The More Things Change, The More They Stay The Same

Lester Parada

Lester Parada

Vice President of Operations at SRS Health
As the Vice President of Operations, Lester brings over 10 years of increased management experience in operations and product management to the team having held roles in Product Management, Business Development, and Project Management. Lester often visits clients to ensure their SRS Health experience is positive and that they are optimizing their solutions to meet the needs of their practice. Lester frequently attends conferences and tradeshows where he shares his vast product and industry knowledge to educate, while learning from clients and attendees as well.

Lester earned a BS Finance and Management from Montclair State University and an MBA in Marketing Management from Rutgers. In addition, he is a certified PMP (Project Management Professional), CSM (Certified Scrum Master) and CSPO (Certified Scrum Product Owner).
Lester Parada

Latest posts by Lester Parada (see all)

Earlier this month, SRS Health attended the 2018 American Academy of Orthopaedic Surgeons (AAOS) Meeting. For us, it is an opportunity to spend time with our clients, make new connections and most importantly keep our finger on the pulse of the industry. Each year, we come back home with a list of hot topics or trends and ensure that we are addressing them. This year however, I felt a sense of déjà vu. So, I went back to the 2017 post-AAOS blog and found that the high level topics were almost identical to what I would have written myself.

  • prescription safety
  • data mining/outcomes;
  • cost reduction/operational efficiencies; and
  • MACRA/ MIPS readiness.

Does this mean there has been no progress in the 12 months since the last conference? Not at all.

Prescription Safety – in 2017 really translated to Electronic Prescription of Controlled Substances (EPCS). In 2018, we find that although 91.9% of pharmacies now support this technology nationwide, only 22.9% of providers are EPCS-enabled. More importantly, in 2018, new complexities have been added as many states now also do or will require checking Prescription Drug Monitoring Programs (PDMPs) before prescribing certain medications.

Outcomes in 2017, outside of hospital and research settings, was limited to the basic assessment for the purposes of meeting some requirement like a quality measure, CJR or BPCI. In 2018, adoption by larger groups is starting to gain momentum. Rather than just focusing on the minimum government requirements, practices are beginning to see the value in being able to improve the quality and efficacy of care through evidence and solid data.

Cost Reduction/Operational Efficiencies in 2017 meant actual hard cost-cutting or expanding business lines to bring more of the continuum of care under the practice’s control. In 2018, not only do we see a continuation of those two strategies but more and more practices are looking to justify spending. They are looking at the value of each technology, each partner, and deciding what they can change, combine or cancel.

MACRA/MIPS in 2017 was a transition year and HCIT vendors warned providers not to be complacent. We warned that you should be ready to jump into the program in 2018 and beyond. Well, in 2018 Congress enacted the Bipartisan Budget Act of 2018. This act pushes out the full implementation, effectively making 2019, 2020, and 2021 three more transition years.

Although change management, especially in healthcare, is often slow, having the right technology to address the challenges and opportunities we face—at the right time—is key to optimizing patient care, practice performance, and population health.

At SRS Health, we’ve developed and delivered a specialized end-to-end solution that addresses the topics above, so that we are ready when you are!

Providers Heard Promises and Warnings at HIMSS

Lynn Scheps

Lynn Scheps

VP, Government Affairs & Consulting Services at SRS Health
Lynn Scheps is a leading resource on MACRA, MIPS, and Meaningful Use. She is the SRS liaison with government policy makers. Representing the voice of specialists and other high-performance physicians, she develops strategies to respond effectively to government initiatives.
Lynn Scheps

I just spent three days in Las Vegas at the annual HIMSS conference, with 43,000 of my closest friends. As the Vice President for Government Affairs at SRS Health, my goal in attending this conference each year is to get a heads-up directly from the leaders of CMS and ONC regarding what the government has in store for physicians. While no secrets are leaked in the sessions or meetings at HIMSS, several government program–related themes clearly emerged this year—topping the list was interoperability and burden reduction.

