How clinically focused technologies can help health leaders prepare for MACRA in 2018

Catherine Gorman-Klug, RN, MSN, CPM, Director Quality Service Line, Nuance

The dramatic transformation of Medicare Part B payments as part of Centers for Medicare and Medicaid Services’ (CMS) Quality Payment Program (QPP) is well underway. Unfortunately, there still are wide gaps in knowledge and understanding among healthcare leaders about the program.

At risk are hundreds of millions in payments to health systems nationwide. Yet, in a recent survey of healthcare finance executives, only 5% of respondents classified themselves as “completely ready” to meet this year’s QPP requirement. This is likely because the penalty environment has not been as severe in the past as it is expected to become in 2018.

The survey also uncovered that fewer than 25% respondents who reported they were “somewhat” or “very” confident in understanding CMS’ QPP requirements correctly answered 4% as the revenue at risk for eligible providers who choose not to participate in 2017; 60% of them either underestimated the amount or didn’t know.

Adding to the confusion is the Proposed Rule that CMS released in June. The Proposed Rule completely restructures the MACRA models as previously promulgated. CMS is anticipating a release of its Final Rule in mid-fall.

The stakes are high:

  • a potential 4% reduction in Medicare reimbursements starting in 2019 and
  • the release of public quality scores—which pose significant financial and reputational risks to clinicians with poor scores.

To the rescue: Clinical documentation improvement technologies

The findings from the survey underscore the important impact clinical documentation improvement (CDI) technologies and programs can have on avoiding penalties and revenue loss. Going forward, leaders will need to consider the following proactive steps:

  1. Know the Coding Impacts—Documentation will face much greater scrutiny under QPP. There will be a significant focus on ICD-10 specificity and clarity as well as Hierarchical Condition Categories, especially if considering Alternative Payment Models. It’s imperative to take a close look at coding and clinical documentation improvement groups and processes now—not at the end of the year.
  2. Adopt a CDI Improvement Program—Documentation for QPP requires much more specificity than previous physician quality reporting programs. A strong clinical documentation improvement program will be extremely important to navigate these challenges and optimize the accuracy and efficiency of physician documentation. Clinical documentation specialists will be a linchpin for identifying documentation issues and opportunities for improved data mapping.
  3. Obtain Real-Time Performance Data—Old performance data will no longer be acceptable under the new rules. Seek analytics solutions that can provide real-time report cards for the five clinician groups included in 2018 and those proposed for future years. Consider a data registry that offers instant feedback on reporting quality. When examining registry vendor options, look for registries that integrate with EHR and quality reporting solution.

Furthermore, as we head into 2018, it is important to keep in mind the following guidelines:

  1. Plan for CMS Deadlines—March 31, 2018 is the deadline to submit data for 2017. It is highly recommended to submit prior to the deadline. For a March 31 date, target Feb. 15 as the last date to submit.
  2. Consider Expanded Clinician Categories—There are five clinical roles in scope for 2017 and 2018, and CMS has discretion to add up to eight more clinical roles in year three (2019). Make sure to understand which organizational roles will be affected.

Taking the right steps now can ensure that the new regulations will be met. By planning well and addressing the current requirements, healthcare organizations can and will be prepared to address upcoming CMS reporting needs for 2018 and beyond.

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