The Centers for Medicare and Medicaid Services (CMS) included several ideas for easing physician administrative burdens in its proposals for the second year of the Medicare Quality Payment Program (QPP) and the 2018 Medicare Physician Fee Schedule, but there is still more that can be done to provide meaningful regulatory relief.
The AMA is tracking these measures in a 2017 regulatory relief dashboard. The tool details where the AMA suggestions and CMS proposed rules are in agreement as well as the AMA’s “top asks” for regulation flexibility and burden reduction. It also cites the list of 21 prior-authorization and utilization-management reform principles that the AMA and more than 100 other organizations have endorsed.
“We believe reducing the administrative burden for physicians will reduce cost, improve quality, and create a more accessible health care system for patients,” wrote AMA CEO and Executive Vice President James L. Madara, MD, in a Sept. 11 letter to CMS Administrator Seema Verma regarding the 2018 Medicare Physician Fee Schedule proposed rule.
“Regulatory wins” stemming from the fee schedule proposed rule listed on the dashboard include the delay in implementing the requirement that physicians consult appropriate use criteria (AUC) before ordering advanced diagnostic images, along with retroactive modification of legacy reporting programs such as Meaningful Use (MU) and the Physician Quality Reporting System (PQRS) to reduce penalties physicians may face in 2018 under the QPP’s Merit-based Incentive Payment System (MIPS).
Regulatory wins originating from the QPP proposed rule include proposals to increase the low-volume threshold exempting practices with few Medicare beneficiaries from the MIPS program and postponing a mandate for physicians to upgrade to 2015 edition certified electronic health records (EHRs).
A number of victories were also secured with respect to EHRs. For example, a process is being established for physicians to register complaints with an EHR product directly to the federal government for action, and EHRs must now include enhanced interoperability technology and support for apps.
The dashboard’s top asks for QPP regulatory relief include: simplifying MIPS scoring methodology, allowing specialty practices to qualify as APM medical homes and creating new exemptions and safe harbors from anti-kickback statutes to facilitate coordinated care.