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Archive for October, 2013

SGR and Value Based Performance: The Umbrella Carrot-and-Stick Program

October 31, 2013 2 comments

On October 30, the Senate Finance and House Ways and Means Committees released a bipartisan, bicameral discussion draft paper titled “SGR Repeal and Medicare Physician Payment Reform.” The draft proposes a framework for a permanent Sustainable Growth Rate (SGR) formula fix, encourages alternative payment models, and aligns various Medicare incentive programs, including the EHR Incentive Program (“meaningful use” or MU). The purpose of the proposal is to solicit comments from the public.

In terms of MU and various other incentive programs, the proposal would rework the imminent penalties and reintroduce incentives in an interesting way beginning in 2017. There would be an umbrella Value Based Performance (VBP) Payment Program based on a “composite score” determined by a physician’s compliance with MU, PQRS/quality, Value Based Modifier/resource use, and clinical practice improvement activities (including participation in Medicare Alternative Payment Models, work in federal Health Professional Shortage Areas, and so on). A high or low composite score will determine whether the physician is incentivized or penalized for VBP as opposed to individual program penalties. The funding pool created by payment reductions to those with low composite scores will be used to pay incentives to those with high composite scores. The penalties and incentives will amount to 8% Medicare payments in 2017, 9% in 2018, and 10% in 2019. After 2019, the funding pool can be increased, but not lowered, by HHS.

While each of the components of the composite score are weighted to a certain percentage (MU, for example, would be up to 25% of the composite score if fewer than 75% of eligible professionals are compliant), the draft proposal does not address what “high” or “low” composite scores specifically are. For example, would 50% of physicians be incentivized while 50% are penalized, or would it scale like the Value Based Modifier system where only the outliers are penalized? The future legislation will likely address these and other details.

Note that the discussion draft covered other subtopics beyond the aforementioned VBP program. The most exciting of the proposals for radiology was the inclusion of appropriateness criteria-guided decision making for physicians who order diagnostic imaging. See the American College of Radiology’s website for more information.

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Categories: EHR, meaningful use, Medicare

GAO Releases Report on MU Payments

October 24, 2013 Leave a comment

On October 24, the Government Accountability Office (GAO) released a report exploring Medicare EHR Incentive Program (“meaningful use” or MU) participation in 2011 and 2012.  Some highlights:

  • 183, 712 or 31% of all eligible professionals (EPs) received Medicare EHR Incentive Program payments in 2012
  • Over 56% of those EPs who received incentives were “specialty practice physicians”
  • “General practice physicians” were 1.5 times more likely to have received an incentive payment than specialists
  • 12% of radiologist EPs received an incentive payment in 2012

While only a few specialties were covered individually, the report was striking for how many specialties are surpassing radiology in terms of MU participation. For example, 31.7% of ophthalmologist EPs received MU incentive payments in 2012. Only two specialties specifically called out in GAO’s report had lower levels of participation—psychiatry and dentistry—but we know from the Centers for Medicare and Medicaid Services (CMS) and Office of the National Coordinator for HIT (ONC) public data that several other major specialties, including pathology and anesthesiology, were also lower than radiology in 2012.

Clearly, the data shows that CMS and ONC have a long way to go to meet the 75% EP participation goal by 2018.

…In other GAO health IT news, the agency also released its list of new appointments to ONC’s HIT Policy Committee.  A big part of the problem highlighted in the aforementioned participation report is a lack of specialty representation on the federal advisory committees that provide MU-related recommendations to ONC and, indirectly, CMS.

Getting the Band Back Together Post-Shutdown

October 23, 2013 Leave a comment

It has been a week since the federal government shutdown ended. Many health IT-related federal agencies are still getting back on track.

The National Institutes of Health (NIH) Office of Extramural Research published a series of guide documents and blog entries on the resumption of activities. NIH also put together a convenient website compiling links to all shutdown and post-shutdown information for extramural grantees, as well as a helpful batch of FAQs.

The Office of the National Coordinator for HIT’s federal advisory committees and related workgroups continued to experience cancellations of their virtual meetings for several days after the shutdown. The HIT Policy Committee’s Privacy and Security Tiger Team was the first such advisory body to publicly convene as scheduled.  It appears ONC’s advisory committee/workgroup calendar will be back to normal beginning October 24.

The Centers for Medicare and Medicaid Services (CMS) FAQ website is back up.  This critical source of first-party guidance regarding the EHR Incentive Program (and all other CMS programs and initiatives) was totally unavailable for the duration of the shutdown.

