The Centers for Medicare & Medicaid Services (CMS) today proposed changes that the agency believes will “fundamentally improve the nation’s healthcare system and help restore the doctor-patient relationship by empowering clinicians to use their electronic health records (EHRs) to document clinically meaningful information.”
These changes, according to CMS, would increase the amount of time that doctors and other clinicians can spend with their patients by reducing the burden of paperwork that clinicians face when billing Medicare. The proposals, part of the Physician Fee Schedule (PFS) and the Quality Payment Program (QPP), would also modernize Medicare payment policies to promote access to virtual care, CMS said in a July 12 announcement.
Such changes would establish Medicare payment for when beneficiaries connect with their doctor virtually using telemedicine to determine whether they need an in-person visit. Additionally, the QPP proposal, set to take place in year three of the program, in 2019, would make changes to quality reporting requirements to focus on measures that most significantly impact health outcomes, CMS said.
The proposed changes would also encourage information sharing among healthcare providers electronically. And, the QPP proposal would make changes to the Merit-based Incentive Payment System (MIPS) “Promoting Interoperability” performance category to support greater EHR interoperability and patient access to their health information, as well as to align this clinician program with the proposed new “Promoting Interoperability” program for hospitals, according to the announcement.
“Today’s proposals deliver on the pledge to put patients over paperwork by enabling doctors to spend more time with their patients,” said CMS Administrator Seema Verma. “Physicians tell us they continue to struggle with excessive regulatory requirements and unnecessary paperwork that steal time from patient care. This Administration has listened and is taking action. The proposed changes to the Physician Fee Schedule and Quality Payment Program address those problems head-on, by streamlining documentation requirements to focus on patient care and by modernizing payment policies so seniors and others covered by Medicare can take advantage of the latest technologies to get the quality care they need.”
E&M Documentation Reforms
In the announcement, officials from CMS and the Office of the National Coordinator for Health Information Technology (ONC) said have heard from stakeholders that CMS’ extensive documentation requirements for Evaluation and Management (E&M) codes have resulted in unintended consequences.
To meet these documentation requirements, providers have to create medical records that are a collection of predefined templates and boilerplate text for billing purposes, in many cases reflecting very little about the patients’ actual medical care or story, according to federal officials.
At HIMSS18 in Las Vegas, Verma spoke about the need to “overhaul E&M codes”—the requirements under Medicare around documenting evaluation and management codes in the patient record, on the part of physicians—“to make it easier to document. We will be updating and streamlining them, so doctors can spend less time using their EHRs and more time seeing patients,” she said.
As such, new provisions in the proposed CY 2019 Physician Fee Scheduleؙ would help to “free” EHRs, such as:
- to allow practitioners to choose to document office/outpatient E/M visits using medical decision-making or time instead of applying the current 1995 or 1997 E/M documentation guidelines, or alternatively practitioners could continue using the current framework;
- to expand current options by allowing practitioners to use time as the governing factor in selecting visit level and documenting the E/M visit, regardless of whether counseling or care coordination dominate the visit;
- to expand current options regarding the documentation of history and exam, to allow practitioners to focus their documentation on what has changed since the last visit or on pertinent items that have not changed, rather than re-documenting information, provided they review and update the previous information; and
- to allow practitioners to simply review and verify certain information in the medical record that is entered by ancillary staff or the beneficiary, rather than re-entering it.
CMS is estimating that if these proposals were finalized, clinicians would see a significant increase in productivity. In fact, removing unnecessary paperwork requirements through the proposal would save individual clinicians an estimated 51 hours per year if 40 percent of their patients are in Medicare. Changes in the QPP proposal would collectively save clinicians an estimated 29,305 hours and approximately $2.6 million in reduced administrative costs in CY 2019, CMS predicted.
Reimbursing for Virtual Care
As it relates to virtual care, CMS officials said that provisions in the proposed CY 2019 Physician Fee Schedule would support access to care using telecommunications technology by:
- Paying clinicians for virtual check-ins – brief, non-face-to-face appointments via communications technology;
- Paying clinicians for evaluation of patient-submitted photos; and
- Expanding Medicare-covered telehealth services to include prolonged preventive services.
Changes to MIPS
Finally, regarding year three of MIPS, CMS is proposing to:
- Remove MIPS process-based quality measures that clinicians have said are low-value or low-priority, in order to focus on meaningful measures that have a greater impact on health outcomes; and
- Overhaul the MIPS “Promoting Interoperability” (formerly called Advancing Care Information) performance category to support greater EHR interoperability and patient access to their health information, as well as to align this performance category for clinicians with the proposed new Promoting Interoperability Program for hospitals.
- For the Promoting Interoperability performance category, CMS is requiring that MIPS-eligible clinicians to use 2015 Edition certified EHR technology beginning with the 2019 MIPS performance period.
In a statement, HHS (Health & Human Services) Secretary Alex Azar, added, “Today’s reforms proposed by CMS bring us one step closer to a modern healthcare system that delivers better care for Americans at a lower cost. Such a system requires empowering American patients by giving them price and quality transparency and control over their own interoperable health records, goals supported by CMS’s proposals. These proposals will also advance the successful Medicare Advantage program and accomplish a historic regulatory rollback to help physicians put patients over paperwork. Further, today’s proposed reforms to how CMS pays for medicine demonstrate the commitment of HHS to implementing President Trump’s blueprint for lowering drug prices. The ambitious reforms proposed by CMS under Administrator Verma will help deliver on two HHS priorities: creating a value-based healthcare system for the 21st century and making prescription drugs more affordable.”