What to expect from MACRA: The early years

MACRA legislation passed in April 2015. When the initial version of the rule came down, the industry collectively braced for declining revenues, the avalanche of administrative paperwork and the increase in overhead costs that would be required to comply.

When the final rule was issued in October 2016, the tempered requirements seemed to point toward fewer projected negative payment adjustments in 2019, the target year for MACRA’s first Quality Payment Program distributions, and the tension subsided a little.

Even with the new allowances in reporting and threshold scores, the MACRA structure makes clear that there’s an abundance of work to be done, especially around efforts to promote care coordination and communication.

Year 1: 2017-2018

Now that we’re already into 2017, the first official reporting year, tensions are rising again because, even though most physicians acknowledge they are going to participate, the majority have not yet plotted their course or defined a compliance strategy.

And if you’re in the group that hasn’t figured it all out yet, the good news is you’re not alone.

According to a recent poll conducted by The Health Management Academy, almost half of the physician and practice leaders who participated are not moving very quickly toward adopting value-based payment models. In fact, only 4% claimed to be moving “very quickly” while almost 40% admitted to moving “very slowly” toward value-based care.

Somewhat surprisingly, the same is true even for large hospital systems. These organizations are perceived to be the driving force, the ones moving the fastest toward the end goal of value-based care, and yet, per a similar poll, few of the large systems are moving very quickly.

Only 8% of large hospital systems polled are moving swiftly toward implementing value-based payment models. – The Health Management Academy, 2017

The Quality Payment Program, however, is going to be the catalyst for healthcare organizations, both large and small, moving more aggressively toward these models in the next couple of years.

The MACRA structure and how you fit in

By now, you know that reimbursements are going to be variable based on performance, even if you’re still practicing in a fee-for-service structure and, like most, have not yet begun practicing in the more advanced tracks.

There are four participation categories, which fall underneath two broad tracks—the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Model (APM) track.

The four MACRA Quality Payment Program participation categories. – The Health Management Academy, 2017

The two categories in the middle of the chart are bridge areas, and won’t apply to many providers right now, but they can be considered as stepping stones from MIPS to the Advanced APM track.

The MIPS track equates to fee‑for‑service, and most physicians will, at least initially, fall into this track. They’ll balance their steps toward embracing more downside risk by continuing to practice fee-for-service medicine, and so they must prepare to report performance metrics and have payments adjusted based on those metrics in 2019.

On the other end of the spectrum is the Advanced APM track. To reach “Advanced APM Qualifying Clinician” status, physicians must engage significantly in certain downside risk-bearing payment models. In this track, participating physicians will enjoy fewer reporting requirements and more financial incentives, while still being held accountable for delivering high-value care. The only way to sustain a profitable practice in this track is to eliminate wasteful workflows that result in inefficient and unreliable communication processes among all members of the broader care team, even if they are not directly affiliated with your practice.

Year 2: 2018-2019

In the first months of 2018, physicians practicing in the MIPS track—again, that will be most of you—will be required to report metrics in three performance categories based on at least 90 consecutive days of work. This should come as more good news, because if you haven’t started measuring yet, or you’re not impressed by your initial metrics, you still have time to pivot before the data is due in early 2018.

CMS will use that data to give each physician a composite score, which will determine the payment adjustment he or she receives in 2019.

The Quality Payment Program’s initially proposed rule was accompanied by disheartening projections in terms of payment adjustments, particularly for solo physicians and small practices. While the finalized October 2016-issued rule basically guaranteed that all physicians who submit any performance data will receive at least a neutral payment adjustment, physicians are still bracing themselves for less-than-average profit margins.

As MIPS is largely a budget-neutral program, less risk equals less reward. Since fewer physicians will be subject to negative payment adjustments in 2019 (see Image 3 below), fewer dollars will be available to distribute to those who perform well.

Only 20%—versus 87%—of physicians in smaller practices are projected to experience negative payment adjustments in 2019. – The Health Management Academy, 2017

Simply put, the best way to ensure your adjustment is as high as possible is to garner a high composite score.

Effectively coordinating care with your patients’ broader care teams as accurately and efficiently as possible to reduce waste and unnecessary overhead costs is a good first step toward achieving high scores in all four MIPS performance categories.

Back to the present

One of the goals of MACRA is to drive the costs out of treatment while still providing high-value care. Physicians will be in a much better position to deliver this dichotomy, and advance to a more rewarding reporting track, when the barriers to real-time care coordination have been broken down.

