More Fed carrots? Or just a different stick? #MACRA #MIPS

Secretary Azar says HHS may cease reporting requirements for MIPS “value-based” care. Perhaps you’re beginning to think that they are finally hearing us, right?

However reading further, things get murky fast:

Instead of requiring physicians who participate in MIPS to submit patient data, the proposal suggests having the government use claims data and patient surveys to grade doctors in the program. “We would be able to independently look at data ourselves to decide their compliance with the quality programs rather than their having to even report anything,” Azar said at Thursday’s hearing.

Here’s what some physicians are saying about this “new direction” from HHS:

  • I’m not going to celebrate just yet. Think of how often HHS/CMS have replaced a bad idea they had, with an even worse idea. If they begin using patient surveys (Press Gainey, etc.) to determine whether or not physicians are given a bonus or penalty, I think that could actually make this awful MIPS experiment even worse.
  • We must be careful what we ask for- and we must control the conversation. There is no reason the government needs to be involved at all – that’s the beautiful thing about the free market – the patient receiving the service determines the value – but the patient must have an  appreciable fiduciary responsibility and they vote with their wallet – good restaurants are busy – bad restaurants are closed – really quite simple.
  • MACRA/MIPS  is fatally flawed.  Patients are individuals and cannot be reduced to an algorithm.
  • There is nothing salvageable or workable in the MIPS system. There is no way on paper and with claims that physician skill, judgement or even outcomes can be legitimately assessed. Further, major institutions are rethinking patient evaluations of physicians, realizing that it is a one way system-i.e. there is no way to evaluate the validity of the patient evaluation and no way for the physician to respond.
    In my opinion our best/only meaningful way of reform is to condemn the entire MACRA/MIPS construct as wasteful and invalid without adding anything to patient care. In fact a point can be made that it detracts from actual care.
  • We should have a say in the type of patient survey they set up. And this should decide only incentives not penalties. The only difference between this and MIPS is that with MIPS we can lose money after spending it on data collection, whereas here we avoid double jeopardy because they do their own data collection and we don’t have to attest to anything. Overall I think what they have suggested is better than MIPS.
  • I just had a very cranky daughter complain about the resident who called her sister rather than her when her mother took a turn for the worst. She would give that resident a failing grade. So much subjectivity makes those evaluation meaningless. Also, when grading a physician on outcomes, which physician can take credit for which specific outcome? Many physicians are often involved. This evaluation scheme is totally unworkable.

I think you’ll agree there is more than a bit of skepticism that CMS is going to meaningfully change things for the better. Tell us what you think!

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MACRA MIPS? Time for GACRA GIPS to hold lawmakers accountable.

How can we hold Congress accountable for the failed policy they continue to foist on American patients and doctors?

Meet GACRA GIPS, the Government Accountability Credibility Realignment Assessment and Government Incentive Payment System.

With GACRA GIPS, if congressmen and congresswomen don’t work, vote, complete their tasks and create a budget that lives within our means well paying down the national debt, they don’t get paid.

Learn more about this needed reform in the latest article by IP4PI founder Craig M. Wax, DO published by Medical Economics:

http://medicaleconomics.modernmedicine.com/medical-economics/news/your-voice-physician-accountability-let-s-legislate-congressional-accountability

57 Million Seniors’ Medical Care Imperiled by Medicare Red Tape

Action is needed this weekend! Take advantage of an opportunity to cut through some of the bureaucratic red tape that imperils the medical care of 57 million seniors. Actually, the regulations in question harm not only Medicare patients, but also put “commercially insured patients and their data under the agency’s control,” explains Dr. Kris Held.

CMS is seeking comments from the public on proposed changes to MACRA rules to be implemented in 2018.

Tell CMS to further widen exemptions from MACRA overregulation for physicians and their patients.

Comments are due by 11:59pm Eastern Daylight Time, Monday, August 21, and can be submitted online at the following link:

https://www.regulations.gov/comment?D=CMS-2017-0082-0002

Here’s an example of what you might say:

MACRA compliance is not compatible with patient-centered medical care. CMS must use all possible discretion authorized under law to free as many physicians as possible, and their patients, from this harmful overregulation. At the very least, practices with 15 physicians or fewer should be exempt from all MACRA penalties.

Additional details:

The U.S. Centers for Medicare & Medicaid Services (CMS) has released proposed changes to its so-called “Quality Payment Program” (QPP) rules for 2018. The QPP “implements provisions of the Medicare Access and CHIP Reauthorization Act (MACRA) related to the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs).”

While initially created under the guise of increasing “quality” and “value,” in practice the program attempts to coerce doctors to comply with cookbook medicine and government rationing protocols while at the same time compromising patient privacy.

