Archive for September, 2016

Problems with ICD-10 Implementation? Check Out These Tips…

Ready or not, tomorrow is the day. While the Medical Association has been and remains an opponent of the forced switch to ICD-10, we fought it and in 2014 got a one-year delay. We continued fighting the mandated changeover in 2015, but when it became evident it would be implemented, we worked diligently to soften the landing as much as possible.

ICD-10 will be implemented on Oct. 1, so the AMA revised its online ICD-10 information and resources. If physicians experience any problems with the processing of their claims or other administrative transactions, they should take the following steps:

Medicare

An ICD-10 complaint form will be available on the AMA ICD-10 web page on Oct. 1 to report problems with Medicare claims.

Please note: Forms will be forwarded to the Centers for Medicare & Medicaid Services (CMS). The American Medical Association will not provide individual responses to each complaint.

Physicians can also contact their Medicare Administrative Contractor (MAC) or monitor their MAC’s website for information on problems with ICD-10.

You may also contact CMS directly by emailing ICD-10 ombudsman Dr. William Rodgers.

Medicaid

Check Alabama Medicaid’s ICD-10 website for updated information about implementation and a method of contact for issues.

Commercial Payers

Check the payer’s website for information about ICD-10 implementation and a method of contact for issues.

  • For UnitedHealth Group, physicians can use the following email address ICD10questions@uhc.com
  • For Humana, physicians can use the following email address ICD10Inquiries@humana.com
  • For Anthem, physicians should contact the Provider Service Call Center for the locality and line of business involved at Anthem.com.

Vendors

Any issues with practice management systems, electronic health records (EHR), billing vendors, or clearinghouses, should be directed to the company.

Physicians should also contact their state or specialty medical society for advice on handling problems and to find out if other practices are experiencing similar issues.

Note:  CMS announced on Sept. 25 that the ICD-10 Coordination Center and claims processing will continue to operate even if there is a government shutdown due to the budget.

Medicare Advanced Payment

CMS announced that MACs will issue advanced payments in situations where the MAC is unable to process claims within established time limits because of administrative problems, such as contractor system malfunction or implementation problems. An advanced payment is a conditional partial payment and will require repayment.

To apply for an advance payment, the physician will be required to submit the request to their appropriate MAC. Should there be Medicare systems issues that interfere with claims processing, CMS and the MACs will post information on how to access advance payments. CMS does not have the authority to make advance payments in the case where a physician is unable to submit a valid claim for services rendered.

Updated Clarifying Questions and Answers for CMS ICD-10 Flexibilities

On Sept. 22, CMS released updated “Clarifying Questions and Answers Related to the July 6, 2015, CMS/AMA Joint Announcement and Guidance Regarding ICD-10 Flexibilities.”  Information added includes the naming of the CMS ICD-10 Ombudsman, Dr. William Rodgers, and additional information about prior authorizations, Medicare Advantage plans, application to other provider types, Medicare advanced payments, cross-over claims, and audits.

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Dr. Buddy Smith on ICD-10: “This should be a wake-up call … to be an advocate”

Medical Association President Buddy Smith, M.D., has had it with government mandates in medicine, likening ICD-10 to the proverbial “straw that broke the camel’s back.”

“It has gotten to the point of absurdity. We need more of the ‘practice’ of medicine and less of the ‘process’ of delivering medical care. We are forced to jump through hoops checking boxes that don’t do the first thing to improve patient care,” Dr. Smith said.

In his opinion, forced adoption of ICD-10 tops the list of practice aggravations and only adds to the frustrations an already overburdened physician workforce is having with their chosen profession.

Seeing the negative effect it would have on its members, over the past few years the Association worked with Congressman Gary Palmer (R-AL06) and the Alabama Delegation on legislation putting off ICD-10 adoption. The Association also worked with state media to raise awareness of the problems with ICD-10 and even the Legislature, ushering through a bipartisan resolution by Alabama’s two physician-Senators Tim Melson and Larry Stutts this spring urging Congress to either delay ICD-10 or find a way to offset the cost to medical practices. In the end, however, medicine was unfortunately unsuccessful, and the full effects will not be known for some time.

“We gave it our best, but with hospitals, insurance companies and the entire health care data and technology industry on the other side, the voices of physicians – like my dear friend the late Dr. Jeff Terry – were drowned out,” Dr. Smith said.

