One Efficient Step at a Time. Before we can dive into what is new with MACRA, the first thing is to take care of Today's Business. And today's Business is to get your 2016 Meaningful Use Attestations out of the way as efficiently as possible, so you can spend the time you need to absorb what you need to do for MIPS in 2017. Your boss already expects you to spend several weeks Attesting to Meaningful Use. But what if you could do all that work in just a day or two? You could use some of the time you... Continue reading

January 1 will not be as hard as you may think. In spite of all the pages of regulations, MIPS is not all that different, really. At least based on the Proposed Rule. Of course the new Final Rule with its thousands of pages may paint a different picture, by the time we absorb it all. But in general CMS does not originate new content in a Final Rule, that was not present in a Proposed Rule. Underneath all the MIPS language, we remain with Meaningful Use and PQRS, which we have been doing for years. Add in Clinical Practice... Continue reading

There is an unintended consequence, and perhaps a great windfall for those who pay attention Recently CMS Acting Director Andy Slavitt published a blog entry that gives a peek into CMS intent to provide flexibility for providers concerned over the aggressive timetable for MIPS Rollout in 2017. Although details will not be forthcoming until the Final Rule is published in November, all the articles, blogs and tweets have expressed appreciation for the ability to defer participation in MIPS. That "deferral" could take the form of either partial year participation for a reduced payment adjustment, or a partial data submission designed... Continue reading

I know that MIPS specifically excludes Medicaid, but what about my Meaningful Use Medicaid providers who also have Medicare Billings? Continue reading

Ok, so you are pretty sure you don't have an Advanced APM because your physicians don't accept Capitations. But what is the impact of being an ACO under MIPS? Continue reading

When CMS rewards EHR-based Quality reporting, what is the role of existing Quality Software? In the MIPS Final Rule, CMS points out the legislative direction received from congress to encourage adoption of the new QCDR participation. And in fact, CMS does so. But ... Continue reading

Regulations sometimes result in Unexpected Consequences. Here's one. First, recall two key background facts: MIPS Creates Competition. Your MIPS reimbursement depends on how you score against a broad peer group (i.e., All ACOs are compared against each other, and high scoring ACOs get the money that low scoring ACOs pay in penalties). Quality is the biggest differentiator. Your score on Quality contributes at least as much to your overall MIPS Score, as all other measures combined. In fact, it is likely be be more impactful than its 50% weighting factor implies. See our blog entry here for an explanation. Here... Continue reading

Your MIPS Composite Score will be more influenced by Quality Reporting than anything else. First of all, the Quality Category counts as much as all three other categories combined. Second, it will be the hardest to score well at. Here’s my thinking: Continue reading

Most of MIPS already exists. We already attest Meaningful Use and file our PQRS data. CMS calculates Value Based scores from claims and PQRS submissions, making VBM administratively simple. Continue reading

The intent of the comment and review process is to provide feedback to CMS that will avoid or mitigate unexpected consequences, indicate support for valuable concepts, and in general to improve our experience with this inevitable body of regulation when it goes effect in 2017. If you are concerned, join the small group who has voiced questions or "answerable" concerns with comment on the above link. It is easy and given the small volume of comments to date, you are likely to have an impact on the MIPS regulations! Continue reading

In the MIPS Proposed Rule, CMS says they are considering a requirement that all MIPS vendors be capable of submitting three of four MIPS Categories. Your current PQRS vendor does not do this yet, and the addition is a big deal. Continue reading

Some of the new Proposed Rule on MIPS is required reading. Here is a list as to what is optional, for whom Continue reading

Some providers will plan on achieving MIPS Compliance via their ACO. This is probably easier on the clinical staff, but not necessarily so for Administrators. Continue reading

Download a simpler version of the MIPS Proposed Rule in the Federal Register Continue reading

