EPtalk by Dr. Jayne 10/20/16

It’s been a busy week as people begin to digest the contents of the MACRA Final Rule. Most of the physicians I’ve spoken with are worried specifically about what they need to do in order to meet requirements for 2017. It would be a mistake, however, to not spend some time planning for 2018 and beyond. CMS will increase the number of outcome metrics as time passes, while also increasing the weighting applied cost measures. CMS is also making changes in the Medicare Shared Savings Program. Although 2017 may seem to be a low-risk year where providers can take it easy, in reality 2017 should be a year where providers work to maximize their performance in preparation for future years.

Providers are going to be increasingly graded on performance and if they’re not honing their skills they’re going to be behind. Our favorite Geek Doctor, John Halamka, weighed in on the Final Rule as well:

Think of MIPS not as four separate categories (quality measurement, cost control, practice improvement, and wise use of IT) but as a single program focused on rewarding clinicians for improving quality and penalizing clinicians for non-participation. There are only a few ways to change clinician behavior – pay them more, improve their satisfaction and help them avoid public humiliation (like poor quality scores posted on a public website). MIPS pays them more, consolidates multiple other government programs, and provides flexibility to give clinicians every opportunity to make their quality scores look good.

As much as everyone has been waiting for the Final Rule, it’s not entirely final. It was released as a final rule with comment, which means that we have 60 days to continue to weigh in. There’s still the opportunity for our feedback to be heard by those who will make subsequent rules and those who will tweak this Rule as it is applied. We’ve seen from previous iterations with Meaningful Use and other federal programs that the only constant is change.

I had the privilege this week of lunching with some former co-workers. We all worked together on a large health system’s EHR implementation project starting more than a decade ago. Although we try to get together quarterly, it gets more and more difficult unless we plan it months in advance. We’re all still in healthcare, although we’ve branched out into consulting, quality improvement, program management, and interoperability roles. Two of the group have come full circle and are again helping the large health system with an EHR implementation as they perform a massive rip-and-replace of all clinical and financial systems.

It was gratifying to learn that although much time has passed and it’s a different system, many of the processes we created are being dusted off and used to help the practices navigate the transition. Regardless of the type and scope of the project, the change leadership and governance pieces are essential and fairly timeless. It sounds like it’s been a bit frustrating for my colleagues who are on the ground, as the organization has lost some of its institutional memory. The current project is being handled as an IT project that has a couple of clinical advisors, rather than as a clinical / operational project with IT support as we had done in the past. They’ve already experienced massive scope creep, delays, and cost overruns.

There are also issues with IT leadership not understanding the needs of a large provider organization. They actually tried to tell the provider group that they “won’t be allowed to onboard any new physicians or practices during the transition period,” which is over 18 months long. That statement alone shows a fundamental lack of understanding of what is going on in healthcare today, as providers are being consolidated into larger organizations either willingly or in response to fear. I can’t imagine telling a CEO he can’t onboard new physicians, but apparently it happened. I’m betting the follow up phone call to the CIO was interesting, to say the least. When you’re spending upwards of a third of a billion dollars on a project, impeding strategic growth probably isn’t the best idea.

Back when we were doing our original implementation, we needed a full-time person to go around and do some periodic retraining for providers. We had the opportunity to hire a retired IT staffer who had been a physician liaison and was dearly loved. The powers that be told us we couldn’t justify a full-time position, so we brought her on as a contractor. I laughed out loud when I heard today that she is still there, eight years later. Maybe that position would have been justified after all.

The health system is wrangling with the same issues that we fought with the original EHR, including how to handle private/community physicians that want to be on the platform but don’t want to pay for it, as well as how to support the infrastructure. Where we were worried about making sure everyone had adequate bandwidth via DSL or T1, now they’re working to upgrade everyone to fiber. They’re still dealing with patient consent around interoperability as well as difficulties with patient matching and provider attribution. Although they’ve made some headway on those issues, the core problems still remain tricky.

Another theme with the group was trying to maintain some kind of work-life balance given the continuing chaos that healthcare reform and ensuing technology requirements has created regardless of role. I remember when we started, the understanding was that we’d do this rollout for 18 months and then go back to our original jobs. The organization quickly realized that it was unlikely for that scenario to play out. A decade later we’re not only still at it, but most of us are leading teams of people dedicated to the ongoing support of healthcare IT and clinical transformation. Some of us are still burning the candle at both ends, which although sustainable for a few years, starts to wear on you when you’ve been doing it nonstop.

By the time we get together again, it will be 2017 with all the MIPS and APM-related excitement that brings. It will be a new year for penalties and incentives, with new clinical quality measures, new carrots, and new sticks. It’s been great to have a core group of friends who can support each other as we go through this, venting about our respective situations and the challenges we face. Looking at what’s coming down the road, we’re going to need each other to stay sane.

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