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CMS Reveals MACRA Rules

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A CMS … Proposal

[By Andy Salmen]

The Centers for Medicaid and Medicare Services (CMS) have finally released the much anticipated unveiling of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) rule proposal.

The goal of this rule is to establish key parameters for the new Quality Payment Program, a framework that includes the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). These two paths for compliance allow doctors more flexibility in achieving compliance.

MIPS

MIPS scores clinicians based measures and activities chosen by physicians and is based on their specialty. MIPS would basically streamline and combine three of the different programs that currently exist under Medicare. These programs are Physician Quality Reporting System, the Value-Based Modifier Program, and the ‘Meaningful Use’ of electronic health records.

There will be four performance categories for clinicians (clinicians include physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists, etc.) to be scored on. These performance categories are:

  • Quality
  • Advanced Care Information
  • Clinical Practice Improvement Activities
  • Cost

APMs

CMS proposed implementing an Advanced Payment Models (APM) pathway, allowing eligible clinicians to become “qualified participants”. This means that eligible clinicians will be able to earn statutorily specified incentives for participation.

CMS predicts most providers to initially opt for MIPS. It is expected that participation in APMs, both number of physicians and number of payment models, will grow over time, as this program will qualify clinicians for financial bonuses in exchange for taking the risks associated with providing “coordinated, high-quality care”, according to CMS. 

***

3726de1f-2375-4301-84e0-78447fb496f3-original

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EHR Meaningful Use Rules Finalized

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The CMS Modifications

[By staff reporters]

Source: Joseph Goedert, Health Data Management [10/7/15]
***
Centers for Medicare and Medicaid Services
***
The Centers for Medicare and Medicaid Services has issued a 752-page final rule covering three components of the electronic health records meaningful use program. The rule finalizes modifications to Stages 1 and 2; the 2015 edition of electronic health records certification criteria; and Stage 3 of meaningful use.
Modifications
Under the modifications to Stages 1 and 2, eligible professionals have 10 meaningful use objectives, down from 18 previously. In Stage 3, there are 8 objectives for eligible professionals and hospitals, and more than 60 percent of measures require interoperability.
Assessment
The entire rule is available here.
***
MD with eHR
***
Conclusion
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Understanding “Meaningful Use” Attestation Numbers for 2014

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Providers versus Hospitals

By CMS

ME121014_PAGE_16

Assessment

So, what do the hospitals know –  that the doctors do not?

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Are Dentists Satisfied with their EDRs?

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Major Discontent With EHR Adoption

[By D. Kellus Pruitt DDS]

1-darrellpruittUnlike physicians, dentists never complain. That means they are probably 100% satisfied with their electronic dental records.

What do you think, Doc?

MarketWatch 

Recently, the Wall Street Journal’s MarketWatch posted a press release titled, “Physicians Cite Major Discontent With Adoption And Use of Electronic Health Record Systems, Despite Government’s $27 Billion Incentive Program”

http://www.marketwatch.com/story/physicians-cite-major-discontent-with-adoption-and-use-of-electronic-health-record-systems-despite-governments-27-billion-incentive-program-2014-02-07

“CLEVELAND, Feb. 7, 2014 /PRNewswire/ — The $27 billion government experiment to incentivize physicians to convert to electronic health records (EHRs) has not been worth it, according to nearly 70% of physicians surveyed.

Medical Economics 

***

In fact, a national [Medical Economics] survey of nearly 1,000 physicians, set for release on February 10, 2014, shows widespread dissatisfaction related to the functionality and cost of these patient record systems. About 45% of physicians believe patient care is actually worse as a result of adopting EHR technology, two-thirds would not purchase their current EHR system again, and 43% of physicians say these systems have resulted in significant financial losses.

In addition, the current state of technology has not improved the coordination of care with hospitals, physicians say.”

***

It is probably better for HHS that very few dentists were able to participate in the ARRA stimulus giveaway. Otherwise, tax-paying citizens might have learned about the wastefulness of Meaningful Use requirements for dentists – which nobody has the guts to reveal. That pretty much rules out brilliant Meaningful Use ideas.

