From the Washington Office: An opportunity to address policymakers on the concerns of Fellows

On March 15, 2018, I had the opportunity to present on behalf of the ACS at a roundtable discussion on Capitol Hill to members of the House Ways and Means Committee on the topic of Medicare red tape relief

The roundtable provided members of this key committee of jurisdiction over Medicare policy the opportunity to hear from representatives from a variety of health care professional organizations on how Congress can improve Medicare to work more effectively and efficiently for both patients and providers. Each group was allotted just three minutes for their presentation. A summary of my presentation is included below:
 

E/M Documentation Guidelines

The ACS has significant concerns regarding Evaluation and Management (E/M) Documentation Guidelines. Though CMS created the E/M documentation guidelines 23 years ago with the laudable goal of adding structure to the various levels of E/M services, and in an effort to create a sense of equivalency of E/M services across the multitude of specialties, ACS believes the time has come to re-examine and revise these guidelines to be more appropriate in the modern digital information era.

US House Ways and Means Committee

Physicians first created the medical record with the primary goal of providing an accurate, chronologic record of patient care. Over time, CMS and payers have increasingly utilized the medical record for purposes of determining payment for services. In addition, because the E/M guidelines were introduced when medical records were primarily paper-based, unintended consequences have been amplified resulting in a medical record that is bloated with repetitive and redundant information. Because patient notes in the EHR contain so much duplicative data, it is often difficult to find the relevant information. Much of the necessity for creating these duplicative notes is borne out of the requirements to document information supporting the level of E/M service and the associated payment.

Again, the primary goal of all medical record documentation is to provide an accurate, chronologic record of patient care. That said, the medical record also serves other important goals including communication between providers, data exchange to facilitate clinical decisions, and a legal document. The payment-focused E/M documentation guidelines do not serve any of these objectives.

There must be some level of trust of the provider by the payers. Physicians should have the ability to meet the primary goal of the medical record without being required to repeatedly enter the same information. If a family history is recorded on Monday, there should be no requirement to re-record it on Thursday unless something cogent changes in the interim. ACS believes that documentation should focus on the minimum data elements needed to establish an accurate chronologic record of patient care.

The ACS is prepared to assist in an effort to explore ways to revise the current paper-based E/M documentation guidelines such that they more efficiently and accurately document patient care information in the modern digital era.

 

Meaningful Measurement of Surgical Quality

I also addressed concerns relative to the meaningful measurement of surgical quality. Despite having expended significant human and financial resources toward helping Fellows succeed in MIPS, the College is becoming increasingly concerned that MIPS is not actually measuring surgical quality, and therefore, is not a quality program for surgery and serves primarily as a payment program.

As evidence, the most recent quality metric data available (from the 2015 Physician Quality Reporting System) show that many of the CMS quality measures reported by surgeons have little to do with improving the quality of the actual surgical care provided to patients. For general surgeons, the two most commonly reported measures were the documentation of a patient’s medications in the medical record and tobacco use screening. While no one would deny the importance of either of these activities, neither is of much real value in the effort to measure the quality of surgical care provided. In another, perhaps even more illustrative example, one of the most common quality measures reported by urologists was inquiring of their patients whether they had received a pneumovax. This obviously has little to do with why one would see an urologist, much less the quality of care provided.

As an organization, the ACS and its members are absolutely dedicated to improving the quality of care they provide to their patients. However, the quality measures forming the basis of the assessment of their care must first be relevant to the surgical care they provide, and second be achievable. Fellows are increasingly expressing concerns about the burdens imposed by the Quality component of MIPS and believe their efforts to participate do little to meaningfully measure the quality of surgical care they provide. I asked that the Ways and Means Committee hold a hearing specifically addressing issues relative to the Quality component of MIPS.
 

 

Standardizing Electronic Prior Authorization for Safe Prescribing Act

I expressed ACS’ support for the Standardizing Electronic Prior Authorization for Safe Prescribing Act, H.R. 4841, which would allow for electronic prior authorization under Medicare Part D and allow for the creation of technical standards for the electronic transmission of prior authorization. While the College believes this legislation is a good first step for electronic prior authorization, I asked that the scope of the legislation be expanded to include all medical services, supplies, and prescription drugs covered by the Medicare program, and also requested prior authorization policies be standardized across all insurers and that prior authorization requests, decisions, and appeals processes be automated through uniform electronic transaction portals for all services and supplies.

As evidence, I provided data from a 2017 ACS survey of nearly 300 surgeons and their staff, which indicated that, on average, a medical practice receives approximately 37 prior authorization requests per provider, per week. Action on these requests requires 25 hours to complete. This exorbitant expenditure of time and resources required for prior authorization is largely due to a lack of automated prior authorization processes that integrate with current electronic health record systems. The ACS is committed to working with the bill’s sponsors and the Ways and Means Committee toward a goal of swift passage.

Questions from and discussion with members of the Ways and Means Committee were truncated because of votes on the House floor. We look forward to continuing the dialogue in the coming weeks when the roundtable is reconvened.

