Category: Clinical Documentation

Is MIPS really doing what it is supposed to do? Research suggests that it is not.

How well does the Merit-based Incentive Payment Program (MIPS) of Medicare measure the caliber of medical treatment that is given? According to the findings of a recent study, not very.

The 2017 introduction of MIPS, which replaced three prior quality measurement programs, aimed to enhance patient care by financially rewarding or penalizing physicians based on their performance on particular “process” and “outcome” metrics in four key areas: cost, quality, improvement activities, and fostering interoperability.

The six metrics that participating physicians choose to report on must include one outcome indicator, such as a hospital admission for a particular disease or condition. Currently, MIPS is the biggest value-based payment program in the country.

Data from Medicare statistics and claims records for 3.4 million individuals who saw about 80,000 primary care providers in 2019 were evaluated for the study by researchers. They compared doctors’ overall MIPS scores with their scores on five process measures, including breast cancer screening, tobacco screening, and diabetic eye exams, and six outcome measures, including ED visits and hospitalizations.

The findings showed there was no consistent relationship between the measures’ performance and the final MIPS ratings. For instance, doctors with low MIPS scores scored somewhat better on the other two process measures, while having much lower average MIPS scores than physicians with high MIPS scores on three of the five process measures examined.

Low-scoring doctors performed much worse on the all-cause hospitalizations per 1,000 patients metric than they did on the other four outcome measures, although they performed significantly better on the metric of ED visits per 1,000 patients. Similar to this, 21% of physicians with high MIPS scores had outcomes that were in the poorest percentile, compared to 19% of those with low MIPS scores who performed in the top quintile for composite outcomes performance.

The findings suggest that the MIPS program’s accuracy in identifying high- versus low-performing providers is really no better than chance.

For these findings, the authors provide a number of interpretations. Among them are the challenges in making meaningful comparisons when doctors are free to select the metrics they report on, the fact that many program metrics, as other research has shown, are either invalid or of dubious validity and thus may not be linked to better outcomes, and the possibility that high scores may simply be an indicator of a program’s capacity for data collection, analysis, and reporting rather than of higher quality medical care.

They claim that the latter conclusion is supported by the discovery that participants with low MIPS scores were more likely to work in independent, small practices even though their clinical outcomes were frequently comparable to those of medical professionals in large, system-affiliated practices with high MIPS scores.

This research was released in JAMA on December 6. https://jamanetwork.com/journals/jama/article-abstract/2799153

Hospital Outpatient Departments: Effective July 1, 2020 you must request prior authorization for certain hospital Outpatient Department (OPD) services

For dates of service beginning July 1, 2020, you must request prior authorization for the following hospital Outpatient Department (OPD) services:

  • Blepharoplasty
  • Botulinum toxin injections (when paired with specific procedure codes)
  • Panniculectomy
  • Rhinoplasty
  • Vein ablation

Medical necessity documentation requirements remain the same and hospital OPDs will receive a decision within 10 days.

While only the hospital OPD service requires prior authorization, CMS wants to remind other providers that perform services in the hospital OPD setting that claims related to/associated with these services will not be paid if the service requiring prior authorization is not eligible for payment. These related services include, but are not limited to, anesthesiology services, physician services, and facility services. Only associated services performed in the hospital OPD setting are affected. Depending on the timing of claim submission for any related services, claims may be automatically denied, reviewed, or denied on a postpayment basis.

For botulinum toxin injections, consult the list of codes that require prior authorization for more details. Generally, the use of botulinum toxin injection codes paired with procedure codes other than 64612 or 64615 will not require prior authorization under this program.

Saince announces the launch of tele-medicine feature within its clinical documentation solution

Doc-U-Scribe clinical documentation solution now comes integrated with tele-medicine workflow. Physicians and administrators can create tele-consultation sessions with patients seamlessly from within the application. This process eliminates the need for providers to use separate solutions – one for clinical documentation and another for video session.