Physician Compare goes Public with Details What effort to put a best foot forward, and verify what gets published? At some (as yet unspecified) near future date, patients will be able to see detail quality reporting information on every physician in the country. This data will come from your PQRS / MIPS Quality submission, and other submitted MIPS data starting in 2017. For consumers of health care, this could be an exciting nationalized scoreboard by which to select providers of care. I think this probably drives a bit of extra work for most of us. The Physician Compare Website will... Continue reading

Under some circumstances, CMS could de-certify an in-place instance of CEHRT (Certified Electronic Health Records Technology) Continue reading

MIPS Proposed rule enforces higher level of physician data sharing standards Continue reading

Ok, if you don't read anything else in the new MIPS proposed rule, read the section (pages 36-41) requiring that we cooperate with CMS Surveillance and Direct Review of CEHRT. It proposes that CMS can demand on-site access to your EHR, so they can verify its functionality. In the process they will have unrestricted access to PHI, without patient authorization and without a BAA. This certainly is more intrusive than current CMS audits, and quite likely more time-consuming on part of the provider. If you feel strongly about this proposal, be sure to submit your comments to CMS before the... Continue reading

Am I more likely to be covered under APM, or MIPS? CMS plans that nany more of us will be paid under MIPS than under APM (starting in 2019 based on 2017 activity). APM participants: 30k - 90k MIPS participants: 687k - 746k Now I know something new. Page 17, Draft Proposed Rule Continue reading

It sounds too good to be true. So, take 90 seconds to view a brief video on how it is done. Then, for a modest one-time trial fee you can get all this years' Medicare Attestations done with automated batch submission. You provide only the spreadsheets and reports you already use, and in a day's time you will be submitting automated batch files to CMS for all your Medicare EP's. Current customers find savings of hundreds of hours by eliminating all Medicare data entry time. If you are not doing this, you are neglecting the opportunity to do your job... Continue reading

By Jim Tate, EMR Advocate Meaningful Use Audit Expert Twitter: @JimTate, eMail: Inquiry@meaningfuluseaudits.com Like all great rumors it started with a grain of truth. CMS acting administrator Andy Slavitt, made a statement (“… we’re now in the process of ending meaningful use”…) that took on a life of its own and soon the mole hill became a mountain. In the blink of an eye the word spread that the meaningful use program had died. My inbox was full of emails from providers and vendors asking if their prayers had come true. In a world of social media there was just... Continue reading

CMS issues specifications for streamlining Attestation for the 2015 reporting year. Continue reading

As we all struggle to react to the late-breaking Final Rule, and react quickly to analyzing readiness, it is hard to think forward to actually attesting. A month or more of tedium. Repetition. Loads of typing and tracking who is done. Here's a no-brainer alternative: Meaningful Use Monitor, a premier Meaningful Use tool used by over 5,000 EP's is offering a one-time promotional use of our Automated Batch Attestation, for a single price of only $625. No strings attached. It may sound too good to be true. But the firm really wants provider groups to experience eliminating an incredible amount... Continue reading

CMS encourages batch attestation, but does not provide very much support When we built the Batch Attestation add-on to our Meaningful Use system, we expected a lot of assistance from CMS. After all, they published it in the Federal Register, dedicated a page on their website to specifications and user manuals, and stated that it was expected to dramatically improve reporting burden. At least, so you might think. Truth is, there is not even a test site. Once you have built an initial file, you have to submit live EP data into the CMS production system to conduct your tests!... Continue reading

Want some pointers in creating your own Batch Attestation File for Meaningful Use? Here's the structure your files need to contain ... Eligible Providers can submit either a .csv or .xml file to CMS, containing homogeneous batches of Medicare-eligible providers, in less time than it takes to assemble documentation for even a single manual attestation. You will need to construct a multi-tiered file that contains some mandatory components, such as Physician Header, containing NPI and other information identifying the EP Additional Information, usually a response from CMS; Measure Attestations. The Measure Attestations contain the information you might expect, such as... Continue reading