Until next month ….

On March 15, 2018, I had the opportunity to present on behalf of the ACS at a roundtable discussion on Capitol Hill to members of the House Ways and Means Committee on the topic of Medicare red tape relief

The roundtable provided members of this key committee of jurisdiction over Medicare policy the opportunity to hear from representatives from a variety of health care professional organizations on how Congress can improve Medicare to work more effectively and efficiently for both patients and providers. Each group was allotted just three minutes for their presentation. A summary of my presentation is included below:
 

E/M Documentation Guidelines

The ACS has significant concerns regarding Evaluation and Management (E/M) Documentation Guidelines. Though CMS created the E/M documentation guidelines 23 years ago with the laudable goal of adding structure to the various levels of E/M services, and in an effort to create a sense of equivalency of E/M services across the multitude of specialties, ACS believes the time has come to re-examine and revise these guidelines to be more appropriate in the modern digital information era.

US House Ways and Means Committee

Physicians first created the medical record with the primary goal of providing an accurate, chronologic record of patient care. Over time, CMS and payers have increasingly utilized the medical record for purposes of determining payment for services. In addition, because the E/M guidelines were introduced when medical records were primarily paper-based, unintended consequences have been amplified resulting in a medical record that is bloated with repetitive and redundant information. Because patient notes in the EHR contain so much duplicative data, it is often difficult to find the relevant information. Much of the necessity for creating these duplicative notes is borne out of the requirements to document information supporting the level of E/M service and the associated payment.

Again, the primary goal of all medical record documentation is to provide an accurate, chronologic record of patient care. That said, the medical record also serves other important goals including communication between providers, data exchange to facilitate clinical decisions, and a legal document. The payment-focused E/M documentation guidelines do not serve any of these objectives.

There must be some level of trust of the provider by the payers. Physicians should have the ability to meet the primary goal of the medical record without being required to repeatedly enter the same information. If a family history is recorded on Monday, there should be no requirement to re-record it on Thursday unless something cogent changes in the interim. ACS believes that documentation should focus on the minimum data elements needed to establish an accurate chronologic record of patient care.

The ACS is prepared to assist in an effort to explore ways to revise the current paper-based E/M documentation guidelines such that they more efficiently and accurately document patient care information in the modern digital era.

 

Meaningful Measurement of Surgical Quality

I also addressed concerns relative to the meaningful measurement of surgical quality. Despite having expended significant human and financial resources toward helping Fellows succeed in MIPS, the College is becoming increasingly concerned that MIPS is not actually measuring surgical quality, and therefore, is not a quality program for surgery and serves primarily as a payment program.

As evidence, the most recent quality metric data available (from the 2015 Physician Quality Reporting System) show that many of the CMS quality measures reported by surgeons have little to do with improving the quality of the actual surgical care provided to patients. For general surgeons, the two most commonly reported measures were the documentation of a patient’s medications in the medical record and tobacco use screening. While no one would deny the importance of either of these activities, neither is of much real value in the effort to measure the quality of surgical care provided. In another, perhaps even more illustrative example, one of the most common quality measures reported by urologists was inquiring of their patients whether they had received a pneumovax. This obviously has little to do with why one would see an urologist, much less the quality of care provided.

As an organization, the ACS and its members are absolutely dedicated to improving the quality of care they provide to their patients. However, the quality measures forming the basis of the assessment of their care must first be relevant to the surgical care they provide, and second be achievable. Fellows are increasingly expressing concerns about the burdens imposed by the Quality component of MIPS and believe their efforts to participate do little to meaningfully measure the quality of surgical care they provide. I asked that the Ways and Means Committee hold a hearing specifically addressing issues relative to the Quality component of MIPS.
 

 

Standardizing Electronic Prior Authorization for Safe Prescribing Act

I expressed ACS’ support for the Standardizing Electronic Prior Authorization for Safe Prescribing Act, H.R. 4841, which would allow for electronic prior authorization under Medicare Part D and allow for the creation of technical standards for the electronic transmission of prior authorization. While the College believes this legislation is a good first step for electronic prior authorization, I asked that the scope of the legislation be expanded to include all medical services, supplies, and prescription drugs covered by the Medicare program, and also requested prior authorization policies be standardized across all insurers and that prior authorization requests, decisions, and appeals processes be automated through uniform electronic transaction portals for all services and supplies.

As evidence, I provided data from a 2017 ACS survey of nearly 300 surgeons and their staff, which indicated that, on average, a medical practice receives approximately 37 prior authorization requests per provider, per week. Action on these requests requires 25 hours to complete. This exorbitant expenditure of time and resources required for prior authorization is largely due to a lack of automated prior authorization processes that integrate with current electronic health record systems. The ACS is committed to working with the bill’s sponsors and the Ways and Means Committee toward a goal of swift passage.

Questions from and discussion with members of the Ways and Means Committee were truncated because of votes on the House floor. We look forward to continuing the dialogue in the coming weeks when the roundtable is reconvened.