Medicare Quality Initiatives at 2013 ACR Imaging Informatics Summit

October 16, 2013 Leave a comment

Meaningful Use in 2014 - Michael PetersI had the honor of presenting with Judy Burleson, Senior Advisor, Metrics in the American College of Radiology’s (ACR) Quality and Safety Department during the third annual ACR Imaging Informatics Summit & Data Registries Forum in Washington, DC. Our October 11 breakout session featured updates on Medicare quality initiatives and incentive programs, including the Physician Quality Reporting System, EHR Incentive Program, Value-based Purchasing, and more. The session was intended to provide a closer examination of each of the federal government initiatives mentioned in the keynote presentation, “Future of Registries – Alignment Across Quality Efforts,” by Louis H. Diamond, MBChB, FCP, (SA), FACP, FHIMSS (President, Quality in Health Care Advisory Group, LLC).

Ms. Burleson covered various complex subtopics in admirable detail inside of 40 minutes. My presentation was a simplified, ten-slide overview of the 2014 participation requirements for the Medicare version of the EHR Incentive Program (“meaningful use”) for eligible professionals.

Categories: EHR, meaningful use, Medicare

ACR’s Annual Imaging Informatics Summit in DC Soldiers On Despite Government Shutdown

October 10, 2013 Leave a comment

The 2013 American College of Radiology (ACR) Imaging Informatics Summit & Data Registries Forum began today in Washington, D.C. despite the loss of several speakers and attendees due to the ongoing shutdown of the federal government. This year’s meeting features the following HIT policy topics:

  • Radiology and the EHR
  • Clinical decision support
  • Image sharing
  • Mobile devices and applications

Representatives from the Centers for Medicare and Medicaid Services were scheduled to present regarding the status of the Medicare Imaging Demonstration project. Likewise, Food and Drug Administration (FDA) staff were planning to discuss FDA oversight of mobile medical applications. Unfortunately, the Congressional impasse on appropriations for fiscal year 2014 continues…

Categories: EHR, FDA, Medicare, research

How to Avoid Meaningful Use Penalties

October 1, 2013 4 comments

*This article was updated with new information from CMS on March 20, 2014.

The payment adjustments (penalties) for nonparticipation in the EHR Incentive Program (“meaningful use” or MU) are scheduled to begin in calendar year (CY) 2015. Eligible radiologists have two ways to avoid the penalties:

Option 1: Comply on time

  • Prior MU participants must comply in the year that is two years before the penalty year.
  • First time MU participants must complete attestation by October 1 of the year before the penalty year. To complete attestation in time, the reporting period must begin by July 1.

Option 2: Obtain a significant hardship exception
CMS can grant a temporary “significant hardship exception” to a physician on an annual basis for up to 5 years maximum. Exceptions that require manual applications have an application submission deadline of July 1 of the year before the penalty year. The various significant hardship exceptions are as follows:

  • Lacking broadband/infrastructure: The physician was located in an area without sufficient Internet access to comply for any 90-day period of time from the beginning of the year that is 2 years before the penalty year to July 1 of the year before the penalty year. Moreover, the physician must have faced insurmountable barriers to obtaining the internet connectivity.
  • Newly practicing: The physician has been practicing for less than 2 years.  This will be automatically given (no manual application required).
  • Extreme and uncontrollable circumstances: a) A previous MU participant faced extreme and uncontrollable circumstances in the year 2 years before the penalty year. Or, b) a physician who has never participated in MU faced extreme and uncontrollable circumstances in the year before the penalty year.
  • Inability to influence availability of certified EHR technology (CEHRT): The physician practiced at multiple locations, and lacked control over the availability of CEHRT at one or more locations where he/she had more than 50% of his/her patient encounters.
  • Lack of face-to-face/telemedicine interaction with patients AND lack of need for follow-up: The physician can demonstrate difficulty in meeting MU on the basis of lack of face-to-face or telemedicine interaction with patients and lack of need for follow up with patients.
  • Primary specialty listing in PECOS: The physician has a primary specialty listed in PECOS as radiology, anesthesiology, or pathology 6 months before the penalty year. For radiology, the primary specialty listing would need to be “diagnostic radiology” (30), “nuclear medicine” (36), or “interventional radiology” (94). This will be automatically given (no manual application required). Note, CMS has not released information about how to “opt out” if the radiologist was MU compliant in time and does not need to obtain an exception in 2015.
  • 2014 EHR Vendor Issues: The physician’s HIT vendor was unable to obtain 2014 Edition certification in time for a reporting period in 2014.

For more information about the significant hardship exceptions, please see CMS’ website.

Categories: EHR, meaningful use, Medicare