A silver lining, Dr. Smith says, was the Medical Association’s success in petitioning Blue Cross Blue Shield of Alabama and VIVA HEALTH along with Alabama Medicaid to implement “grace periods” for physician coding errors made under ICD-10 as is being allowed under Medicare Part B. Few other states have any commercial payors implementing any type of “grace period.”

“Most of our colleagues in other states will have zero leeway if they miscode for anyone other than a Medicare patient,” Dr. Smith said, “and even though we must still code under ICD-10 we are better off than most physicians in this country.”

In his rural Clay County medical practice, Dr. Smith tries to focus on the positive when there is bad news to deliver to patients. For physicians, ICD-10 implementation certainly fits that description. But there is hope, Dr. Smith believes, pointing to medicine’s successes on the state level as not only proof that doctors can be effective advocates for their patients and professions but also to using those successes as a blueprint for future battle plans.

“When you look at the multitude of proposed standards of care, trial lawyer tricks and threats to medicine our Medical Association and its members have fought off over the years, it’s truly remarkable,” he says. “We can succeed, but we all have to be in this together.”

Engaging more doctors and expanding the influence of organized medicine, he says, is the key to learning from the losses we’ve encountered while expanding on our successes. After losses on the Affordable Care Act and now ICD-10, while many in Washington are saying “organized medicine is dead” Dr. Smith believes the opposite is true. He thinks ICD-10 will instead be a turning point where physicians finally stand up and say enough is enough.

“This should be a wake-up call to my colleagues, not just in Alabama but around the nation, that non-physicians are dictating the future of our profession and you can’t afford not to be an advocate for the profession,” he said. “You are most vulnerable to giving up after you’ve suffered a loss – and ICD-10 was a loss for medicine – but we cannot abdicate the remainder of our profession without fighting every inch of the way.”

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What You Said…about ICD-10

During the launch of ICD-10 on Oct. 1, we wanted to know how the day was going for our physicians and their staff, so we asked them. Below are a few responses we received about the implementation of the new billing system. Keep in mind the true test of the implementation of ICD-10 won’t be fully realized for some time:

“I think the whole thing is unworkable, a waste of time and will make my office much less efficient. I am not sure why doctors continue to tolerate these ridiculous mandates.”
— Sen. Larry Stutts, M.D., OB/GYN from Sheffield

“Much anticipated arrival of ICD-10 today that passed smoothly for patients and practitioners alike; the final grade is now left with our billing service.”
— Maartin Wybenga, M.D., family physician from Prattville

“We have been working to prepare for years with lots of study, classes and tests. It is disappointing on Day One that 100% of our claims have been rejected. It appears our clearing house is not ready. I’m glad I have put money in a savings account to be prepared. It should be made clear to EVERYONE that we are the only country in the world that uses ICD-10 for payment. It was designed to allow statisticians to monitor disease. This is ALL about Big Brother keeping track of what we do. I am struck by the idiocy of the bureaucrat many years ago that was once reported to say that the expense to doctors would be nothing more than ‘printing’ fees for a few new superbills.”
— Allen Meadows, M.D., allergist from Montgomery

“We had no problems today. We were slower in documentation trying to find the new codes. However, the jury is not in just yet, since we haven’t yet had time for any claims to be rejected. We are cautiously optimistic.”
— Beverly Jordan, M.D., FAAFP, family physician from Enterprise

“Since our EMR did not properly work pulling up the new codes as promised, we had a difficult day searching for codes online, ultimately slowing us down.”
— McCain Ashurst, M.D., OB/GYN from Montgomery

“There’s been a lot of comments about how specific ‪‎ICD-10‬ is, but I have been surprised by how many codes are even less specific than ICD-9.”
— Steven P. Furr, M.D., former president of the Medical Association and family physician from Jackson

“No problems here at all … I took the day off!”
— Tim Stewart, M.D., pediatrician from Huntsville

“Although today was a day I have been dreading for quite some time now, it has gone smoother than I ever expected it to. I believe the transition has gone as well as it has gone because of adequate preparation. My staff, my software vendor and IT support team prepared exceptionally well for the storm. My quick navigation tools were already in place, and my office had several ‘ICD-10 dummy days’ where we practiced entering patients/visits with the new ICD-10 codes. My software vendor also gave us the ability to convert to the new ICD-10 codes effortlessly from our old ICD-9 database. My staff and I also attended seminars by the Medical Association and Baptist Hospital, which helped immensely. As with any storm, your best chance of surviving is to be adequately prepared. We have had this forecast on the radar for quite some time now. For so long it appeared we were blowing a lot of hot air in an attempt to get the hurricane to go away or to change its course as opposed to just hunkering down, preparing, and allowing it to do would it was ultimately going to do. All storms, no matter how bad they are, will eventually blow over. What remains to be seen at this point is how well the change will affect my reimbursements and how much of a delay and additional expenses I will incur.”
— Jefferson Underwood III, M.D., internist from Montgomery

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ICD-10 Is Here…Now What?