  • Seema Verma, Administrator of CMS, promised a “complete overhaul” of Meaningful Use, and (I assume) by extension, the ACI portion of MACRA. She was purposely short on details, so we don’t know exactly what that means, but subsequent conversations with her team confirmed what it does not mean: MACRA is not going away; MU3 is not disappearing; and the use of 2015 CEHRT is not off the table. I don’t expect that we will see major changes, but we will have to wait for the details to be revealed in the rulemaking that comes later this year.
  • Interoperability will be the focus going forward, and providers were warned that measures are being developed to identify and prevent information blocking, as required by the 21st Century Cures Act, going so far as to impose fines for willful actions in this regard. Patient data must be shared freely between providers; and it must be made easily—and electronically—available to, and controllable by, the owners of that data, i.e., the patients themselves, through programs like the newly announced MyHealthEData initiative.
  • Promises of regulatory relief and clinical burden reduction were abundant, and were offered within various contexts, including the overhaul of MACRA to reduce the time providers devote to compliance, streamlining documentation for the E&M coding/billing process, and the introduction of the Meaningful Measures initiative to increase the validity and efficiency of quality measurement and reporting. ONC and CMS led several ”listening sessions” in which they sought feedback on burden reduction—I sensed hopeful optimism tempered by healthy skepticism on the part of attendees.
  • The opioid crisis is on everyone’s mind. As one Congressional staffer put it, this is the “issue du jour.” It is being addressed at the national level as well as by the states, the majority of which are already mandating PDMP checking before a physician can write a prescription for a controlled substance. One challenge here will be for HIT and EHR vendors to automate this process so that the problem can be tackled without creating a new task that providers will perceive as yet another burden. 

It will be interesting to see what progress is made in all of the above areas when HIMSS reconvenes in 2019.

Congress Authorizes Changes to MIPS

Lynn Scheps

Lynn Scheps

VP, Government Affairs & Consulting Services at SRS Health
Lynn Scheps is a leading resource on MACRA, MIPS, and Meaningful Use. She is the SRS liaison with government policy makers. Representing the voice of specialists and other high-performance physicians, she develops strategies to respond effectively to government initiatives.
Lynn Scheps

mips-blogHow many times have you heard the expression, “It would take an act of Congress.”? Well, Congress has acted! Had this blog been posted just 2 weeks ago, the message would have been slightly different and a little more ominous in tone. I would have said—and you may have read articles elsewhere where I did—that the MIPS transition period is coming to an end, and providers should begin to prepare in earnest for 2019, when by law, the MIPS threshold would be much higher and the cost category would account for 30% of the MIPS score. These provisions in MACRA were not subject to CMS’ discretion; but apparently, Congress has been persuaded to extend CMS increased flexibility. As part of the Bipartisan Budget Act of 2018, Congress has pushed out the full implementation of MIPS from 2019 to 2022, effectively making 2019, 2020, and 2021 three additional transition years.

This means that:

  • There will still be winners and losers since budget neutrality remains a requirement; however, CMS is now not obligated to set the MIPS threshold at the mean (or median) of prior performance until 2022. Instead, the threshold will be gradually increased to that level over the intervening years, the good news being that it will not be as challenging to avoid a downward adjustment for a few more years. The consequence of this, however, is that the amount of money available to winners will continue to be less than the maximum provided for in the law, (i.e., 5% related to the 2018 performance year, 7% for 2019, and 9% from then on.)
  • The Cost category does not jump to 30% of the MIPS score in 2019. CMS can hold off on the increase until as late as 2022, with the flexibility to set the rate at between 10% and 30% each year until then and to make it 30% only when the Secretary is confident that the resource use, (i.e., cost), measures are ready for adoption. In addition, the bonus points for year-over-year improvement in this category have been eliminated.