Seamless care team communication and collaboration among interdisciplinary, and often disparate, providers will be a foundation on which you can lay the groundwork for improved care coordination, which leads to less waste, improved efficiencies, and ultimately better outcomes, all of which underlie value-based care and the successful reduction of healthcare costs.

Source: “Making Sense of MACRA” webinar. The Health Management Academy and PerfectServe. March 2017. 

Watch the full webinar to learn even more about MACRA and how it applies to your practice.

Safeguarding security: 4 tactics for secure clinical communication and collaboration

I had the honor of speaking at the 2016 Becker’s Hospital Review Annual CIO/HIT + Revenue Cycle Summit, discussing the elements needed to truly secure clinical communications with some of the best minds in the healthcare world. With a number of recent high profile news stories announcing ransomware attacks in hospitals and health systems, security and the ability to secure clinical information is top of mind for many.

Those who oversee organizational data and IT systems recognize the importance of securing communication channels containing ePHI as they build a unified communications strategy. While security and regulatory mandates are essential elements of a clinical communication strategy, to create a truly successful strategy, the needs of those who provide care: physicians, nurses, therapists and others on the care team – in any setting – at any time – must be addressed flawlessly and securely.

To do so, there a few tactics to keep in mind:

Understand what the HIPAA Security Rule actually states – There’s been a lot of confusion in the industry when it comes to HIPAA compliance and communication. I often notice that many organizations think this is all about secure text messaging, which is incomplete. The Security Rule never speaks to a particular technology or communications modality, application or device. It is technology neutral.

HIPAA compliance is about the system of physical, administrative and technical safeguards that your organization puts in place to to ensure the confidentiality, integrity and availability of all ePHI it creates, receives, maintains or transmits. Because of this, there is no such thing as a HIPAA-compliant app.

Understand care team dynamics – Care team members are mobile and they employ workflows to receive communication based upon situational variables such as origin, purpose, urgency, day, time, call schedules, patient and more. The variables determine who should be contacted and how to do so for every communications event.

For this reason, third parties (hospital switchboards and answering services) and disparate technologies are used in organizations’ clinical communication processes. Understanding this variety of technologies and actors is key to accurately assessing your organization’s compliance risk. And, coming up with strategies to effectively address that risk is key.

Secure text messaging is essential, but it’s not sufficient – While secure messaging is an essential component of your overall strategy, it’s not sufficient because:

  1. it requires the sender to always know who it is they need to reach—by name.
  2. it requires the recipient to always be available to other care team members 24/7.

These requirements are inconsistent with the complexity inherent in communication workflows that enable time-sensitive care delivery processes, because they don’t address the situational variables I described above.

Secure messaging is only one piece of what should be a much larger communications strategy—one that should address clinician workflows and multi-modal communications channels for all care team members.

Your goal should be to enable more effective care team collaboration – Organizations often focus on achieving HIPAA-compliance. This is a flawed objective. The focus should be on achieving more effective care team collaboration. If this is done effectively, achieving HIPAA-compliance will come along for the ride.

Six essential capabilities – An effective secure clinical communications and collaboration strategy will include the following six elements.

  1. It will facilitate communication-driven workflows that enable time-sensitive care delivery processes. An example of a communications-driven workflow is stroke diagnosis and treatment. When a patient with stroke symptoms presents in the ED, one of the first things the ED physician does is initiate a communications workflow to contact the neurologist covering that ED at that moment in time, while simultaneously notifying and mobilizing a stroke team to complete a CT scan to determine if it is safe to administer tPA, the drug that arrests the stroke. Time is critical. Healthcare is chock full of these kinds of workflows, executed every day in every hospital by the hundreds and thousands.
  1. It will provide technology that automatically identifies and provides an immediate connection to the right care team member for any given clinical situation—this is nursing’s greatest need! Your strategy should be to bypass third parties and eliminate all the manual tools and processes used to figure out who’s in what role right now given the situation at hand. Ignoring this need means you won’t achieve adoption, which means your organization will still be at risk.
  1. It should extend beyond any department and the four walls of the hospital. It should enable cross-organizational communication workflows. This is increasingly important under value-based care where care team members must collaborate across interdependent organizations to deliver better care.
  1. It should secure the creation, transmission and access of ePHI across all communication modalities—not just text messaging. Enough said!
  1. It should integrate with your other clinical systems to leverage the data within those systems to facilitate new communication workflows. This is key to enabling “real-time healthcare.”
  1. It should provide analytics to monitor your communication processes and continuously improve those processes over time.

With these capabilities in place, secure clinical communication simply becomes another positive result of implementing a broader care team collaboration strategy, designed to address clinical efficiency and improve patient care delivery.