It’s been just more than a week since the debut of ICD-10, and reports of its implementation have been mixed. While some physicians and their staff had little trouble, others had a very long day of coding issues.

Keeping in mind the true test of ICD-10’s implementation won’t be realized for a few more weeks, we contacted Kim Huey, also known as Kim the Coder, to find out what physicians need to know next about this new billing and coding system:

  • Practices will be able to use unspecified codes after this first year IF that is the only appropriate code. There has been much confusion about Medicare’s announcement that claims would not be denied for lack of specificity for the first year. That does not mean unspecified codes will be automatically denied on Oct. 1, 2016. In some cases, you don’t have any other choice. For example, with Vitamin D deficiency, the only options are rickets or unspecified. Obviously, not everyone with Vitamin D deficiency has rickets. Practices should focus on the specificity already documented or on specificity that would support a particular diagnostic test or course of treatment.
  • Don’t rely completely on crosswalks built into your EMR. Many of these only take you to the most unspecified code available. Others don’t take into consideration Guidelines and Notes contained within the ICD-10-CM book. Some have chosen not to give their physicians any training – that is a huge mistake! Software simply cannot capture all the nuances in the new codes. For example, COPD with bronchitis with exacerbation is one code in ICD-9-CM. This takes three separate codes in ICD-10-CM. Does the software prompt you to enter the additional codes? EMRs vary widely in their search functions, in which some ask the additional questions necessary to choose the appropriate code, while others simply provide a crosswalk that may or may not be correct. When looking at the differences in coding between ICD-9-CM and ICD-10-CM, a practice needs to look up the code in ICD-10-CM to find the differences in the guidelines. This would not be apparent if just using the crosswalks.
  • Everyone who touches a diagnosis code needs some amount of training. Training may vary from just an hour to several hours, whether it is a lab technician or clinical staff or a receptionist who calls in for pre-authorizations.
  • There are some good things about the ICD-10-CM changes. Hypertension is no longer classified as benign or malignant. Some conditions, such as asthma can now be coded to capture severity that may support additional treatment or more expensive medications. There is now one code for vaccinations – Z23. There are more specific codes for patient refusal of treatment, underdosing of medication and other circumstances that may affect physician quality reporting.
  • Identify the particular challenges in your practice. Coding for injuries is a huge change in ICD-10, but if you don’t see injuries, don’t sweat it. Coding for diabetes is another big change – walk through the coding guidelines to see the differences in information captured. For example, OB practices will now code for the trimester and weeks of gestation – that is almost always documented – and the practice needs to find a way to transfer that to a code on the claim.
  • External Codes are not mandated. That is, you do not have to use them unless a particular payer requires it. We have all laughed about the External Cause codes such as burn from fire while on water skis, bitten by a duck, struck by debris from a spacecraft.

In response to a request from the Medical Association, Alabama Medicaid, Blue Cross Blue Shield of Alabama and VIVA HEALTH have said they will not penalize physicians for coding errors under ICD-10 as long as a valid ICD-10 code from the correct “family of codes” is used. This follows a similar policy by CMS for Medicare Part B claims announced in early July.

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What You’re Saying about ICD-10, One Month Later

Last month, we wanted to know how the day was going for our physicians and their staff during the rollout of ICD-10, so we asked them. It’s been one month since the official implementation of ICD-10. We checked in with those physicians to see how things were going with the new billing system, keeping in mind the true test of the implementation of ICD-10 may not yet be fully realized for some time:

“A lot of extra work and collections are down 25 percent. Enough is enough. ACA that is anything but affordable, electronic medical records that make a joke of a real history and physical, and now ICD-10.”
— Sen. Larry Stutts, M.D., OB/GYN from Sheffield