The COVID-19 public health crisis has accelerated the use of tele-medicine solutions among healthcare provides across the nation. However, many small hospitals and physician offices do not have access to a single solution that takes care of all their needs. Physicians are forced to use multiple solutions to complete their tele-medicine workflow. They are often finding this process frustrating and cumbersome.

Doc-U-Scribe clinical documentation solution which is used by hundreds of hospitals and physician offices across the country provides an integrated and seamless workflow for clinical documentation as well as tele-medicine.   This new HIPAA compliant tele-medicine solution can cut costs, increase efficiency, and improve physician satisfaction significantly.

Saince announced that this new feature will be available to all their existing customers immediately. Saince also announced that with their plug and play model, any new hospital or physician office can be up and running with their tele-medicine program within 48 hours.

Safeguarding Cyber security Amid CDI Efforts

Original: Cyber security, Coding and CDI. Best practices to ensure best practices for cyber security are employed.

 

To say that the present state of healthcare cyber security poses a challenge for organizations undertaking clinical documentation improvement (CDI) efforts is a drastic understatement. Under the ever-present specter of costly cyber attacks, providers across the country continue to grapple with myriad, big-picture challenges such as information governance (IG), highly ambiguous government oversight and unstable compliance landscapes as well as shifting care settings.

 

Providers are required to adhere to strict security laws like HIPAA and HITECH while simultaneously acceding the regulatory demands of fluid information sharing contained in the 21st Century Cures Act—all while adapting to the logistical reality of increasingly frequent outpatient care delivery. Further intensifying those challenges, the shift to outpatient care means that greater volumes of protected health information (PHI) is being routed through ambulatory and other non-hospital settings, making them increasingly attractive targets for hackers. Additionally, a recent survey of medical coders also found that roughly one-third reported working remotely at some point, highlighting the potential vulnerability many providers face.

 

Healthcare Cyber Security

 

As they approach this challenging future, however, smart organizations can balance conflicting security and compliance concerns as well as inpatient and outpatient CDI initiatives by sharpening their focus in a few key areas.

 

Staffing and Training. In CDI, overwhelmed and under-trained teams are more apt to make costly mistakes. The same is true for cyber security. A misaligned and overworked team is a liability and leading cause of security breaches, but one with the tools, training and cohesion to efficiently manage their workflow is a powerful safeguard. The quickest way for any organization to promote quality and compliance—as well as security—while executing CDI efforts is to ensure its staff is trained well. Fostering alignment between providers, coding and other administrative staff must include education on common security risks, drills to identify weak points and emphasis on a culture where anomalies, breaches and prevention are openly discussed and addressed.

 

Emphasis on Accuracy and Clarity. Just as optimized CDI and streamlined organizational compliance—from the point of care to the submission of a claim—can reduce error-driven medical necessity denials, that same focus on accuracy and clarity can reduce security errors as well. As provider organizations seek to improve overall IG while also contending with growing troves of clinical data, enhanced CDI workflow is a necessary component strategy, intricately linked with all others.

 

Encryption of All Devices. Loss of mobile devices is a major cause of healthcare data breach, particularly in outpatient settings. As mobile devices become increasingly common tools in clinical documentation, ensuring that these devices and all computers are encrypted is an important, albeit not-HIPAA-required, step for organizations to take.

 

Vetting Vendors. An organization must safeguard its own internal protocols, but it must also ensure that its vendors—particularly those offering Software as a Service (Saas)—are taking all reasonable steps to protect data, confidentiality and security as well. It’s a must to understand a vendor’s risk assessments and require indemnification provisions and cyber security insurance in business associate agreements.

 

Designing your organization’s CDI efforts is a significant undertaking. To learn about  PracticePerfect, a platform to help you address outpatient CDI, or Doc-U-Aide, a revolutionary platform for inpatient CDI, contact Saince.

