I’ve been trying to digest the recently-released CMS final rules. Overall, much of the flexibility we expected for the Quality Payment Program is now final, including the ability for providers to use 2014 Edition or 2015 Edition Certified Electronic Health Record Technology (CEHRT) for the Advancing Care Information category. Although many organizations are breathing a sigh of relief over this, there is a bonus for using only 2015 CEHRT and those organizations that kept the pedal to the floor may get at least a little reward for their efforts.
Additional items in the Final Rule include relief for providers impacted by Hurricanes Harvey, Irma, and Maria by automatically weighting the Quality, Advancing Care Information, and Improvement Activities performance categories at 0 percent of the MIPS final score. Small practices can get five bonus points to the MIPS final score, as can those practices that treat complex patients.
Although CMS continues to crow about their success related to the “goals of regulatory relief, program simplification, and state and local flexibility in the creation of innovative approaches to healthcare delivery” I know there are a lot of us that think any rule that requires 1,600+ pages to explain cannot possibly be simple. I’d personally like to see the “QPP for Dummies” edition to make sure I fully understand everything that’s in there. Even the Executive Summary is 21 pages long.
Last Monday CMS administrator Seema Verma also announced the “Meaningful Measures” initiative which CMS claims will help streamline quality measures that providers are trying to meet. Although this sounds like a welcome change, this isn’t the first time we’re heard about proposed program simplification. Although some payers follow the lead of CMS on quality measures, others put their own little twists on the measures clinicians need to report, requiring them to create custom reporting that mimics CMS requirements in a “missed it by that much” manner. If payers can’t agree on the most meaningful measures for patient outcomes, that doesn’t give those of us in the trenches confidence.
For many of us, the constant changing of measures and requirements just seems to highlight the idea that we’re all part of some uncontrolled experiment with no defined endpoint. The sheer number of hours spent by organizations on regulatory compliance is staggering. At least a couple of times a year, I have conversations with medical students who are questioning their career choices and who are trying to figure out if they want to go to business school, law school, or residency. I know it’s anecdotal, but I feel like we’re having a lot more of these conversations than we did in the era before Meaningful Use.
I haven’t had admitting privileges at my hospital for a long time, but I’ve been able to keep an adjunct status that lets me participate in continuing education sessions, attend Grand Rounds, and hang out in the physician lounge, which gives me a place to meet with students and residents to talk about career planning or mentoring. It’s been worth the small fee I pay every year to have a central place to have those conversations, since my “office” is in my house and sometimes meeting at a restaurant or coffee shop can be noisy.
We have a new hospital administrator who spoke at a recent medical staff gathering. I was struck by a several things. First by his youthful exuberance but relative lack of experience and second by his amazingly full command of what I can only describe as an executive word salad. Seriously, if he told me how much we were going to synergize around results-oriented outcomes one more time, I was going to burst out laughing. I am going to have to break out the Buzzword Bingo cards if I ever go to an event where he will be speaking again. I miss the camaraderie of the hospital, and the hilarity of the whole thing made me glad I took the time to attend.
While I was chatting with some of my colleagues, I heard some complaining about changes to how the AMA is calculating the need for licensing for CPT codes. Rather than counting actual end users, AMA is moving to a “User Proxy Method” that approximates the number of CPT code users in an ambulatory billing or clinical system based on the number of full-time equivalent providers in the practice. These counts are multiplied by industry data. In the case of an ambulatory clinical system with or without a billing system, the multiplier is four. The discussion at the hospital included overall unhappiness with AMA’s monopoly on coding, with one provider questioning whether the RICO act should be used to counter its grip on providers. In researching the issue, I noticed AMA still uses the “EMR” verbiage, which highlights how behind the times they are.
When I returned home from the hospital, I was glad to find an email from the last of my friends in Puerto Rico that I have been waiting to hear from. He and his family are safe, but were without power for more than a month and are still having difficulty obtaining supplies. Although stores are restocking, his community has returned to a cash economy. It sounds like there continue to be many health system challenges that won’t be resolved anytime soon.
AMIA2017 has been in full swing this week, with National Library of Medicine Director Patti Brennan presenting at Monday’s Sunrise Session and National Coordinator Don Rucker presenting on Tuesday. I didn’t make it this year because of a conflict, but hopefully next year’s calendar will be more forgiving. Looking at a schedule of available conferences for the next year, I’m going to have to choose carefully, especially since I need to fit in a board review course to prepare for recertification. Since I haven’t practiced traditional primary care in a number of years, I’m dreading the exam but given our need to comply with Board Certification in order to be credentialed by payers, I don’t have much of a choice. Not to mention, we have to maintain a primary board certification to keep our clinical informatics certifications, so letting mine lapse would be a double-whammy.
Have any good board exam prep tips? Email me.
Email Dr. Jayne.