“The final grade on the initial implementation of ICD-10 rested with our billing service since as practitioners (two NPs and myself) we felt comfortable with it. This was due in part to having attended the Medical Association’s recent workshop in preparation. The billing service, leading up to the Oct. 1 deadline, worked closely with their third party internet vendor which resulted in a smooth transition to ICD-10 for them as well; very few claims have had to be resubmitted. Due to more time spent documenting but otherwise a fairly uneventful transition our overall grade is: A-. So far our income stream is not affected any.”
— Maartin Wybenga, M.D., family physician from Prattville

“After a few glitches in the first 72 hours, our claims are being paid. If we choose to, we can use ICD-10 to our advantage. We can use the expanded codes to prove the burden of illness in our patients, one of the three criteria we are being judged on by third parties (other being cost and outcomes).”
— Allen Meadows, M.D., allergist from Montgomery

“So far, it has added a couple of hours to my day every day in looking up the new codes. My coding department is further behind than ever, and we have yet to see ANY payments for charges for dates of service 10-1-15 or later. I’m holding my breath, hoping that the payments come quickly. The charges are getting easier to do, but I feel sure it will take me a few more months before I am really comfortable with all of them.”
— Beverly Jordan, M.D., FAAFP, family physician from Enterprise

“Truthfully, ICD-10 is incredibly disappointing. It’s a bureaucratic PoJ (piece of junk). It has more unspecified codes than ever before. About 65 percent of the codes directly crosswalk from ICD-9 so most of the codes offer no further information. The additional codes are often very nonspecific and sometimes even meaningless. Sometimes it is not even for sure what the codes mean. Certainly, another physician looking at it does not know what you mean when the code refers to other disorders of bone metabolism when previously everyone knew what osteopenia meant. It’s incredible that we are now having to do hundreds of additional clicks a day to upgrade the patient’s problem list to codes that offer no further information or even less specific than before. We have been sold a bill of goods that’s not worth the computer screen it is written on. We are suffering by wasting our valuable time and spending enormous amounts of money. Our patients are suffering because we are spending less time with them trying to treat their problems.”
— Steven P. Furr, M.D., former president of the Medical Association and family physician from Jackson

“So far the ICD-10 rollout has been like my one-month wedding anniversary… everyone is still alive. No major problems so far. The transition remains relatively smooth.”
— Jefferson Underwood III, M.D., internist from Montgomery

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ICD-10 Grace Period Ends Oct. 1

The one-year grace period for ICD-10 will end on Oct. 1, the Centers for Medicare and Medicaid Services announced in an update to its FAQ guidelines for the diagnostic code set.

ICD-10 went live on Oct. 1, 2015, and at the time CMS said it would not deny claims as long as physicians used codes in the correct “family” related to the treatment. However, with the grace period ending, physicians will now be held to using the correct degree of specificity in their coded claims.

“ICD-10 flexibilities were solely for the purpose of contractors performing medical review so that they would not deny claims solely for the specificity of the ICD-10 code as long as there is no evidence of fraud,” CMS said.

ICD-10, which contains more than 70,000 diagnostic codes, replaced ICD-9, which relied on just 11,000 codes. The grace period had only applied to claims submitted to Medicare and Medicaid, and while many commercial insurers offered similar flexibility, the majority did not.

For more information about ICD-10 and a list of resources, view the ICD-10 Update: Physician Resource in the NewsCenter.

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2016 Virtual Credit Card Legislation

After two years, the Medical Association successfully saw passage in 2016 of its legislation to prevent physicians from unknowingly accepting virtual credit cards (VCC) and their hidden fees as a form of payment from health insurance companies and RCOs, even though the Medicaid RCO system has yet to officially launch.

Having heard from its members that VCCs were a growing concern, the Association went to work again to pass the VCC bill this year after narrowly losing it at the end of the 2015 session. The Medical Association worked diligently between legislative sessions to build support for the VCC bill and was successful in passing the bill this year.

quintonrosskylesouthThe legislation – SB 291 by Sen. Quinton Ross (D-Montgomery) and Rep. Kyle South (R-Weaver) – ensures all health insurers and RCOs make physicians aware in their contracts of a physicians’ right to request payment via flat-fee “direct deposit” methods over VCCs, which charge a percentage-of-claims-based fee. The new law requires that all such physician requests for payment preference be honored.

Read Act 2016-320

Q: What is a VCC?