Through these changes, Congress has relieved some of the immediate pressure for providers. However, this does not change the fact that it will become progressively harder to score well as providers gain experience, making MIPS increasingly competitive in the coming years:

  • The Quality and Cost categories will remain distinguishing factors among providers.
    • It will become progressively harder to score well in the Quality category. Benchmarks will be more aggressive as providers build experience. The 2018 benchmarks have been posted on the QPP website, and you can already see differences from the 2017 deciles for some measures.
    • Improving your comparative Cost position is not something you can do overnight; it takes time. So, it’s not too early to address this area more vigorously.
  • MIPS performance has implications beyond Medicare payment adjustments. Your reputation could be impacted as CMS makes more and more performance data publicly available on its Physician Compare website. Consider what you want patients, referring physicians, and payers to see about you when they are researching your practice.

So, don’t let down your guard. Take advantage of the additional transition years to secure your future success.

MIPS 2018 New Year Resolutions

Christine Schiff

Christine Schiff

Government Affairs Specialist at SRS Health
Christine has been with SRS for over 5 years, working in Government Affairs and serving as the HIPAA Privacy Officer. She is devoted to providing excellent customer service, and she translates this passion into the work she does to support government program compliance. She has an expert understanding of MU and PQRS and serves as a valuable client resource.

Prior to joining SRS, Christine worked at NYU for 11 years where she also obtained her Bachelor of Science in Healthcare Management.
Christine Schiff

Check out these top 5 tips for starting your 2018 MIPS reporting on the right foot!

  1. Focus on Quality! – 2018 new-years-resolution-mipsrequires full-year reporting. With quality being the highest valued category (50% of your MIPS score), now is the time to review your quality-reporting plan and make sure you are capturing all the necessary data to report successfully. Furthermore, this is the category where providers can really distinguish themselves. It is anticipated that ACI scores will generally be high due to MU experience, and that most providers will earn the full score in the Improvement Activities category.
  1. Understand Your Cost Position – In a change from the original proposal, the cost category will contribute up to 10% of your overall MIPS score. Look for CMS reports later in 2018 to help you understand how cost is assessed and consider ways to reduce the cost of care you provide.
  1. Plan your ACI Reporting Strategy – CMS is allowing the use of 2014-certified software in 2018. Here are your options:
    • Your EHR is 2014 Certified – report the 2017 Transitional Measure Set.
    • Your EHR is 2014 and 2015 Certified – report either 2017 Transitional Measure Set, the ACI Measure Set, or a combination of both.
    • Your EHR is 2015 Certified – report the ACI Measure Set.

Compare the two measure sets and evaluate which set will likely earn you higher performance scores.

  1. Pick Your Improvement Activities – CMS has included some additional Improvement Activities for 2018. Review the list and make sure you will be able to attest to completing them for at least 90 days in 2018.
  1. Strive for Better Performance – Improvement in the Quality (and Cost) category for 2018 over last year will earn you bonus points this year. Review your CQMs and readjust workflows as necessary to support higher performance.

 

 

Achieving Value-Based Care – Making the Right Partnership for Success

Christine Schiff

Christine Schiff

Government Affairs Specialist at SRS Health
Christine has been with SRS for over 5 years, working in Government Affairs and serving as the HIPAA Privacy Officer. She is devoted to providing excellent customer service, and she translates this passion into the work she does to support government program compliance. She has an expert understanding of MU and PQRS and serves as a valuable client resource.

Prior to joining SRS, Christine worked at NYU for 11 years where she also obtained her Bachelor of Science in Healthcare Management.
Christine Schiff

There are many factors that contribute to achieving “value-based care,” some of which your practice may already be targeting—patient engagement, interoperability, outcomes, and efficiency, just to name a few! The reality is that the shift to value-based care has been underway for some time, but the change-over is accelerating with the implementation of MACRA. Whether through Alternative Payment Models or the Merit-Based Incentive Payment System (MIPS), the emphasis is now on improving quality and reducing cost.

