Curbside Consult by Dr. Jayne 6/12/17

Last week, CMS kicked off a multi-pronged outreach program to help providers prepare for the transition to the new Medicare Beneficiary Identifier (MBI). New Medicare cards, to be issued starting in April 2018, will have a new identification code for each beneficiary, which is not based on the Social Security number. Congress mandated that all cards be replaced by April 2019, and vendors have been working on adding functionality to hold the new identifiers for some time. There will be a nearly two-year transition window where providers can use either the MBI or the old Medicare number, as well as secure lookup tools for both providers and patients. The ID will include both numbers and letters – along with many others, I’ll probably still call it a “Medicare number” regardless of the presence of letters.

There are nearly 58 million people on Medicare, and the goal of the program is to fight identity theft, fraud, and illegal use of SSNs. Unfortunately, this doesn’t help the rest of us who are constantly asked to provide our SSNs across the rest of the healthcare space. I checked with a couple of my clients to see if they have plans to phase out use of the SSN in general and they haven’t really thought about it. I’ve had quite a few adventures in healthcare this year, and every single one has asked for not only my SSN but also had fields on their patient data forms to gather the SSN of a guarantor where one exists.

Even with a Congressional mandate, this process has taken years. It was in the works prior to the passage of MACRA, but that law accelerated the timetable. Although CMS has had a website about the project for some time, it’s unclear how much providers understand at this point. Providers and their office leaders have been through a lot of federally-induced change in the last few years, including the prolonged ICD-10 transition and now the distraction of MIPS, along with continued Meaningful Use pressures for our Medicaid friends. It could be that people just aren’t planning to pay too much attention until it gets closer. The other piece of it is that vendors aren’t entirely ready yet, so it’s not yet “real.” Once the new ID field starts appearing in systems, then perhaps it will be worth thinking about. I searched my email archives and found a notice from our vendor a few months ago, mentioning that it will be added to the system towards the end of 2017. One of the benefits (and sometimes challenges of) a vendor-hosted, cloud-based system is that features just appear after a brief announcement, so we’ll have to see what other communication we receive as it gets closer.

The migration to the new MBI is not just a digital change but one that will require operational and process changes as well. Practices may want to consider proactive outreach to their patients to educate them about the new cards and the need to bring them to the office, as well as to allow for additional check-in time on their first visit after they receive their new cards. Sites will need to educate staff about their cutover plan and the need to maintain both identifiers during the transition, and the fact that they can’t simply remove the old IDs from the system since claims may still be working their way through the system. Everyone should be readying a plan, even if it’s just high level at this point. I’d be interested to hear what organizations of varying sizes are doing at this stage in the game.

In other CMS news, Tuesday is the last day to submit formal comments on the FY18 Inpatient Prospective Payment System and Long Term Acute Care Hospital proposed rule. The rule also includes language around Indian Health Service and other Tribal facilities. Most notably, it modifies the EHR reporting period from full calendar year to 90 days, which many of us are eagerly awaiting. Other nuggets include a new exception from the Medicare payment adjustments for eligible professionals, hospitals, and critical access hospitals if they demonstrate that they can’t comply with being meaningful users because their EHR has been decertified. There’s always a path for no payment adjustments for EPs who furnish all their covered services in the ambulatory surgical center setting. Even if you don’t have any comments to offer, the closure of the comment period is a milestone in the countdown to a final rule, which many of us are eagerly awaiting.

I spent some time this weekend at a continuing education conference at one of the local medical schools. I was looking forward to it, since it was targeted towards community physicians and was an opportunity to engage with some of the leaders in the field about the best ways we can co-manage patients. The content was outstanding, with concise presentations offering real-world advice rather than the more esoteric academic discussions I’ve seen in some of their sessions in the past. However, it was marred by attendees behaving badly. The worst example was a physician who was clearly responding to emails and/or transcribed phone messages, and who was using the voice recognition features on his phone to do so. If you have to multitask, you need to either do it non-verbally or you need to step out of the room.

The first couple of times he did it, I’m not sure people understood what was going on, because it looked like he might be having a sidebar conversation with the person next to him and was just being loud. As it continued, it was more obvious what he was doing, yet no one close to him said anything although there were plenty of people giving him dirty looks. Finally, one of the CME door monitors came forward to address the situation and he quit. Still, you have to wonder in what universe someone thinks that’s OK and how we’ve arrived at a place where people’s need to try to do it all interferes with them being a considerate member of society.

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