Fortunately, there are some new faces at CMS who understand the danger of this program and a few helpful changes have been proposed; however the changes don’t go nearly far enough. We are asking CMS to use all possible authority to lessen the burden on patients and physicians.

AAPS is not alone in calling for these needed changes. The Editorial Director of Medical Economics has called on CMS to “Exempt all small practices from the program. … Smaller practices shouldn’t have to play the same game as the larger practices they already compete against every single day when it comes to things like patients, resources and payer influence. Don’t make the alleged ‘failures’ of small practices fund larger practice payment bonuses.”

Please submit your comments to CMS on this crucial issue before the Monday deadline.

Thank you for your help!

~AAPS

For the full proposed rule see:

https://www.regulations.gov/document?D=CMS-2017-0082-0002

And the CMS fact sheet on the changes is available at:

https://qpp.cms.gov/docs/QPP_Proposed_Rule_for_QPP_Year_2.pdf

Tell CMS to Protect Patients and Physicians from Harmful Red Tape

CMS has released the proposed 2018 regulations for MACRA and is asking for comments.  The new changes don’t go far enough to protect independent physicians and their patients from harmful red tape.

CMS has a fact sheet about the proposed rule available here:

Comments are dues August 21 and can be submitted here:
https://www.regulations.gov/document?D=CMS-2017-0082-0002

Dr. Marcy Zwelling had put together sample comments to help everyone get the correct message to CMS.

Below are comments that you can cut and paste –

Medicare Administrators: 

We appreciate the sentiment of the new MIPS regulations, but it does not get the job done for many physicians struggling to go to work and NOT sit behind a computer all day. America’s physicians need to be able to just do our job and struggling with computers does not help us get it done.  It is not about micro-managing the regulations; it’s about our professionalism. 

We understand the statutory constraints, and we think we have the answer.  If the regulations could be edited to read 

Exemptions permitted:

Clinicians below the low-volume threshold – Medicare Part B allowed charges per physician less than or equal to $90,000 OR 200 or fewer Medicare Part B patients per physician up to a 6 person practice. 

Thank you for your serious consideration.  While this change does not save all small practices, we feel that this minor change will send the right message to American physicians and will encourage physicians to work with CMS and keep their offices open. 

 Further, we encourage CMS to follow thru with Dr. Price’s commitment to allow physicians to balance bill as a means of enhancing our patients’ options and keeping physicians’ doors open. 

MIPS Math: a losing equation for physicians and patients

Dr. Jane L. Hughes reacts to the latest offer for MIPS “training”: http://conta.cc/2ps7YTq

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.

Best regards,

Jane

58 Hours of CME George Orwell Style

Friend of IP4PI Jane Hughes, MD writes in:

Anyone who thought that things were on hold regarding continued implementation of ACA and the statist move by Medicare via MACRA and its payment scheme called MIPS to centralize and control patient and physician choices needs to read this upcoming offering for unprecedented free CME from one of our premier institutions, Johns Hopkins. Key to centralization is electronic medical records that are interoperable. Read that to mean 24/7 access by government/insurance for data gathering and eventual treatment rubrics. Note that all of these CME hours are not featuring medical or surgical issues, they deal with “educating” and indoctrinating physicians on the advisability of population based care.

This is a sinister turn for the worse. We should have gotten a health plan through in some form to start the dismantling of ACA and trumpet the message that this is the beginning of decentralizing healthcare. Critical to reform of Medicare and getting rid of MACRA is a stable, affordable, and accessible private option.

These sponsoring organizations are proceeding as if nothing has changed. Until Trump appointees get rid of entrenched bureaucrats subversive to the true reform of statist ACA this is no surprise. The collusion with insurance and govt also needs to be exposed. These two forces are insatiable looters of tax monies, people’s premium moneys, individual human dignity, and doctor and physician choices. Note they are offering 58 hours of CME credit/brainwashing. What an impotent feeling to read that even an institution as grand as John Hopkins has succumbed to the George Orwell form of medical care.

IP4PI to CMS: Exempt Independent physicians from ACA MACRA MIPS and APMs

CMS ACA MACRA MIPS and APMs discriminate against independent solo and small primary care practices, while unfairly advantaging hospital health systems who employ doctors. Please exempt solo and small physician practices of 9 or fewer doctors or less than 999 Medicare patients. CMS ACA MACRA MIPS and APMs will put small independent practices out of business and will deprive patients of their physician, jeopardizing their health.

Submit your comments at:

https://www.regulations.gov/comment?D=CMS-2016-0060-3944