Onsite HIPAA audits coming in 2017: ONC official
OCR senior adviser Linda Sanches, at the Healthcare Information and Management Systems Society Privacy & Security Forum in Boston this week, explained what healthcare leaders can expect from the process, according to Healthcare IT News.
“We’re looking for evidence that you are implementing the policies and procedures,” Sanches told the audience. “Two huge problems we’re seeing are implementation of risk analysis and risk management.”
HIPAA privacy audits were put on hold last year as the agency developed its phase 2 policy. This spring, HHS posted a new HIPAA audit protocol.
OCR will look “at risk analyses and risk management, notices of privacy practices and access and response to requests for access, and content timeliness of notifications,” OCR Director Jocelyn Samuels said at the time.
Currently, more than 200 desk audits are ongoing—most of them focused on providers, Sanches said, according to Healthcare IT News.
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MGMA Survey of Operations in Medical Practices Shows an Increased Focus on Patient Experience
Survey analyzes how practices adjust their operations as patients have more choices for care, including improving wait times, office hours, appointment scheduling, financial management, and patient portals
New Medical Group Management Association (MGMA) (@MGMA) data find that medical practices focus on patient experience and access as patients face more options in how their care is delivered. The first-of-its-kind Practice Operations Survey analyzes a range of important benchmarking data that’s never been available before, including patient portals usage, wait times, call volumes, hours of operation, appointment length, scheduling and other nuts and bolts of running a medical practice.
“From what time the doors open to how long a patient waits in an exam room, operations affect a practice’s bottom line as well as its ability to deliver quality care to patients,” said Dr. Halee Fischer-Wright, MD, MMM, FAAP, CMPE, President and CEO of the Medical Group Management Association. “As patients increasingly have more options for receiving care, it’s essential for practices to have benchmarking data to identify tactics that best improve patients’ experiences.”
The survey shows that practices concentrate efforts on gathering information about their patients’ experiences to guide improvement of operations. The data found that 85 percent of practices conduct patient satisfaction surveys, and of those, more than 70 percent conduct them at least monthly if not more frequently.
Many of the operations metrics in the new survey focus on patient access. For example, of all responding practices, the MGMA data show that 61 percent of practices have taken action to improve wait times. Practices report median wait times between 10 and 15 minutes for time spent in the waiting area.
These findings further underscore the results of an MGMA Stat poll – a real-time, text-based polling initiative – from April of more than 100 health professionals finding that more than 80 percent of the respondent practices changed or were in the process of changing processes to improve patient access.
The data show that few practices report having extended hours on the weekends – 26 percent are open to patients on Saturdays and 11 percent on Sundays. Of those practices that are open on the weekends, nearly all are either primary care or multispecialty practices with just a handful of surgical specialty practices. Additional patient access measures in the data include wait for a scheduled appointment, call volumes and responsiveness, length of appointment times, number of appointment slots per day and percentage of same-day appointments.
Patient portals also show variations: Practices report that patients utilize online portals most for accessing test results, regardless of specialty: generally more than 10 percent. Primary care practices also report a higher percentage use of patient portals for communication with providers and medical staff compared to other specialties.
The MGMA data also look at management aspects of operations, including frequency of collecting patient balances at time of service, establishing and monitoring an annual budget, limiting patient no-shows, managing employee turnover and satisfaction, and improving billing functions.
The survey found that nearly 25 percent of medical practices do not create an annual budget. Of the three quarters of practices that do create an annual budget, the vast majority compare their year-to-date status relative to their budget on a monthly basis.
“An annual budget is critical to every practice’s preparations for the upcoming year as it projects the revenue that will be available to support practice activities, defines future staffing levels, and most importantly forecasts the bottom line for the practice and its owners a year in the future,” said David Gans, FACMPE, MGMA senior fellow industry affairs. “Despite the value of having a tool to manage ongoing activities and minimize the impact of unfavorable conditions, these data confirm what we’ve observed, that many practices across the country don’t understand the value they can derive from preparing an annual budget. That’s why MGMA provides guidance how to create a budget that is tailored to a practice’s needs and the best ways to use it to bring actuals in line with projections.”
The Practice Operations report is based on information provided by 791 practices across the country and is available to purchase here.
SOURCE: RCM Answers | 11/7/16
Here We Go Again…
Meg Bryant over at Healthcare Dive reports that CMS released an API tool to ease MACRA reporting.
- The Centers for Medicare & Medicaid Services launched an online tool enabling clinicians to automatically share electronic data for the Quality Payment Program.
- The tool is the first in a series of efforts aimed at easing the burden of participating in the program, according to the agency.
- Last month, CMS launched a QPP website to help physicians and other providers understand and navigate the new program.
With the application program interface tool, developers can write software for quality measures listed on the QPP website. CMS created an earlier tool, Explore Measures, so that clinicians could choose appropriate measures, assemble them into a group and save or print them for reference later.
The American Academy of Physicians and other groups praised the new online tool.
CMS published its QPP final rule, which implements the Medicare Access and CHIP Reauthorization Act (MACRA), on Oct. 14. In June, HHS announced a five-year, $100 million funding initiative to help small physician practices prepare for the program. Organizations awarded funding will assist practices in deciding which quality measures or EMRs best suit their needs and other issues related to QPP success.