Those who might patriotically defend the benefits of the tasks would do so, if they were idiots.

So how do dentists feel about their electronic dental records? It’s hard to tell. Over 96% of them are HIPAA-covered entities, making them vulnerable to audits, which can be “random” now. As one can imagine, very few dentists openly discuss EDRs. Do you think the silence is more likely to improve or harm patient care?

doc

Even though thousands of physicians have participated in dozens of national surveys like Medical Economics’ over the last few years, as far as I know, not one survey of dentists’ opinions has ever been published. Perhaps someone can prove me wrong. I doubt it.

The Survey

The results from the Medical Economics survey include:

  • 67% say that system functionality influences their decisions to purchase or switch systems.
  • 48% say that cost is influencing their decisions to purchase or switch systems.
  • Nearly half of physicians say that implementation of EHR systems has made the quality of patient care worse.
  • 69% of respondents say that coordination of care with hospitals has not improved.
  • 45% say they have spent more than $100,000 on an EHR
  • 77% of the largest practices (more than 10 physicians) spent more than $200,000 on an EHR.
  • 38% doubt their systems will still be viable in 5 years.

Assessment

Not long ago, Wisconsin became the first state to outlaw paper dental records, which are both cheaper and safer than digital.

So, is it still too soon for dentists and patients demand more transparency in dentistry? When costs and danger are hidden in dental care, it is always the last in line who suffer the most – clueless, trusting dental patients.

Am I right, Doc?

More:

  1. Sales of Dental Equipment and eDRs Down
  2. Military Electronic Dental Records [eDRs]
  3. Dr. Pruitt Invites Dr. Cohen to Discuss eDRs
  4. Cyber Insurance for Dentists

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More on “Meaningful Use” Requirements

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And  …  Its’ Impact on eHRs

Carol Miller RN MBA millerconsultgroup@gmail.com

The American Recovery and Reinvestment Act of 2009introduced the “Meaningful Use” requirement for EHR systems with three main components:

The Components

1) The use of a certified EHR in a meaningful manner, such as e-prescribing, 2) The use of a certified EHR technology for electronic exchange of health information to improve quality of health care, and 3) The use of a certified EHR technology to submit clinical quality and other measures.

Meaningful Use refers to a set of 15 criteria that medical providers must meet in order to prove that they are using their EHRs as an effective tool in their practice.  There are also 10 additional criteria that are considered a la carte from which only 5 need to be demonstrated by the medical provider.

In total, 20 Meaningful Use criteria must be used within the EHR to qualify for stimulus payments during Stage One of the EHR incentive program.   Each of the criteria were developed and further reviewed by the Office of the National Coordinator [ONC] with public input.

A Five Year TimeLine

Meaningful use will be measured in stages over five years.  Each stage represents a level of adoption.  Many certified EHRS will allow providers to complete all Meaningful Use criteria, whereas others will only certify what is required in the early stages and modify at a later date with any new criteria.

The three stages are:

Stage One:  Essentially, Stage One is using the major functionality of a certified EHR.  This includes documenting set percentages of your visits, diagnoses, prescriptions, immunizations and other relevant health information electronically; using the clinical support tools (warnings and reminders that will be included in a certified EHR); and sharing patient information.  Providers and hospitals must report quality measures and public health information. For providers they must report on 6 clinical quality measures – 3 required core measures and 3 additional measures selected from a set of 38 clinical quality measures.  Eligible hospitals and Critical Care Hospitals (CAHs) must report on all 15 of the clinical quality measures.  Stage One is required in years 2011 and 2012.

Stage Two:  In addition to continuing to use all functionality from Stage One, physicians will be required to use EHRs to send and receive information such as lab orders and results.   Other criteria may be added.  Stage Two is expected to be implemented in 2013.

Stage Three:  This stage will continue fulfilling the criteria from Stages One and Two and will include clinical decisions support for national high priority conditions; emailing patients in a Personal Health Record (PHR); accessing comprehensive patient data; and improving population health.  Stage Three criteria have not been developed to date and the implementation is not expected until 2015.