A: A virtual credit card (VCC) is a single-use credit card number. Physicians accepting VCCs are losing a percentage of their contracted rate for any claims paid via this method. The fees may be as high as 5 percent of the total payment amount and health insurers paying claims with VCCs often receive cash back (up to 1.75 percent) or other incentives. The bank or credit card company issuing the VCC is also paid for use of their card network. In other words, unknown to many physicians and their staff responsible for claims and billing, insurers and credit card companies are indirectly charging up to 5 percent of a claim for processing the transfer of money via VCC. In some practices, these fees may add up to substantial sums – and the charges are hidden.

Q: What does this legislation do?

A: The legislation requires health insurance companies and RCOs to place language into all their contracts with physicians outlining that a physician’s request to be paid with an ACH EFT (electronic funds transfer) must be honored. Under HIPAA, payments made via the Automated Clearing House may only be a nominal flat fee – for instance $0.34 instead of the 5 percent attached to some VCCs. The required language for all contracts, which must be in all caps, bolded 12-point font and offset from other language, reads as follows: “If a covered health care provider requests payment under a health insurance plan from a health insurer or its contracted vendor or a regional care organization be made using ACH electronic funds transfer, that request must be honored. Furthermore, such a request may not be used to delay or reject a transaction, or attempt to adversely affect the covered health provider.”

Q: Why is the language that an insurer or RCO cannot “attempt to adversely affect” a physician for requesting an ACH EFT payment over a VCC included?

A: That language protects a physician requesting an EFT payment from being penalized by the health insurer or RCO in some other manner, like denying or delaying payment simply because a physician requested an EFT.

Q: What you still need to do…

A: The Medical Association was successful in getting the law changed to ensure physicians are notified in their contracts of their right to be paid with ACH EFT payments over VCCs. Physicians and practices must individually decide whether or not they want to consent to the percentage-based fees associated with acceptance of VCCs. Additionally, because the Medical Association successfully included specific language be placed in each contract that the health insurer or RCO cannot delay or deny a transaction because of the choice of electronic funds transfer, each physician and practice should look for hidden “value-added” services. For instance, some ACH vendors have attempted to charge a higher fee for providing access to a 24-hour hotline. Under existing law, physicians are not required to enroll in such “value added” programs.

Q: Does this affect patients’ use of credit cards for payment?

A: No.

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Legislation Prevents Prosecution for Following a Physician’s Orders

chemicalengangerment_banner

Background

When the Alabama Supreme Court in 2013 interpreted a law intended to criminalize exposing children outside the womb to chemical substances to also include children in utero, it created significant new liability problems for pregnant women and their doctors. The chemical endangerment statute as passed by the Alabama Legislature was intended to criminalize the exposure of children to substances used in the production of methamphetamine and to meth itself.

The Medical Association heard concerns from a number of its members regarding the consequences of the Court’s interpretation for those caring for pregnant women and began examining the issue. That research and consultation with member physicians led the Association to begin discussions with the law enforcement community to produce mutually-supported legislation to prevent the normal practice of maternity care from being considered a crime for either the patient or her physicians. The concept for the legislation soon became part of the Association’s 2016 agenda. The legislation was proposed and passed this year, was signed by the governor and is now law.

Read Act 2016-399

Q: Why was this legislation necessary?

A: To protect pregnant women and their physicians from prosecution under the chemical endangerment law for the prescribing of legitimate medications and for recommendations for FDA-approved OTC medications. The legislation was also necessary to prevent any uncertainty of whether physicians needed to report the prescription or recommendation of such medications for pregnant women to the Department of Human Resources. Without the legislation, both a pregnant woman taking a legitimately prescribed medication or a recommended OTC medication and her physician could be considered to have violated the state’s chemical endangerment law, the state’s child abuse laws and potentially various other state laws and the physician would also technically have been required to make a report to the Department of Human Resources.

Q: Why didn’t the Medical Association stop this from going into effect?

A: Given that the setting was the Court and not the legislature or some other body empowered with rule-making authority, the Association did not have an opportunity to prevent this interpretation of the chemical endangerment law from going into effect or even to put in place exceptions for the normal practice of women’s medicine. Had these changes been proposed in the legislative or even regulatory arena, the Association would have lobbied against criminalizing normal maternity care. The Association did file an amicus brief asking the Court not to expand the purview of the law beyond those the legislature intended but that request was not honored.

