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

Don’t Ignore the Lessons of History: MACRA will simply not work

The following MACRA comments were written by a Kansas City dermatologist, Viseslav Tonkovic-Capin, MD, who grew up under Communism in Czechoslovakia.

I was born and raised in communist Yugoslavia. My dad was a 9 year-old boy when WWII started and was courier for partisans, i.e. resistance against nazis and fascists during the war. After the war it was easy to dupe people into communism, because as an idea it sounded great, but within a several months or years almost everyone realized that it simply will not work.

My dad became lawyer and judge just to end up in the political prison because of his disagreements with the communist interference into his judicial duties. In short order my entire family turned from communists and communist sympathizers into people severely allergic to anything resembling communism.

My dad summarized the difference between communism and the Free World: Continue reading

Final MACRA rule still byzantine and unworkable, patients lose.

The final MACRA rule expands exemptions, flexibility, claims ModernHealthCare.com but it is still byzantine and unworkable. Patients lose.

The 2,398 page rule can be downloaded here: https://qpp.cms.gov/docs/CMS-5517-FC.pdf

We haven’t read the all 2,398 pages yet but here are a few initial notes:

  • The low-volume threshold is now < $30,000 in Part B billings OR < 100 Part B Patients.The proposed rule was < $10,000 AND < 100 Patients.
  • The infamous table from the proposed rule showing 87% of solo docs would face a negative adjustment under MIPS has been “bleached.” The sanitized table no longer lists solo physicians separately, and claims that only 10% of practices from 1 to 9 physicians will will face negative adjustment.  Click here for image combining both new table and old table. Supposedly, overall, 94.7% of eligible clinicians will get a positive or neutral adjustment with 5.3% receiving a negative adjustment.

Another trouble spot to look out for (Page 1513):

“One commenter supported the inclusion of ABMS board certification and participation in Maintenance of Certification (MOC) Programs on Physician Compare. Another commenter recommended MOC participation as a measure in future rulemaking as part of quality performance data publicly reported on Physician Compare … We appreciate the points, concerns, and suggestions raised by commenters and, if feasible and appropriate under the statute, we may possibly consider these issues in future rulemaking. ”

Some other low-lights:

Re Privacy:

“We disagree with commenters who maintained that the disclosure of PHI to ONC or an ONC-ACB (authorized certification body) could be inconsistent with reasonable privacy or other organizational policies or would otherwise be an unjustified invasion of privacy or any other interest. As noted, the disclosure of this information would be authorized by law on the basis that it is a disclosure to a health oversight agency (ONC) for the purpose of determining compliance with a federal program (the ONC Health IT Certification Program). In addition, we note that any further disclosure of PHI by an ONC-ACB or ONC would be limited to disclosures authorized by law, such as under the federal Privacy Act of 1974, or the Freedom of Information Act (FOIA), as applicable.” (page 67)

Data-Collection from all-payers:

“In addition, we are finalizing our approach of including all-payer data for the QCDR, qualified registry, and EHR submission mechanisms because we believe this approach provides a more complete picture of each MIPS eligible clinician’s scope of practice and provides more access to data about specialties and subspecialties not currently captured in PQRS” (page 468)

“We desire all-payer data for all submission mechanisms, to create a more comprehensive picture of the practice performance. Section 1848(q)(5)(H) of the Act authorizes the Secretary to include, for purposes of quality measurement and performance analysis, data submitted by MIPS eligible clinicians with respect to items and services furnished to individuals who are not Medicare beneficiaries. As discussed in section II.E.5.b. of this final rule with comment period, we are finalizing our proposal to require MIPS eligible clinicians to report allpayer data on quality measures where possible.” (pg1396)

CMS will be accepting comments for 60 days, however the online comment portal is not yet open as far as we can determine.  Stay tuned!

MACRA empowers bureaucracy, not patients and their doctors

Richard Armstrong, MD of https://d4pcfoundation.org/ submitted the following comments to CMS in opposition to the 962-page MACRA proposed rule.  Comments are due 6/27.  Submit yours TODAY at http://bit.ly/macracomment

Good afternoon, Ladies and Gentleman,

My name is Dr. Richard Armstrong. I am a general surgeon who has been in practice for 35 years since completing post-graduate training. I have been in the military, in academics, in private practice and now employed. I have watched the development of the federal medical bureaucracy since 1976 and opposed more government intervention then in public in a letter to the Washington post. I did this as an active duty naval officer and received hundreds of letters of support.

In 2009 after President Obama spoke before a joint session of Congress about health care reform, I wrote to him with a simple specific request. I asked him to please speak with the doctors on the front lines, the dedicated physicians and surgeons who care for all of you and your families day and night…24/7. The fellow human beings who are there for you when you need us and who passionately care about our profession and our patients. Of course, my plea went unheeded, so I joined a group of concerned physicians and traveled to Washington to read my letter in public on October 1st, 2009. This was the beginning of a national movement to return the leadership of our proud profession to those who understand what it is to care for individual human beings, one at a time, face to face, with dedication, compassion and excellence. That movement is growing. Continue reading

“MACRA/MIPS population health is the problem. Individual healthfreedom is the solution.”

Dear Congress & CMS,

The original stated goal of Medicare in 1965, to give healthcare to those at the end of life—when life expectancy was about 65 years—was credible and laudable. However forcing all citizens to participate in Medicare, and pay hard earned dollars into a system that they don’t want to use is not laudable, especially given the expanding government interference in Medicare which exponentially increases under MACRA/MIPS.

The original 18 page legislation declared:

“Nothing in this title shall be construed to authorize any federal officer or employee to exercise any supervision or control over the practice of medicine, or the manner in which medical services are provided, or over the selection, tenure, or compensation of any officer, or employee, or any institution, agency or person providing health care services….” Continue reading