For most doctors, of course, delivering quality care has always been a priority, so the question really is how to document that while maintaining practice efficiency, containing costs, and continuing to provide excellent patient care. Let’s look at some of the components of Value-Based Care:value-based-care-infographic

 

Whether you focus on all or some of these components, there will likely be a shift in how you use your EHR. To be effective in your pursuit of value-based care, you need your HIT vendor to be a true partner. Here are some questions to consider as you determine your goals and your technology needs:

  • What am I doing to drive value-based care, and how are my partners supporting me?
  • Where do I need more assistance?

And more specifically:

  • Do I have the capability to effectively engage and maintain communication with my patients—both pre- and post-visit—to better manage their care?
  • Can I track outcomes and set standards of care/protocols?
  • Can my current technology improve my practice efficiency?

Don’t settle for only what is imposed by regulatory requirements—decide what is truly valuable for the care of your patients and then implement it. The right technology partners will help you to develop a strategy for achieving your patient-care goals. Remember: How to efficiently deliver the highest quality patient care is an ongoing conversation—make sure your technology partners are holding up their end of it.

Let’s continue the conversation – tell us what you are doing to drive value-based care.

Patient-Reported Data Collection and Return on Investment

ROI-300x300-screenDetermining ROI Metrics

The determination of when an investment recoups its costs is in many instances a fairly straightforward matter. In other instances however, it isn’t quite that simple. As the transition to value-based healthcare advances, providers are keenly looking for ways to assess the impact of patient-reported outcomes data on their bottom line.

The identification of a specific ROI metric to the cost of deploying a patient-reported outcomes data platform deployment is dependent on a number of factors that are not always easily quantifiable. Much depends upon what kind of data is being collected, the purposes for which it is being collected and both the qualitative and quantitative nature of the data.

To ensure a credible and reliable calculation of the ROI of patient-reported outcomes data collection, providers should rely upon a rigorous systematic approach for evaluation. One such methodology can be found in the work of the ROI Institute, through their “evaluation framework,”1 which categorizes results in a prescribed, logical order. This recommended sequence represents a chain of impact that can attribute and account for benefits realized. This framework consists of 5 levels of information to consider:

  1. Reaction to the program, particularly the perceived value of the program.
  2. The extent of learning such as skills, competencies, knowledge, and insights in the program.
  3. The extent of application and use of knowledge, skill, and insights acquired during the process.
  4. The program’s effect on the data such as, sales, productivity, quality, time, and costs.
  5. The ROI, the net monetary benefits compared to the cost of the program.

Patient-reported outcomes data collection offers its users a myriad of ways to generate value. For researchers, the data analysis tools provide powerful opportunities to analyze deep data sets. Practice managers are enabled to follow physician members to uncover best practices. And of course physicians can optimize their CMS reimbursement adjustment amounts by monitoring their performance scores throughout a performance year. The point is each user has a unique basis from which to evaluate and determine the overall benefit Patient-reported outcomes data collection contributes to a provider’s practice. Any valid assessment of an ROI must be tailored to the specifics of each user. Any generalized metric is clumsy at best and more than likely misleading.

Value Return to Physicians

The value of any patient-reported data collection platform to a physician must be measured by an array of considerations requiring objective and deliberate analysis. Each aspect of a physician’s practice that is impacted, whether directly or indirectly, necessarily needs to be factored into the equation. Failure to pursue such diligence in the assessment process will more than likely produce an incomplete and misleading result.

Application of the ROI Institute’s evolution framework offers a substantive foundation on which to assemble a meaningful appraisal. The framework is flexible enough to enable application to each unique practice configuration, yet establishes cumulative benchmarks that result in a succinct and useful metric. The sequential nature of the framework reinforces an approach that captures seemingly disparate variables and leverages them collectively to reveal a deeper and more nuanced valuation of deploying a patient-reported outcomes measurement system.

Data mining technology, such as OBERD’s “Mountain,” can factor prominently in generating value out of the data being collected. With it, physicians have the power to slice and dice information in a myriad of ways for infinite uses. For example, providers may measure effectiveness of care, by specific procedure as well as in aggregate. These insights, which can be generated on-demand, can empower physicians with invaluable and actionable information. No longer is a physician constrained to wait for an annual, boilerplate report.