Here are the MACRA final rule changes you need to know
Last week, HHS released a barrage of regulations and guidance under it’s various arms. One final rule focused on health IT but the big news centered on CMS’ release of the highly anticipated Medicare Access & CHIP Reauthorization Act of 2105 (MACRA) implementation final rule (link removed). The announcement differed somewhat from CMS’ previous releases. For one, the agency gave interested parties the news in the morning hours as opposed to within the happy/witching hour of 4 p.m. at the end of a working week. Another is the agency teamed up with the U.S. Digital Service team to produce an easy-to-use, informative website detailing the program.
The Medicare program covers about 55 million people, CMS’ acting Administrator Andy Slavitt noted on a call for reporters.
MACRA will eliminate the sustainable growth formula and replace it with a .5% annual rate increase through 2019, after which physicians are encouraged to shift to one of two Quality Payment Programs: 1) Merit-Based Incentive Payment System (MIPS) or 2): Alternative Payment Model (APM).
MIPS sunsets and packages up Meaningful Use, the Physician Quality Reporting System and the Value-Based Payment Modifier where physicians will receive payment adjustments based on quality (via both evidence-based standards and practice-based improvement activities), cost and use of certified EHR technology use.
2017 will be a transitional year
While initial reports noted the hefty 2,398 page count (including one from this very publication (link removed)), the majority of those pages account for responses to comments on the proposed rule (the agency received around 3,800 comments!). CMS is, with the aforementioned website and it’s streamlined executive summary, really trying to make the regulation understandable, allow flexibility for physician implementation and push for more patient-centered care.
The rule finalized 2017 as the performance period for the 2019 MIPS payment year as a transition year as part of the development of the program. “For this transition year, for MIPS, the performance threshold will be lowered to a threshold of 3 points. Clinicians who achieve a final score of 70 or higher will be eligible for the exceptional performance adjustment, funded from a pool of $500 million,” CMS noted.
A sigh of relief for small providers
The law increased the low-volume threshold to $30,000 in Medicare Part B charges or 100 Medicare patients. About 600,000 clinicians are expected to be affected by the law. Dr. Patrick Conway, deputy administrator for innovation & quality, CMS CMO, said on a call for reporters at the release of the rule that 380,000 clinicians could be exempt from the MIPS program. He added CMS expects 25% of physicians to participate in advanced APMs in 2018 but for the first year expects about 100,000 to participate.
“We think the vast majority of small practices can succeed,” Conway said. In addition to increasing the low-volume threshold, HHS noted that $20 million each year for five years will be provided to train and educate Medicare clinicians in small practices of 15 clinicians or less and providers working in underserved areas.
CMS is also allowing MIPS reporting as a group (defined as “a set of clinicians (identified by their NPIs) sharing a common Tax Identification Number, no matter the specialty or practice site”). This could help small providers of similar size to band together to receive a payment adjustment based on the group’s performance. Groups must register by June 30, 2017.
CMS listened to administrative burden concerns and focused on flexibility
The agency got out of the office to get real-world takes on how such a sweeping rule could affect the care delivery system. In addition to the written comments, the agency went on listening tours drawing over 100,000 attendees. On the press call, Slavitt noted the changes to the rule were to help physicians focus on delivering care and seeing patients instead of performing administrative tasks. The overwhelming response to the rule was to “make the transition to MACRA as simple and as flexible as possible,” Slavitt said.
To that end, providers who feel comfortable can begin on New Year’s Day to collect performance data but providers can begin collecting such data anytime between January 1, 2017 and October 2, 2017. Here’s the catch: You have to do something in 2017. While providers are offered three different MIPS submission options, no participation will result in a 4% negative payment adjustment in 2019. Performance data is due March 31, 2018.
The agency is allowing providers a “pick-your-pace” method over three data submission options through MIPS or a fourth option to join an Advanced APM:
- “Test” the program by submitting a minimum amount of data – one quality measure, for example – to ensure physicians’ systems are working and prepared for broader participation in the next years.
- Submit 90 days of 2017 data, which would allow practices to submit their first performance period for a time later than Jan. 1, 2017 and still qualify for a small positive payment adjustment.
- Submit a full year of 2017 data which could result in a positive payment adjustment.
- Join an Advanced APM, which involves more risk. “If you receive 25% of Medicare payments or see 20% of your Medicare patients through an Advanced APM in 2017, then you earn a 5% incentive payment in 2019,” the Quality Payment Program website notes.
More Advanced APM participation opportunities are coming
The agency anticipates the following to be advanced APMs in 2017:
- Comprehensive ESRD Care – Two-sided risk;
- Comprehensive Primary Care Plus (CPC+);
- Next Generation ACO; and
- Medicare Shared Savings Program – Tracks 2 and 3.
CMS intends to broaden APM opportunities for clinicians, including small practices and specialists. For example, a major opportunity being considered for 2018 will be the new Accountable Care Organization Track 1+ model. The agency is also reviewing reopening some existing Advanced APMs for application.
Reduced health IT measures
The “Advancing Care Information” section of MIPS replaces the Meaningful Use program. To mitigate administrative burden, CMS reduced the total number of required measures from 11 in the proposed rule to five in the final rule:
- Security risk analysis;
- Provide patient access;
- Send summary of care; and
- Request/accept summary of care.
In addition to the five required measures, there will be optional measures a provider can report to potentially allow for a higher score. “For the transition year, we will award a bonus score for improvement activities that utilize [certified EHR technology] and for reporting to public health or clinical data registries,” the rule stated.
The agency is still open to ideas
Comments will be taken on the final rule for 60 days (the rule is set to be published in the Federal Register on October 19) as CMS begins to implement the law on an iterative basis. “We’re not looking to transform the Medicare program in 2017,” Slavitt said on the call for reporters. “We’re looking to make a long term program successful.”