 

 

 

 

 

 

 

 

CMS introduces new payment model for both inpatient and outpatient care

The Centers for Medicare & Medicaid Services (CMS) announced the launch of a new voluntary bundled payment model called Bundled Payments for Care Improvement Advanced (BPCI Advanced). Under traditional fee-for-service payment, Medicare pays providers for each individual service they perform. Under this bundled payment model, participants can earn additional payment if all expenditures for a beneficiary’s episode of care are under a spending target that factors in quality.

Bundled payments create incentives for providers and practitioners to work together to coordinate care and engage in continuous improvement to keep spending under a target amount. BPCI Advanced participants may receive payments for performance on 32 different clinical episodes which are listed below.

Of note, BPCI Advanced will qualify as an Advanced Alternative Payment Model (Advanced APM) under the Quality Payment Program (QPP). Under Advanced APMs, providers take on financial risk to earn the Advanced APM incentive payment.

BPCI Advanced will operate under a total-cost-of-care concept, in which the total Medicare fee for services (FFS) spending on all items and services furnished to a BPCI Advanced Beneficiary during the  Clinical Episode, including outlier payments, will be part of the Clinical Episode expenditures for purposes of the Target Price and reconciliation calculations, unless specifically excluded.

Clinical Episodes

BPCI Advanced will initially include 29 inpatient Clinical Episodes and 3 outpatient Clinical Episodes. Participants selected to participate in BPCI Advanced beginning on October 1, 2018, must commit to be held accountable for one or more Clinical Episodes and may not add or drop such Clinical Episodes until January 1, 2020.

Inpatient Clinical Episodes – 29

  • Disorders of the liver excluding malignancy, cirrhosis, alcoholic hepatitis *
    *(New episode added to BPCI Advanced)
  • Acute myocardial infarction
  • Back & neck except spinal fusion
  • Cardiac arrhythmia
  • Cardiac defibrillator
  • Cardiac valve
  • Cellulitis
  • Cervical spinal fusion
  • COPD, bronchitis, asthma
  • Combined anterior posterior spinal fusion
  • Congestive heart failure
  • Coronary artery bypass graft
  • Double joint replacement of the lower extremity
  • Fractures of the femur and hip or pelvis
  • Gastrointestinal hemorrhage
  • Gastrointestinal obstruction
  • Hip & femur procedures except major joint
  • Lower extremity/humerus procedure except hip, foot, femur
  • Major bowel procedure
  • Major joint replacement of the lower extremity
  • Major joint replacement of the upper extremity
  • Pacemaker
  • Percutaneous coronary intervention
  • Renal failure
  • Sepsis
  • Simple pneumonia and respiratory infections
  • Spinal fusion (non-cervical)
  • Stroke
  • Urinary tract infection

Outpatient Clinical Episodes – 3

  • Percutaneous Coronary Intervention (PCI)
  • Cardiac Defibrillator
  • Back & Neck except Spinal Fusion

Hospital OPPS and ASC Payment System and Quality Reporting Programs Changes for 2018

On November 1, CMS issued the CY 2018 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System final rule with comment period, which includes updates to the 2018 rates and quality provisions and other policy changes. CMS adopted a number of policies that will support care delivery; reduce burdens for health care providers, especially in rural areas; lower beneficiary out of pocket drug costs for certain drugs; enhance the patient-doctor relationship; and promote flexibility in healthcare.

CMS is increasing the OPPS payment rates by 1.35 percent for 2018. The change is based on the hospital market basket increase of 2.7 percent minus both a 0.6 percentage point adjustment for multi-factor productivity and a 0.75 percentage point adjustment required by law. After considering all other policy changes under the final rule, including estimated spending for pass-through payments, CMS estimates an overall impact of 1.4 percent payment increase for providers paid under the OPPS in CY 2018.

CMS updates ASC payments annually by the percentage increase in the Consumer Price Index for all urban consumers (CPI-U). The Medicare statute specifies a Multi-Factor Productivity (MFP) adjustment to the ASC annual update. For CY 2018, the CPI-U update is 1.7 percent. The MFP adjustment is 0.5 percent, resulting in a CY 2018 MFP-adjusted CPI-U update factor of 1.2 percent. Including enrollment, case-mix, and utilization changes, total ASC payments are projected to increase approximately 3 percent in 2018.