The capacity to robustly leverage data enables insightful benchmarking for both patient and practice analysis can fortify operational best practices. By incorporating efficiencies and successful procedures revealed through tools such as Mountain, new competitive and productive gains can be realized.

A byproduct of this ability to mine data is to provide physicians the opportunity to license newly uncovered knowledge to manufacturers for research and development by the medical and pharmaceutical industries.

Patient Engagement

Patient portals and other technologies that identify and fortify patient touch-points provide opportunities to encourage patient participation in their own care. Heightened patient engagement can lead to better healthcare outcomes at a lower cost by increasing the efficiency of the healthcare system/care offered. In addition, the deployment of patient defined outcomes instruments offers to maximize clinician-patient communication by facilitating an environment that involves patients in their care leading to a better understanding of their conditions and quality outcomes.

Tracking patient reported outcomes for research purposes provides an exceptional marketing tool to showcase your advancement in medical treatments/surgical practices. OBERD’s powerful analytic tool, Mountain, offers providers a platform to analyze and mine the data you collect, and to benchmark against other data sets, global or local.

MIPS Compliance

The determination of any unambiguous ROI regarding MIPS compliance relies upon several factors that presently are premature to firmly assess and are simply not available. No reliable computations can be made until CMS has aggregated Composite Performance Scores (CPS) of all physicians participating in MIPS performance year one, 2017. All scores achieved during this initial year will be used to determine a “CPS Threshold” against which providers will be compared in order to assign reimbursement adjustments that will affect payment year one amounts in 2019. Until that threshold is published, it is simply impossible to identify express ROI expectations.

That said, close monitoring of CMS communications are beginning to reveal benefits through the thoughtful and strategic usage of patient-reported data measurement for the collection, analysis and reporting of patient-reported outcomes data.

CMS has published guidelines to demonstrate how reimbursement will work through the Quality Payment Program (QPP) but has yet to provide specific monetary values. The program has allocated $833 million dollars yearly for the next 5 years that will be distributed based on eligible clinician merit with a focus on quality outcomes, which is reflected in one’s CPS.  The better one’s CPS, the higher the probability that positive reimbursement adjustment will follow. Beyond the funding set aside to incentivize performance merit, here is an additional $500 million dollars available annually for the next 5 years reserved for those with an overall composite score of 70 points or above.

OBERD continues to closely monitor CMS announcements and regulatory developments. As each iteration of QPP rules are revealed, OBERD will continue to refine its products to optimize results for its customers.

Reinforcing a Practice’s Marketing Message

The publication of CMS’s Physician Compare website, by publishing clinician measure scores, allows patient to embody the role of a consumer in shopping around for the best healthcare and for providers that demonstrate higher quality outcomes. CMS has further advanced the promotion of provider score transparency by empowering qualified clinical data registries (QCDR) to supplement Physician Compare website information with enriched content that will further empower patients to see additional information about providers and their practice. OBERD, as a CMS-approved QCDR, is developing multi-modality scorecards to showcase a provider’s best qualities, identify top performers, identify best practices and establish additional practice marketing opportunities.

Summary

As the transition from a fee-for-service to a value-based care system continues to evolve and accelerate, the ability to efficiently and economically collect, analyze and communicate patient-outcomes data will be foundational to a provider’s success. Evidence-based healthcare decisions will rely on leveraging a patient’s involvement in their own healthcare. By increasing the role of a patient to communicate on their own individual situation and progress, that patient is afforded a more active role, which promotes better patient experience and satisfaction. Better performance scores directly impact reimbursement computation.

Of the ROI Institute’s five point evaluation framework mentioned earlier, it needs to be underscored that the first three elements address subjects that do not lend themselves to quantifiable measurement. The perceived value derived from acquired knowledge, skills and insights precludes the value received in the application of those newly realized observations. Application of the new knowledge in turn can directly impact and drive a provider’s best practice.

