have to join an accountable care organization or an approved patient-centered medical home, or otherwise be in an alternative payment model entity where payment is at least partly based on quality performance and on total spending. Payment tied to performance must be 25 percent of a doctor’s or group practice’s Medicare revenue in 2019, increasing to 75 percent in 2022.

Physicians who join a CMS-approved alternative payment model will get an annual 5 percent bonus in their fees from 2019 to 2024. And, starting in 2026, physicians in alternative payment models will receive an annual across-the-board fee increase of 0.75 percent. Physicians participating in MIPS will get a 0.25 percent annual increase.

CMS proposes an approach to implementing the MACRA APM pathway through which eligible clinicians can become “qualifying participants” and earn statutorily specified incentives for participation. Advanced APMs must meet three proposed requirements deriving from the MACRA statute:

  1. Required use of certified EHRs;
  2. Payment for covered professional services based on comparable quality measures; and,
  3. Either being an enhanced medical home or bearing more than “nominal risk” for losses.

Joining an APM requires physicians to accept a certain degree of risk. Unfortunately, CMS has not yet adequately defined what degree of risk participants must accept to qualify. However, CMS proposed a “generally applicable financial risk standard” requiring APMs to include provisions that, if actual expenditures exceed expected expenditures, CMS can withhold payment, reduce payment rates, or require the APM to incur a debt to CMS. The risk must be more than nominal, which CMS accepts as “meaningful for the entity but not excessive.”

For more information about how MACRA can affect your payments, check out Health Affairs’ Health Policy Brief on Medicare’s New Physician Payment System from April 21, 2016.

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MACRA 911: Will MACRA Destroy the Small Physician Practice?

The Centers for Medicare and Medicaid Services may be serving MACRA up as “part of a broader push toward value and quality,” but most small physician practices feel the federal regulation will more likely push them out of business, according to a new survey.

In a May survey by Black Book Market Research of 1,300 physician groups with five or less clinicians showed 67 percent of high Medicare-volume physicians said MACRA means “the end of their independence.” These practices believe they “will not have the technology, capital or staffing to sustain under the conditions of the Merit-based Incentive Payment System (MIPS).”

The survey also shows that a strong majority of smaller practices are struggling with reporting requirements, revenue collection, and competition from larger practices and physician networks:

  • 89 percent of respondents said they “expect to minimize Medicare volumes” to avoid having to submit reports for quality improvement activities or cost performance
  • 77 percent said they currently are financially struggling “due to physician staffing losses to larger group practices and hospital integrated delivery networks”
  • 72 percent said they “blame their under-performing billing technology and compounding payment issues” for their financial woes

“Physician payment based on 2017 performance isn’t scheduled to kick in until 2019,” Doug Brown, managing partner of Black Book, said in a statement. “That’s far too long to maintain operations for the most stressed practices to hold on with outmoded technology and scarce billing support.”

Most small physician practices appear to agree. Nearly four-fifths of survey respondents (78 percent) said they anticipate joining a larger practice or network “to gain needed reporting, revenue cycle tools and support before 2019,” Black Book said.

However, the survey revealed that 63 percent of practices with fewer than 10 practitioners, as well as solo practice physicians, have still not settled on a technology suite or set of products that delivers to their expectations on Meaningful Use, clinician usability, interoperability and coordinated billing and claims. But over a third of those slower adopters expect to make product decisions before the end of this calendar year.

American Medical Association President Dr. Andrew Gurman is a solo-practice orthopedic hand surgeon who doesn’t use an EHR, according to MD Magazine.

“I don’t have an EHR,” Dr. Gurman told MD Magazine. “I just take the penalties.”

MACRA’s payment adjustments are scheduled to begin in January, and CMS has already made moves to help small practice physicians. HHS recently announced it will award $100 million over the next five years to organizations that provide support and training to Medicare physicians in group practices with 15 or fewer clinicians to comply with MACRA.

The Medical Association is studying the proposed rule and may provide comments particularly on those provisions of the rule of most significance to smaller practices. The timeline of the implementation of MACRA is of the utmost importance in that physicians will begin reporting Jan. 1, 2017, which will affect Medicare payments in 2019. The Association will provide more information as it becomes available.

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