Assessment

CMS payment penalties for non-compliance to the meaningful use regulations will begin in 2016 with an initial 1% penalty which could escalate to 5% five years later.  Therefore, with these criteria in place, we are likely to see virtually all hospitals attempt to meet the meaningful use criteria to avoid penalty cost.

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Implementing “Meaningful Use” [A True Tale from the eHR Field]

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Maintaining Criteria for CMS Incentives

Anonymous Doctor

[By Anonymous Doctor]

If you qualified for year one … you qualified for year one. Deposit the check and pat yourself on the back. I too worked myself ragged, added a couple of hours to my charting each day … and collected $18,000 for 90 days (actually 6 months) of added stress.

But, I have opted NOT TO continue into year 2 … as $1,000 per month for 365 straight days of compliance is too much to bear. There is no mandatory need to comply until 2015.

I plan to use my software, comply as much as possible, not pull my hair out until 2015 when we have to be 100% compliant, 100% of the time. I know there are those with big staffs, and big overhead who will disagree, and have their assistants do all the charting.

For those of us in solo practice struggling to make ends meet, this burden is NOT WORTH carrying into year #2.

Source: Ann Miller RN MHA

via Name Withheld (FL)

PM Mews #4,382

Assessment

This story was originally a “comment”, but it has been re-published as a “post”, to illustrate the dichotomy between medical practitioners using eHRs and salesfolks recommending and selling them based on the government rebate feature rather than true market competition, efficiency and innovation.

MORE: MU GE Healthcare

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The Federal Strategic Plan to Reduce Health IT Disparities

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[By Staff Reporters]

Working to ensure all Americans benefit from health IT is one of the principles guiding the development and execution of the federal health IT strategy. The Federal Health IT Strategic Plan that was released for public comment on March 25, 2011, states that we will strive to: Support health information technology (heath IT) benefits for all.

All Americans should have equal access to quality health care. This includes the benefits conferred by health IT.: The government will endeavor to assure that underserved and at-risk individuals enjoy these benefits to the same extent as all other citizens.

Health IT Disparities Workgroup

For the past few months, the Health IT Disparities Workgroup — comprised of staff from agencies of the U.S. Department of Health and Human Services (HHS): with strategic and operational programs in health IT and co-chaired by the Office of the National Coordinator for Health Information Technology (ONC) and the Office of Minority Health (OMH) — has led a focused effort to further define the federal government’s strategies and tactics to reduce health IT disparities within underserved communities. The result of this process will reflect our commitment to do more to reduce health IT disparities.

The Health IT Disparities Workgroup is developing a federal plan to reduce health IT disparities.: A draft set of strategies/tactics — aligned with the five goals of the Federal Health IT Strategic Plan — is included below: We hope you will assist us by providing comments on the following questions:

  • What do you think of the draft strategies / tactics listed below?
  • What specific activities would you like to see the federal government take on to reduce health IT disparities?

HIT

Health information technologies — such as electronic health records (EHRs), telemedicine, mobile health, and electronic disease registries — have been identified as effective means of helping to deliver safe, effective, affordable health care services; coordinate care across providers and clinical settings; and provide critical population data that may catalyze further policy and delivery system innovations.

Meaningful Use

The growing adoption and meaningful use of health IT is even more critical within the context of underserved communities. Within both rural and urban underserved communities, access to primary and specialty health care resources can be limited. This scarcity in many instances contributes to reduced quality of health care and of health outcomes for people residing in these communities. Within underserved communities, the use of health IT has demonstrated it can improve health outcomes, both from an individual and community-/system-wide perspective.

Federal Planning

Federal planning efforts focused at reducing health disparities, including The National Stakeholder’s Strategy and the HHS Action Plan to Reduce Racial and Ethnic Health Disparities, highlight the proliferation of meaningful use of health IT within underserved communities as a critical objective. This draft set of strategies/tactics (see below) for the federal plan to reduce health IT disparities aims to ensure that underserved communities realize the full benefits of health IT.

Assessment

Read more: http://www.healthit.gov/buzz-blog/from-the-onc-desk/federal-strategic-plan-disparities/#ixzz1X7U1WnCQ

Conclusion

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