Q: What changed through passage of this legislation?

clydechamblissaprilweaverA: The Association’s 2016 legislation that is now law – SB372 by Sen. Clyde Chambliss (R-Prattville) and Rep. April Weaver (R-Alabaster) – clarified that no one shall commit chemical endangerment of a child (including unborn) or any other crime for expoing a child in utero to a chemical substance if that substance was a legitimate prescription issued by a physician or a non-physician working within his/her scope of practice or for the recommendation to take an FDA approved over-the-counter medication. As well, no one is required to report such activities to any authorities. Many thanks are due to bill sponsors Sen. Chambliss and Rep. Weaver as well as leadership in the Senate and House for making passage of this important bill possible.

Q: Does this new law impose any new requirements for newborn and/or mother drug testing?

A: No, this law does not in any way place new requirements for drug testing newborns or their mothers or standardize such testing.

Q: Does this new law govern a situation in which a pregnant woman is abusing drugs?

A: Not necessarily. Under SB372, the mother of the unborn child must be taking the medication pursuant to a “lawful” prescription to be protected. If the mother is abusing drugs, by taking more than prescribed, or something not prescribed, then the woman would not be protected. The physician would be protected if he or she has a good-faith belief that the woman is taking a drug pursuant to a lawful prescription. However, there is no requirement on the physician to inquire.

Q: Do other aspects of the chemical endangerment law need to be reviewed and possibly changed?

A: Yes, this issue is a continuing discussion between physicians treating pregnant women, addiction specialists and law enforcement. The Association, along with a number of specialty medical societies including the American College of Obstetricians and Gynecologists, believe proposals should be explored that emphasize treatment in lieu of prosecution so that addicts can get the professional help and treatment they need.

Summary

The chemical endangerment problem the Association worked on this year prevents the normal provision of maternity care from being deemed a crime, both for the pregnant woman and her physicians. The Medical Association believes only physicians should establish medical standards and treatments. Each year the Association successfully pushes back against such proposals in the legislative and regulatory arenas on behalf of its members and their patients.

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MACRA 911: Will MACRA Make Interoperability Better?

MACRA 911: Will MACRA Make Interoperability Better?

In September, CMS Acting Administrator Andy Slavitt in a bold and surprising move announced that physicians will have more options to comply and avoid a negative payment adjustment in 2019. Just a few months ago CMS was considering delaying the implementation of the Medicare Access and CHIP Reauthorization Act, which is set to start Jan. 1, 2017, but instead offered physicians more flexibility to the MACRA program with four options for participation. But, will this additional flexibility to entice more physicians to participate in the Medicare reimbursement program also make interoperability better in the long run?

Now that physicians will have a choice in how they participate in MACRA, the question becomes whether a technology upgrade will be necessary as well. Because MACRA is designed to overhaul how physicians are paid under Medicare, how they will use technology to achieve value-based care will take a valuable role in the coming year. The success of MACRA and a physician’s technology will be based on interoperability, or the ability of two or more systems or components to exchange information and to use the information exchanged. It may sound simple, but is it?

Under the Merit-Based Incentive Payment System (MIPS) portion of MACRA, an eligible physician must allow a single unique patient to view, download or transmit their patient record, within a performance period, or allow them to use an application programming interface (API) to access their record–or a combination of both. However, value-based care cannot be achieved without the interoperable exchange of data and the analysis of the data, to improve care and lower costs.

Although CMS backtracked a little by giving physicians more choices in how they participate in the program, the start date of Jan. 1, 2017, remains the same giving physicians mere months to get tech-ready yet again for another government mandate.

“We’ll be smart if we look at the Quality Payment Program as a framework we can work with that if implemented with care, can begin the process of turning things around towards a more sensible, simpler approach where physicians and other clinicians will feel supported by laws and regulations, the technology vendors, and the infrastructure that surrounds them,” Slavitt said at the 2016 Annual Meeting of the American Medical Association.

“This is why we need to be so committed to a collaborative implementation, increased transparency, and a continual improvement process, so that over the next several years we allow feedback on the ground to inform the policies we implement.”

Nevertheless, John Squire, president and chief operating officer of Amazing Charts, a West Warwick, R.I.-based electronic health record software vendor, is less confident in small practices’ ability to succeed under MACRA. Squire, whose company’s provider clients are mainly in the 1 to 10 practice size range, says that most of them aren’t the least bit familiar with MACRA’s rules. He notes how many of them don’t have an IT staff, so no one is perusing the latest CMS regulations, meaning they only hear about them over time from physician association groups. “We are focused on educating these practices since they’re simply not ready,” Squire said. “CMS has a long way to go in terms of educating small practices,” he adds.

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