|
In this seventh issue of our Patients over Paperwork newsletter,
we are giving you an update on our ongoing work to reduce administrative
burden and improve the customer experience while putting patients first. In
this edition, we highlight our progress on burden reduction efforts:
How are we reducing burden?
Over the past few years, stakeholders have been telling us about
regulatory burden and that paperwork is increasing. We have listened and made
a thoughtful plan, the Patients over Paperwork initiative, to address burden
across our programs. Patients over Paperwork’s goals are to:
First, we tried to fully understand providers’ concerns about
burden, especially where they were feeling burden the most. We did this in 2
parts through Requests for Information (RFIs) and customer engagement. Last
year, we issued 9 RFIs to solicit comments on burden. We received 2,800
comments and have been working over the past 6 months to address them.
We also realized that RFIs alone were not enough to understand
the burden providers feel when they are delivering care. We established
4 customer centered workgroups and traveled across the country to visit
health care facilities and speak directly with care providers, beneficiaries,
and patients.
Second, we addressed burden through the Federal Rulemaking
process. As of September 2018, we have proposed and finalized a number of
rules that directly reduce burden and give providers more time with patients.
We estimate that across rules finalized in 2017 and 2018 and current
proposed rules CMS projects savings of nearly $5.2 billion and a reduction
of 53 million hours through 2021. That means saving 6,000 years of
burden hours over the next 4 years!
Recently, we released a proposed rule to lift unnecessary
regulations and ease burden on providers. The updates collectively
would save health care providers an estimated $1.12 billion annually.
Many of the proposed provisions simplify and streamline the Medicare
Conditions of Participation and Requirements for Participation for facilities
so that health and safety standards can be met more efficiently. You
can get more information in our fact sheet: https://www.cms.gov/newsroom/fact-sheets/medicare-and-medicaid-programs-proposed-regulatory-provisions-promote-program-efficiency-0.
You can also electronically submit comments through our
e-Regulation website here: https://www.cms.gov/Regulations-and-Guidance/Regulations-and-Policies/eRulemaking/index.html?redirect=/eRulemaking.
What did we learn from our RFIs?
To reduce burden, we had to understand:
Last year, we issued RFIs to solicit comments on burden
reduction, flexibilities, and efficiencies through the annual rulemaking
process for 9 Medicare Fee-for-Service payment rules. We received over
2,800 RFI responses from 7 stakeholder groups: Beneficiary/Consumer,
Clinician/Individual Provider, Institutional Provider, Government Entity,
Health Plan, Supply Chain, and Others.
Our policy analysts spent hundreds of hours reviewing comments
and identified 3,040 mentions of burden. We synthesized and consolidated the
3,040 comments into 1,146 burden topics. Examples of burden topics
include: time intensive auditing/compliance practices across provider
settings, time-consuming prior authorization requirements, lack of uniformity
in home health eligibility documentation requirements, and Repetitive
Medicare Secondary Payer Questionnaire (MSPQ) process.
As of July 2018, we identified 284 actions we have taken or are
taking in response to the RFI burdens, addressing 624 (55%) of the
1,146 burden topics. An additional 185 burden topics (16%) remain under
consideration, and 337 (29%) were either referred to another agency or
decided they didn’t require further action.
RFI Data Analysis Work Stream
Burden Topic Action Status
For example:
Burden identified in RFI comment: Program
compliance costs, such as those associated with beneficiary notices and
requirements to deliver, explain, log, and continually support related
provider-patient interactions, sometimes outweigh the clinical value of the
policy or program.
Recommendation: Consider revisiting notice
requirements and condensing them into fewer, more concise notices that redirect
beneficiaries to other resources. Maintain most information in the
beneficiary manual (Medicare and You), provided to all beneficiaries.
Action taken: In January 2018, we
released a newly revised Skilled Nursing Facility Advance Beneficiary Notice
of Non-coverage (SNFABN), which eliminated the need for the 5 SNF Denial
Letters and the Notice of Exclusion from Medicare Benefits - Skilled Nursing
Facility (NEMB-SNF).
What did we learn from our customer centered
workgroups?
While we were reviewing RFI comments about burden, we were also
busy looking for ways to reduce burden for consumers. To start, we
focused on 4 customer segments:
1. Nursing homes
2. Beneficiaries
3. Clinicians
4. Hospitals.
To understand the customer experience, we left Washington and
went into the field. Over the past year, we have traveled the United
States engaging customers in various health care delivery settings.
We met with providers, beneficiaries, family members,
caretakers, and health care clinical and support staff. We conducted
21 site visits, nearly 300 customer interviews and 97 Subject Matter Expert
interviews, and held 73 listening sessions and other engagement activities.
From this, we were able to learn from our customers in a fuller way how our
policies impact care delivery and innovations they are trying to advance.
What we heard:
Some ways we addressed concerns:
You said: Requiring teaching physicians to re-document
most updates made by medical students in the patient record as part of a
billable Evaluation and Management (E/M) service created burden.
We listened and acted: As of January 1, 2018, a
teaching physician may rely on the medical student documentation and verify
it rather than re-documenting the (E/M) service. In those cases, Medicare
Administrative Contractors shall consider the documentation requirement met
if the teaching physician signs and dates the medical student’s entry in the
medical record.
You said: Facilities spend countless hours
requiring duplicative questionnaires be answered at the time of admission and
reviewing and documenting where in the medical record required information
can be found.
We listened and acted: We are reducing burden by
removing the admission order documentation requirement in an effort to reduce
duplicative documentation requirements. We believe this requirement
will continue to be appropriately addressed through the enforcement of the
hospital conditions of participation, as well as the hospital admission order
payment requirements.