The ROI evaluation framework begins to address quantifiable activities in step four only after the first three steps of the process are accomplished. These activities, such as sales, productivity and costs can only be accurately assessed in the context of framework steps 1-3. The ROI Institute’s framework requires that all four steps are necessary, a condition precedent, before any actual ROI, the net monetary benefit compared to cost, can be accurately assembled.

OBERD understands that providers desire to be free from the routine task of data collection. Providers can now harness exceptional new methods to gather information from their patients, learn from them and to apply those insights towards that patient’s care. A healthcare provider should be able to practice medicine, and not have to monitor every single regulatory change. OBERD is set up to do just that. Be assured that OBERD will continue to advance solutions that address the latest in compensation strategies that generate optimized benefit to its customers.

As seen in OBERD’s Insights Blog.

Learn how you can take your value-based care to new levels with our new outcomes solution in partnership with OBERD.

2018 MACRA (MIPS) Proposed Rule: The Abridged Version

Lynn Scheps

Lynn Scheps

VP, Government Affairs & Consulting Services at SRS Health
Lynn Scheps is a leading resource on MACRA, MIPS, and Meaningful Use. She is the SRS liaison with government policy makers. Representing the voice of specialists and other high-performance physicians, she develops strategies to respond effectively to government initiatives.
Lynn Scheps

lynns-notesThe proposed rule is here, and it’s another long one! So for those who don’t have the patience (or the time) to read through the 1,000+ pages, here are some highlights from what CMS is suggesting for the second year of MIPS. Bear in mind that these are proposals; they must be confirmed in the Final Rule, which will be released by November. (What had already been set in stone within the MACRA legislation itself is the maximum penalty and related incentive: 5% in 2020 based on performance in 2018, up from 4% in 2019 based on performance in 2017.)

  • CMS would allow clinicians to use either 2014- or 2015-Certified EHR technology to report for 2018. Acknowledging the slower-than-anticipated pace at which EHRs are achieving the next required certification, this accommodation will facilitate more successful, non-rushed upgrades and provide sufficient time for training on the new capabilities and associated requirements. To encourage the move to 2015 CEHRT, 10 ACI bonus points would be awarded for its exclusive use. (Finalized as proposed)
  • The Quality reporting period returns to full year, but ACI (Advancing Care Information) and Improvement Activities remain at a minimum of 90 days. Cost is still unscored, but performance in this category will be evaluated by CMS and feedback will be provided to clinicians to prepare them for 2019 when, by law, the cost category must account for 30% of the MIPS score. (Finalized as proposed)
  • The proposed performance threshold separating “the winners” from “the losers”, (i.e., recipients of positive vs. negative payment adjustments), would increase from 3 points out of 100 in 2017 to 15 MIPS points in 2018—still an eminently achievable bar. (Finalized as proposed)
  • CMS would implement increased protection for small groups (≤15 eligible clinicians)—these are the practices that had been predicted to be the most vulnerable to penalties. (Finalized as proposed)
  • Many more clinicians would be exempt from MIPS altogether because the eligibility threshold would increase from $30,000 to $90,000 in annual Medicare revenue and from at least 100 to at least 200 Medicare patients.
  • Small groups that do participate in MIPS would receive 5 bonus points toward their score, in an attempt to level the playing field.
  • And my favorite proposal (Unfortunately, not finalized as proposed) is one that specialists, in particular, will appreciate: the elimination of the restriction that all 6 quality measures had to be reported by the same submission method. In 2018, clinicians would be able to mix and match submission methods within a category. Specialists, who have typically been faced with an insufficient number of relevant eCQMs, would be able to continue reporting those measures which are available by EHR submission, but could supplement them with registry or claims measures that are also specialty specific. The result would be more meaningful reporting and more equitable scoring. This is a request that SRS has included in its comments to each of the previous proposed and final MACRA rules, so we were very happy to see this change.

MIPS is only one of the two MACRA participation options, and CMS has also proposed some changes designed to accelerate the shift from MIPS to Alternate Payment Models. More on that topic in a future post.