Physician Fee Schedule Final Policy for Calendar Year 2018

On November 2, CMS issued a final rule that includes updates to payment policies, payment rates, and quality provisions for services furnished under the Medicare Physician Fee Schedule (PFS) on or after January 1, 2018.

The overall update to payments under the PFS based on the finalized CY 2018 rates will be +0.41 percent. This update reflects the +0.50 percent update established under the Medicare Access and CHIP Reauthorization Act of 2015, reduced by 0.09 percent, due to the misvalued code target recapture amount, required under the Achieving a Better Life Experience Act of 2014. After applying these adjustments, and the budget neutrality adjustment to account for changes in Relative Value Units, all required by law, the final 2018 PFS conversion factor is $35.99, an increase to the 2017 PFS conversion factor of $35.89. 

Highlights of Quality Payment Program for Year 2 (Calendar Year 2018) Under MACRA

Here are the highlights of the Final Rule for QPP for Year 2 under MACRA as announced by CMS yesterday:

• Weighting the MIPS Cost performance category to 10% of your total MIPS final score, and the Quality performance category to 50%.
• Raising the MIPS performance threshold to 15 points in Year 2 (from 3 points in the transition year).
• Allowing the use of 2014 Edition and/or 2015 Certified Electronic Health Record Technology (CEHRT) in Year 2 for the Advancing Care Information performance category, and giving a bonus for using only 2015 CEHRT.
• Awarding up to 5 bonus points on your MIPS final score for treatment of complex patients.
• Automatically weighting the Quality, Advancing Care Information, and Improvement Activities performance categories at 0% of the MIPS final score for clinicians impacted by Hurricanes Irma, Harvey and Maria and other natural disasters.
• Adding 5 bonus points to the MIPS final scores of small practices.
• Adding Virtual Groups as a participation option for MIPS.
• Issuing an interim final rule with comment for extreme and uncontrollable circumstances where clinicians can be automatically exempt from these categories in the transition year without submitting a hardship exception application (note that Cost has a 0% weight in the transition year) if they were have been affected by Hurricanes Harvey, Irma, and Maria, which occurred during the 2017 MIPS performance period.
• Decreasing the number of doctors and clinicians required to participate as a way to provide further flexibility by excluding individual MIPS eligible clinicians or groups with ≤$90,000 in Part B allowed charges or ≤200 Medicare Part B beneficiaries.
• Providing more detail on how eligible clinicians participating in selected APMs (known as MIPS APMs) will be assessed under the APM scoring standard.
• Creating additional flexibilities and pathways to allow clinicians to be successful under the All Payer Combination Option. This option will be available beginning in performance year 2019.

EMRs Taking Away Close to One-Third of Physicians’ Work Time – AMA

The EMR Time Crunch

A common complaint among physicians across practices and specialties has been the amount of time that was previously spent attending to patients is now being occupied by clinical documentation.  These time disparities can have adverse effects on physician-patient relationships, and also limit the number of patients able to receive care from a physician or practice. Value-based purchasing models are frequently the basis for physician reimbursements, and because these models require extensive documentation to accurately report the quality and cost of care, the EMR software physicians are required to use is becoming increasingly complex and time consuming.

AMA Findings

A recent study conducted by the American Medical Association focusing specifically on the use of electronic health records in academic centers concluded that an average of 27% of the participating Ophthalmologists’ time spent on patient examinations was occupied by EMR use. On average a total of 5.8 minutes per patient and 3.7 hours was spent working in EMR on any given full day of clinic.  The study also found a negative association between the amount of time spent on EMR per patient encounter and overall clinic patient volume.

The AMA study concluded what many physicians have been expressing for years: doctors have limited time to spend with patients while they are spending more time within EMRs. Aside from the strain EMR places on physicians’ time and patient relationships, it is also creating cumbersome clerical burdens when completed incorrectly or hastily. Large swaths of copied and pasted text create bloated and messy records, and a lack of training and technical knowledge can result in incorrect coding, medical errors, and frequent interruptions in the documentation process.