Until next month ….

On March 15, 2018, I had the opportunity to present on behalf of the ACS at a roundtable discussion on Capitol Hill to members of the House Ways and Means Committee on the topic of Medicare red tape relief

The roundtable provided members of this key committee of jurisdiction over Medicare policy the opportunity to hear from representatives from a variety of health care professional organizations on how Congress can improve Medicare to work more effectively and efficiently for both patients and providers. Each group was allotted just three minutes for their presentation. A summary of my presentation is included below:
 

E/M Documentation Guidelines

The ACS has significant concerns regarding Evaluation and Management (E/M) Documentation Guidelines. Though CMS created the E/M documentation guidelines 23 years ago with the laudable goal of adding structure to the various levels of E/M services, and in an effort to create a sense of equivalency of E/M services across the multitude of specialties, ACS believes the time has come to re-examine and revise these guidelines to be more appropriate in the modern digital information era.

US House Ways and Means Committee

Physicians first created the medical record with the primary goal of providing an accurate, chronologic record of patient care. Over time, CMS and payers have increasingly utilized the medical record for purposes of determining payment for services. In addition, because the E/M guidelines were introduced when medical records were primarily paper-based, unintended consequences have been amplified resulting in a medical record that is bloated with repetitive and redundant information. Because patient notes in the EHR contain so much duplicative data, it is often difficult to find the relevant information. Much of the necessity for creating these duplicative notes is borne out of the requirements to document information supporting the level of E/M service and the associated payment.

Again, the primary goal of all medical record documentation is to provide an accurate, chronologic record of patient care. That said, the medical record also serves other important goals including communication between providers, data exchange to facilitate clinical decisions, and a legal document. The payment-focused E/M documentation guidelines do not serve any of these objectives.

There must be some level of trust of the provider by the payers. Physicians should have the ability to meet the primary goal of the medical record without being required to repeatedly enter the same information. If a family history is recorded on Monday, there should be no requirement to re-record it on Thursday unless something cogent changes in the interim. ACS believes that documentation should focus on the minimum data elements needed to establish an accurate chronologic record of patient care.

The ACS is prepared to assist in an effort to explore ways to revise the current paper-based E/M documentation guidelines such that they more efficiently and accurately document patient care information in the modern digital era.

 

Meaningful Measurement of Surgical Quality

I also addressed concerns relative to the meaningful measurement of surgical quality. Despite having expended significant human and financial resources toward helping Fellows succeed in MIPS, the College is becoming increasingly concerned that MIPS is not actually measuring surgical quality, and therefore, is not a quality program for surgery and serves primarily as a payment program.

As evidence, the most recent quality metric data available (from the 2015 Physician Quality Reporting System) show that many of the CMS quality measures reported by surgeons have little to do with improving the quality of the actual surgical care provided to patients. For general surgeons, the two most commonly reported measures were the documentation of a patient’s medications in the medical record and tobacco use screening. While no one would deny the importance of either of these activities, neither is of much real value in the effort to measure the quality of surgical care provided. In another, perhaps even more illustrative example, one of the most common quality measures reported by urologists was inquiring of their patients whether they had received a pneumovax. This obviously has little to do with why one would see an urologist, much less the quality of care provided.

As an organization, the ACS and its members are absolutely dedicated to improving the quality of care they provide to their patients. However, the quality measures forming the basis of the assessment of their care must first be relevant to the surgical care they provide, and second be achievable. Fellows are increasingly expressing concerns about the burdens imposed by the Quality component of MIPS and believe their efforts to participate do little to meaningfully measure the quality of surgical care they provide. I asked that the Ways and Means Committee hold a hearing specifically addressing issues relative to the Quality component of MIPS.
 

 

Standardizing Electronic Prior Authorization for Safe Prescribing Act

I expressed ACS’ support for the Standardizing Electronic Prior Authorization for Safe Prescribing Act, H.R. 4841, which would allow for electronic prior authorization under Medicare Part D and allow for the creation of technical standards for the electronic transmission of prior authorization. While the College believes this legislation is a good first step for electronic prior authorization, I asked that the scope of the legislation be expanded to include all medical services, supplies, and prescription drugs covered by the Medicare program, and also requested prior authorization policies be standardized across all insurers and that prior authorization requests, decisions, and appeals processes be automated through uniform electronic transaction portals for all services and supplies.

As evidence, I provided data from a 2017 ACS survey of nearly 300 surgeons and their staff, which indicated that, on average, a medical practice receives approximately 37 prior authorization requests per provider, per week. Action on these requests requires 25 hours to complete. This exorbitant expenditure of time and resources required for prior authorization is largely due to a lack of automated prior authorization processes that integrate with current electronic health record systems. The ACS is committed to working with the bill’s sponsors and the Ways and Means Committee toward a goal of swift passage.

Questions from and discussion with members of the Ways and Means Committee were truncated because of votes on the House floor. We look forward to continuing the dialogue in the coming weeks when the roundtable is reconvened.

Until next month ….