How has regulatory action helped?
We have issued a number of proposed and final rules that, in
part, aim to reduce burden and have made a lot of progress. We estimate
that across rules finalized in 2017 and 2018 and current proposed rules CMS projects
savings of nearly $5.2 billion and a reduction of 53 million hours through
2021. That means saving 6,000 years of burden hours over the next
4 years!
Burden
Reduction Impact:
Total
projected savings from rules finalized in 2017 and 2018
Savings
reflected from 2018-2021 equals $5.2 billion and 53 million hours
Regulatory action taken to reduce burden:
You said: Stakeholders maintain that CMS evaluation and
management documentation guidelines are outdated, complex, ambiguous, and that
they fail to distinguish meaningful differences among code levels.
We listened: CMS acknowledged that the current guidelines
create an administrative burden and increased audit risk for some providers.
We proposed a number of recommendations for E/M visits to begin the
discussion. Currently, we are in the process of reviewing each and every
comment and suggestion we received. We thank the clinician and provider
community for engaging with us in this process.
This rule incorporates a variety of changes in response to
stakeholders’ suggestions about ways to reduce burden for hospitals. Overall,
the rule will reduce the number of hours hospitals spend on paperwork by
about 2 million hours. For example: Removing the requirement that
certification statements detail where in the medical record the required
information can be found.
The Skilled Nursing Facility PPS final rule reduces unnecessary
burden on providers by easing documentation requirements and offering more
flexibility. As part of our actions to modernize Medicare, the SNF PPS rule
makes an innovative new classification system, the Patient Driven Payment
Model (PDPM). The PDPM ties skilled nursing facility payments to
patients’ conditions and care needs rather than volume of services provided.
PDPM simplifies complicated paperwork requirements for performing patient
assessments by significantly reducing reporting burden (approximately $2.0
billion over 10 years), helping to create greater contact between health
care professionals and their patients.
The rule finalizes a variety of changes in response to
suggestions from the public on ways to reduce burden for IRFs. In addition to
policies that reduce the number of measures IRFs are required to report, we
are reducing burden by easing documentation requirements and providing
flexibility in several areas. The final rule will reduce regulatory burden
for IRF providers by well over 300,000 hours.
This rule enables more efficient use of Hospice Compare data in
the Hospice Quality Reporting Program by no longer directly displaying the 7
component measures from which a composite measure is calculated on Hospice
Compare. We would still provide the public the ability to view these
component measures in a manner that avoids confusion on Hospice Compare.
In an effort to reduce unnecessary burdens for physicians, we
are proposing to eliminate the requirement that the certifying physicians
estimate how much longer skilled services are required when recertifying the
need for continued home health care. This proposal is responsive to industry
concerns about regulatory burden reduction and could reduce claims denials
that solely result from an estimation missing from the recertification statement.
We estimate that this proposal would result in annualized savings to
This proposed rule takes significant steps forward by
strengthening quality incentives and reducing administrative burden. Based on
stakeholder feedback, we plan to reduce ESRD facility-related documentation
burdens for certain payment adjustments so that requirements are more
consistent with other payment systems. We are also proposing to update the
measure set for the ESRD Quality Incentive Program so that it’s more closely
aligned with the quality priorities the agency has adopted as part of the
Meaningful Measures Initiative.
What is the Documentation Requirement
Simplification Initiative?
We are simplifying Medicare documentation requirements so
clinicians spend less time on paperwork, including confusing and
time-consuming claims documentation, allowing for more time with patients. We
have made some important changes already: In the past year, we completed 9
sub-regulatory documentation requirements simplifications.
Here are some of our most recent simplifications:
1. Simplified the requirements for preliminary/verbal Durable
Medical Equipment, Prosthetics/Orthotics, and Supplies Fee Schedule (DMEPOS)
orders.
Before: Our instructions were not clear about
whether preliminary (verbal) orders for DMEPOS items were conditions of
payment.
After: Suppliers may dispense most items of DMEPOS based on a verbal
order or preliminary written order from the treating physician. However,
Medicare medical review contractors will look to the signed, written order to
see if the item meets our payment requirements.
2. Clarified DMEPOS written order prior to delivery date
requirements.
Before: There was confusion about whether
contractors needed to verify that a written order was received by checking
for a fax transmittal date or a date
stamp.
After: If the written order is dated the day of or prior to delivery
there is no need for affirmative documentation of its being “received.”
What are our cross-cutting initiatives?
We are committed to reducing burden across our whole
agency. We have launched several initiatives that make up Patients over
Paperwork and they all have the same goal: making patients our top priority.
Meaningful Measures
Our Meaningful Measures initiative is centered on: patient
safety, quality of care, transparency, and making sure the measure sets
providers are asked to report make the most sense. The modernizing proposals
to advance our Meaningful Measures Initiative have or will eliminate 105
measures resulting in projected savings of $178 million and an anticipated
reduction of 4.6 million burden hours!
My HealthEdata & Interoperability
MyHealthEdata aims to empower patients by ensuring that they
control their health care data and can decide how their data is going to be
used, all the while keeping the information safe and secure.
How can I learn more?
Learn more about Patients over
Paperwork.
Join our
listserv to get this newsletter and any other Patients over
Paperwork updates. You can also find our past
newsletters.
Tweet about Patients over Paperwork using the hashtag
#patientsoverpaperwork and #RegReform.
|
Friday, September 28, 2018
Patients Over Paperwork
Subscribe to:
Post Comments (Atom)
No comments:
Post a Comment