Physician Dissatisfaction

The amount of physician dissatisfaction has also grown with the increased implementation of EMRs. Nearly half of all physicians report feeling unsatisfied with their work-life balance, and 57% of physicians display signs of burnout. The additional time requirements of clinical documentation are a significant factor in both of these statistics. Physicians are spending an increasing amount of time outside of regular work hours completing EMRs, and an increasingly less amount of time on actual patient care and interaction. This has led to heightened levels of stress and job dissatisfaction.

Looking Forward

While the path hasn’t always been an easy one, electronic medical records are here to stay, and they do present a plethora of benefits to clinical documentation, patient care, and bottom lines. The challenge that needs to be addressed is how to make EMRs efficient and thorough, while minimizing the amount of time physicians are required to spend on them.  Perhaps the solution for better EMR efficiency lies within a hybrid workflow — a workflow that combines the traditional model of medical transcription, where physicians dictate patient encounters and trained transcriptionists and coders review the reports for accuracy and sufficiency, combined with the advantages of using a modern day EMR is the most efficient way to ensure document quality and lessen the time burden EMRs place on physicians. When the responsibility of clinical documentation is not placed solely on the physician, doctors will be able to attend to more patients, improve patient relationships, and increase their job satisfaction.

The Cost of Care: How AI is Revolutionizing Healthcare and Driving Down Prices

The cost of healthcare is once again at the center of a national debate.  With premiums rising, the baby boomers aging, and diabetes, the most expensive disease in the world, affecting 10% of the US population, the rising cost of healthcare in America is an issue that affects all of us.  In the past, the implementation of new and emerging technologies in healthcare has contributed to the climbing costs. In contrast, the application of AI into healthcare is promising to drive those costs down.

Healthcare is an enormously expensive industry and the costs are steadily climbing.  According to World Book, in 2014 healthcare made up 17.1% of the GDP of the United States– up 4% from 1995, and continuing to grow.  The application of artificial intelligence into healthcare is promising to greatly reduce these expanding expenses while improving healthcare quality and access.  By 2026, it’s estimated $150 billion could be saved annually in the US healthcare economy by AI applications. It’s no wonder that healthcare is currently the number one investor in AI.

One of the areas in healthcare that will be most significantly impacted by the application of artificial intelligence is clinical documentation. AI applications in medical workflow management are estimated to accumulate $18 billion in annual savings for the healthcare industry by 2026, the third largest estimated savings from AI technology in healthcare after robotic surgery and virtual assistants.  Modern healthcare AI is capable of learning and comprehending and can perform clinical healthcare functions in much the same way as a human, minus human error.

Physician error in clinical documentation is an understandable yet costly complication in healthcare, and AI is able to streamline the tedious clinical documentation process and automatically generate accurate and complete reports.  Many AI healthcare programs are capable of fully augmenting human behavior and can perform tasks from risk analysis to patient diagnosis. Physician engagement in clinical documentation is a critical component to the quality and costs of healthcare, and AI applications are proving to increase physician engagement and improve clinical documentation quality.

With so much potential to improve not only healthcare costs, but also access and quality, the AI health market is currently experiencing a boom, and is expected to grow into a $6.6 billion dollar industry by 2021. This growth makes sense when you consider that the nation and the world are currently facing a shortage of doctors and healthcare personnel, and AI offers hospitals and physician practices a way to combat their rising operational and labor costs, while enabling them to better perform critical administrative functions quickly, accurately, and cost effectively.

Artificial Intelligence seems like the wave of the future, but the reality is, the future is here. In today’s medical environment of value-based care, appropriate reimbursements are incumbent upon accurate, high quality clinical documentation. As AI continues to grow and evolve, AI enabled clinical documentation improvement technology will continue to transform the healthcare industry, improving patient outcomes and optimizing revenue.