I will bet that in their course they will not mention that “the physician must [participate in MIPS]” is not true. The physician chooses to comply in the hope of getting that 9% increase in Medicare payment. CMS says 47% of physicians will lose the zero sum game of MIPS. Weill Cornel Medical college estimates the cost of compliance with EMR, PQRS, etc to be $40,000/physician/year. As I’ve said before, do the math. You would have to clear $430,000 at a 9% return (if you are in the elite compliers) to reimburse yourself for your compliance costs. Hey, then you’d be rolling in reward money…What a thinly veiled process to gather the data to justify real time treatment dictates. I know of no other profession that would give up their privileged communication without a tooth and nail, knock down drag out fight, except the medical profession. If only because of the disastrous treatment implications of not being able to candidly talk and privately record medical and surgical encounters, it would seem to me that all physicians, in spite of the many compliance courses, should choose to just say no, at least to “interoperable EMR with 24/7 unfettered access” by HHS and CMS, as dictated in the MACRA law.
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.
After spending the last 7 years treading water naively and optimistically waiting for things to be repealed and fixed and after countless trips to DC and across the country trying to cry from the wilderness of the practice of medicine from the trenches with many of you and our organizations, I am convinced this is beyond repair and will never be repealed by those in power.
The Philosophy of the architects of the current system we are floundering in is the antithesis of Hippocratic medicine and in fact works to undermine and dismantle it. Just take innovation- look at Ezekiel Emanuel’s own words on this- he believes innovation is too expensive and the taxes in Obamacare reflect this opinion. He also is an ethicist whose roots stem from his area of expertise which is dying with dignity and systems of rationing like the complete lives system. Continue reading →