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Curbside Consult with Dr. Jayne 7/3/17

July 3, 2017 Dr. Jayne 2 Comments

No surprise here. A recent survey by the American Medical Association finds that physicians don’t feel they are prepared for quality reporting rules. The survey reached out to 1,000 practicing physicians who have been involved in discussions and decisions related to the Quality Payment Program within their practices. Nearly 90 percent of the physicians find MACRA’s requirements burdensome, with fewer than one in four feeling well prepared to meet those requirements in 2017. Specific areas cited as burdensome included the time required to report performance, understanding requirements, MIPS scoring, and the cost to capture and report data.

The AMA data notes that a little more than half (56 percent) of physicians plans to participate in the Merit-based Incentive Payment System (MIPS) with 18 percent expecting to participate in Advanced Alternative Payment Models (APMs). There were also some interesting statistics on how well physicians feel they understand MACRA and the QPP. Although 51 percent of physicians feel they are somewhat knowledgeable about the topics, only 8 percent describe themselves as deeply knowledgeable.

Although previous participation in quality programs such as PQRS and Meaningful Use seems to have helped physician readiness, only 25 percent of those with prior reporting experience feel well-prepared for the QPP. There were also concerns raised that those who may be prepared for 2017 reporting may not have the long-term financial strategies in place to succeed in 2018 and beyond. Small practices were called out as needing more assistance to be prepared, where large practices were more likely to be concerned about the organizational infrastructure needed to effectively report data.

Where the larger practices were more likely (79 percent) to have previously met Meaningful Use Stage 2, the smaller practices were mixed with 45 percent yes, 44 percent no, and 12 percent not knowing whether they had previously complied or not. Not surprisingly, primary care specialists were more likely to participate in APMs than non-primary care specialists (22 percent vs. 15 percent respectively). Multi-specialty practices seemed to be better prepared than hospital-based, solo, or single-specialty practices with greater participation in Advanced APMs and more optimism around a positive payment adjustment in coming years.

The report notes that its findings support assumptions that although some challenges are universal, small practices will need more assistance in meeting their goals. There is opportunity for CMS, medical societies, and other stakeholders to educate physicians and to help practices prepare for success.

Although the report doesn’t mention them specifically, some of those other stakeholders include vendors and consultants. I’ve seen a pretty significant uptick in messaging from the latter, although nearly all the emails I receive seem to be for clients on Epic. The vendor emails I receive are mostly targeted towards smaller practices who may not be on an EHR or who are looking to switch. These communications make everything look pretty rosy as far as ability to report on their platforms, but neglect to mention the amount of work needed to complete a conversion or bring a practice live on EHR in the first place.

My vendor is actually pretty good at providing information around the various quality and regulatory programs out there, even though it’s a niche specialty vendor and many of its clients have opted out of Meaningful Use in the past and plan to opt out of quality programs in the future. Whether your practice has opted out or not, there needs to be an ongoing dialogue and analysis to make sure that their plan still makes sense. Payer mixes can shift over time, especially with an aging population, and what may have made sense a couple of years ago may not make sense moving forward.

For independent practices, ongoing dialogue is also needed with local health systems or hospitals to determine how their strategy for value-based care will impact everyone else. There are several major players in my area, and none of them seem particularly interested in sharing data with the little guys, especially when smaller groups are potential competitors for procedural volume. It still seems to be less about the patient or controlling costs than it is about market share. I have yet to see any medical staff meetings devoted to helping admitting physicians stay in business by learning how to handle Meaningful Use or MIPS. I do see a lot of attempts to purchase practices, however.

CMS does seem to be trying to do its part to educate physicians, and recently released some new resources on its Quality Payment Program website to try to help us through the maze. At least two of the new resources – MIPS Measures for Cardiologists and Advancing Care Information Measure Specifications/Transition Measure Specifications – are updated versions of previous documentation. This highlights the difficulty in staying up on everything, and the fact that even when you think you have the game figured out and have put processes in place, the game can change. Other resources include vendor lists for Qualified Clinical Data Registries (QCDRs) and Consumer Assessment of Healthcare Providers & Systems (CAHPS) for MIPS. This highlights the complexity of the program, where many participants need to work with multiple vendors to even have a chance of doing it right. The list of new documents is rounded out with an Introduction to Group Participation in 2017 MIPS and a MIPS Measures Guide for Primary Care Clinicians.

I was a little disappointed in the primary care document, which seemed to be overly general and was described as a “non-exhaustive sample of measures that may apply to primary care.” It seemed to be more of a filler to point physicians to the main QPP.CMS.GOV site for more information. Even for those of us who have been steeped in the content, requirements are pretty complex and implementing them is daunting if you haven’t done the pre-work to get all your clinicians on the same page and operating as a cohesive organization. The majority of the consulting work I’m doing these days seems to be in the change management / change leadership space, where I spend a fair amount of time trying to convince reluctant providers that having standardized care plans and office processes really is a good idea and not an infringement on their individuality.

Regardless of our feelings about it, MIPS, the QPP, and Meaningful Use (Medicaid-style, at least) are not going away. It will be interesting to see how physicians feel about their level of understanding a year or two from now.

Are you ready for MIPS? If not, why? Email me.

Email Dr. Jayne.

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Currently there are "2 comments" on this Article:

  1. The current mechanism to measure healthcare quality is flawed. The emperor has no clothes. Sooner or later everyone will realize it and surely a more accountable system will be designed to accurately arrive at grading “value” provided by physicians during care delivery.
    Shutting down PQRS showed how little value that system offered. The learning from PQRS can help to design a more reliable quality measurement system whose limitation can be transparently documented to pave way for continuous improvement. PQRS experience report does not have data on how PQRS helped bring down cost or provide more value to patients, it just has graphs on provider participation stats. Even the QRUR reports are tons of data with no actionable insights for provider improvement.

  2. I work for an EHR vendor who has lots of MACRA/MIPS documentation in the pipeline. Unfortunately, all education and documentation takes time, and that’s rarely the priority at any organization. For us, this means that a lot of our documentation will launch shortly before the requirements go into effect, which I’m afraid will frustrate our customers, and allow more time for our competitor’s marketing departments to try and lure customers away with their pitches. (But as Dr. Jayne points out, buyers should beware of the rosy picture painted by marketing teams, and take a hard look at the costs of switching EHRs before making a jump). Rest assured, we’ll all get there in the end. Just give it more time.







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