Editor’s Note: Dr. Maddux originally prepared this article in early December as a blog post for Acumen Physician Solutions. We asked her to modify the post to forecast how the 12 days of Christmas, or nephrology IT, might fare over the next 12 months.
Twelve Drummers Drumming
Meaningful Use (MU) had a constant drum beat at the beginning of 2014, with MU stage 1, 2 and 3 details in the news. MU2 changes in 2014 included required reporting for 9 of 64 Clinical Quality Measures (CQMs) covering 3 of the 6 National Quality Strategy (NQS) domains and the overlap with the Physician Quality Reporting System for one reporting year. MU2 hit the brakes in May 2014 with the notice of proposed rulemaking (NPRM) that became a final rule delaying MU2 required reporting to 2016 and MU3 reporting to 2017.
What is in store for Meaningful Use in 2015? Expect to be required to implement and use a 2014 Edition CEHRT for MU reporting and be prepared to meet the more strenuous reporting requirements of MU Stage 2. With any luck, HR 5481 will be passed and MU will only occupy three months of 2015.
Eleven Pipers Piping
The “Doc Fix” or repeal of the Sustainable Growth Rate and Medicare Provider Modernization Act was a familiar tune from Congress this past February. Despite two options for a permanent SGR fix, Congress did not act. Physicians received another patch to maintain the status quo through March 2015 and avoid the more than 24% physician pay cut in Medicare reimbursement.
In December the American Society of Nephrology (ASN) joined other health care organizations in pleading with Congress for an end to the “flawed, unpredictable Medicare physician payment system.” Despite this organized effort it seems unlikely that we will see legislation that creates a sustainable Medicare physician payment plan. The March 2015 midnight deadline looms (see RPA public policy director Rob Blaser’s commentary on the SGR in this section).
ICD 10 continues to stay a leap ahead. Last February, an Acumen blog post addressed preparing for ICD 10 transition on September 30, noting the U.S. is behind other industrialized countries that are already using ICD 10. On March 31, in a fit of March Madness, the Senate passed H.R. 4302, the Protecting Access to Medicare Act of 2014, which delayed ICD 10 implementation “until at least October 1, 2015.” ICD 9 has been in use since 1978 and the World Health Organization will release ICD 11 in 2017.
While the AMA has been a long-time ICD 10 opponent, considering it an unfunded Federal mandate with significant cost for small practices, the ICD 10 delay to October 2015 has been costly for large health care organizations and hospitals that are ready to make the coding change.
Nine Ladies Dancing
The Value-Based Payment Modifier (VM) has been discussed this year as a “rock our world” change in health care. Large practices with 100 or more providers are already dancing with performance surveillance in 2013 followed by VM application to Medicare payments in 2015. Practices with 10 or more providers were observed during 2014 and will step onto the dance floor in 2016, and everyone’s rocking by 2017.
Perhaps the most important feature of this program is the penalty for not successfully participating in the 2015 PQRS program. Depending on practice size, if you fail to successfully report PQRS in one flavor or another in 2015, your practice will face a 2-4% VM penalty to Medicare Part B payments in 2017.
VM brings us right to the daily work of the PQRS: the eight-year, pay-for-reporting, old-brown-milk-cow CMS program. 2014 was the last year for the PQRS reporting incentive. Unsuccessful 2015 PQRS reporting will result in a 2% PQRS-related reduction in Medicare Part B payments in addition to VM-related payment reductions. PQRS is a program that reports on process metrics not outcome metrics, so it has been a stepping stone to the new pay-for-performance programs.
CMS is maintaining the PQRS option to report via a measures group for at least 20 patients (11 being Medicare Part B patients). In the past the CKD measures group has been a nephrology favorite, but the 2015 final rule includes 6 CKD measures:
- preventive care and screening for tobacco use and cessation intervention
- documentation of current medications in the medical record
- adult kidney disease: blood pressure management
- adult preventive care and screening: Influenza immunization
- Advanced care plans/surrogate decision making documentation
- adult kidney disease: lipid profile laboratory testing.
