Dr. Jane Hughes writes in with a summary of pages 100-200 of CMS’ proposed rules to implement MIPS & APMs.
Submit your comments to CMS before June 27!: https://www.regulations.gov/#!submitComment;D=CMS-2016-0060-0068
Here are the most telling and salient points for pages 100-200.
- All reporting has to go through EMR/Questionaires CMS approves
- The requirements are going to increase for reporting outcome measures over next several years as more outcome measures become available
- High priority measures to be rated are a. Outcome b. Appropriate use (not defined nor not specified who decides “appropriate use”) c.Patient safety d. Patient experience e. Care coordination quality measures
- CMS believes MIPS “Appropriate use will minimize overuse of services, treatments or related ancillary testing that may promote overuse of services and treatments.”
- CMS decides “underuse” of specific services that reflect “overuse” of alternate treatments that are not evidenced based or supported by clinical guidelines. CMS assures that they will seek input from various “stakeholders” as to evidenced based treatments and clinical care guidelines.
- CMS plans to develop a.Care episode groups b. Patient condition groups c. Patient relationship groups with codes for all.
- CMS plans to update definition of primary care services, and thinks MIPS survey will closely align with PQRS, but they state they do not know yet.
- Doctors will bear the cost of contracting with CMS approved survey vendors to administrate the required MIPS surveys.
- In future years there will be bonus points, girls and boys, for patient experience reports. CMS may expand patient experience measures to all payers so that everyone can be be included.
- CMS expands reporting to non-Medicare patients to “ensure completeness” for the broadest group of patients possible. If submitting via qualified registries or EMR must report on 90% of patients. If using Medicare Claims must report on 80% patients. KEY: CMS thinks this gives a more complete picture of each MIPS eligible clinician’s scope of practice and more access to data not currently captured on PQRS.
- CMS plans on increasing data requirements in the future.
- Global population based measures and global outcome measures may be used by the Secretary for purposes of defining quality performance. Will use Agency for Healthcare Research and Quality (AHRQ) and Prevention Quality Indicators (PQI)in calculating total MIPS score.
- Secretary will publish annual list of quality measures which may change from the previous year. If performance on a measure becomes so high that meaningful improvement is not possible, it will be eliminated.
- There’s more of the same, with promises of even more rules to come.
This is absolutely not achievable. The first step is for every doctor to quit reporting and take the deduction. Recall that Meaningful Use 3 had to be suspended. This is the absolute takeover of every aspect of our profession, violation of patient privacy and dignity, and an absolute indictment of our Congress, and especially every physician in Congress. Obamacare is imploding around us and had no Republican fingerprint. This was bipartisan, not read beforehand, and once again a trillion dollar plus mistake before it is over if it is not stopped. This does not measure physician quality nor improve patient care. It measures compliance with disastrous consequences our profession.