An EHR Security Risk Analysis is an important part of Meaningful Use. Use of 2014 CEHRT does not meet the requirement for compliance attestation with the HIPAA Security Rule. If you are in the 5% of practices chosen for a pre- or post-payment MU audit, then you will need to submit a security risk analysis.
The 2006 HIPAA Security Rule requires all health care providers to conduct or review a security risk analysis. When you attest for Stage 1 or 2, you are attesting to the fact that your practice is in compliance with this piece of the 2006 HIPAA Security Rule.
In 2015, data security will continue to be a Health IT hot button. You must ensure that your practice is compliant with all expected data security measures.
The year 2014 was filled with the golden eggs of personal health devices that are enriching individual health data, enhancing patient engagement, and initiating continuous health monitoring. The Federal Health IT Strategic Plan for 2015-2020 lists telehealth and mobile health technologies and services as strategies to improve health care quality. Expect Federal policies, including incentive payments that will support use of telehealth and mobile and home devices that generate patient health and wellness data. Hold onto your Fitbit––it’s just the beginning.
Five Gold Rings
Patient portals may be the golden ring of patient engagement. A functional patient portal that provides secure electronic messaging with patients was a 2014 and now 2015 MU 2 requirement for Eligible Providers (EPs). Vendors with 2014 CEHRT will have patient portal capability.
The five-year ONCHIT strategy will force Health IT at the practice level to not only meet the continuity of care needs of the providers, but also to allow patients to interact with their health data. Initially that will be accomplished with patient portals, but in the future there is likely to be a central repository of patient-centered data with access authorization to all or part of the data controlled by the patient.
Four Calling Birds
In addition to understanding Meaningful Use (MU) everyone needs to be knowledgeable about MU audits. There are 2 types of audits: post payment or prepayment. A post-payment audit occurs after you receive your check from CMS (if you fail, you get to pay them back) and a prepayment audit occurs shortly after you attest, but before you are paid (if you fail, you do not get paid). The audit itself is conducted in the same fashion whether it occurs before or after you receive your meaningful use incentive.
If the government comes to your practice calling for a Meaningful Use audit, you want to be prepared. Each year approximately 5% of practices participating in Meaningful Use will experience an audit.
Three French Hens
The rare French Hens are a reminder of the foraging we will be doing for nephrologists in the coming years, as the number of nephrology fellows continues to dwindle. During Renal Week in Philadelphia last November, the American Society of Nephrology reported that 51% of nephrology training programs and 32% of fellowship positions were NOT filled in the recent 2014–2015 specialty match. That means 120 nephrology fellowship positions are unfilled for the upcoming year. Nephrology fellows are as rare as hen’s teeth.
Two Turtle Doves
We have written before in posts for the Acumen blog about the two parts of the Quality and Resource Use Report (QRUR): quality and cost. The QRUR has your practice quality data across the PQRS measures and cost data across Medicare Part A and Part B claims for patients attributed to your practice. In the end, the QRUR provides a glimpse into the future of VM for your practice.
The QRUR is the start of public visibility of Federal health data sets. While ensuring patient privacy, the government is committed to increasing access to health care data to support research, innovation and to improve patient outcomes.
A Partridge in a Pear Tree
Health IT News published a list of “Health IT Change Agents” for 2014 and artist Regina Holliday is on this list for her creation of The Walking Gallery, the cornerstone of her work for patient advocacy. Check out Regina’s story on her blog at reginaholliday.blogspot.com. For a reminder of why we come to work every day, watch a wonderful short video about The Walking Gallery at this link.
2015: Happy New Year!
Health care Big Data will lead the health care revolution. Future Health IT will allow practicing physicians to utilize point of care clinical decision support that recommends treatments based on individual genomic data and continuous home monitoring devices as well as traditional signs and symptoms. Imagine a world where digital epidemiology generated from personal HIT, social media IT, and health registries identifies communities at risk for infectious diseases or in need of better resources to prevent chronic diseases before we diagnose a single patient.
Here’s to a bright New Year with better health, for you and your patients brought to you in part by Health IT.