Wednesday, May 11, 2016

Rethinking MACRA, a follow up

In my blog posts, I speak from the heart without a specific political or economic motivation.   Although I’ve not written about highly controversial subjects such as religion, gun control, or reproductive policy, some of the topics in my posts can be polarizing.   Such as was the case with MACRA.   Some agreed with my initial analysis that clinicians will have a hard time translating complex MACRA payment processes into altered clinical behavior.   Others felt I was overharsh, negative and inappropriate.    It’s never my intent to criticize people, instead I want encourage dialog about ideas.    In that spirit, here’s my opinion on how we should evolve from fee for service to pay for value/outcomes.

1.  Humans can never really focus on more than 3 things at a time.  Although we sometimes believe multi-tasking is efficient, in reality we do work faster with less quality.    Instead of 6 or 8 dimensions of Meaningful Use performance combined with a large number of quality indicators, why not delegate each medical specialty the task of choosing 3 highly desirable outcomes to focus on each year, then reward those outcomes?  For example, I have glaucoma.   Asking my opthalmologist to record my smoking status or engage in secure messaging with me is probably less important than ensuring my intraocular pressures are measured, appropriate medications are given, and my visual field does not significantly worsen.    The cost to society of my blindness would be significant.    Keeping my sight intact represents value.   Care Management software could ensure I’m scheduled for pressure check appointments, given medications, and have my visual field checked once per year.   Some percentage of reimbursement could be withheld until those outcomes are achieved. How  software does that is not important and innovative workflow would be left to the marketplace where clinicians will choose applications based on usability, cost, and time savings instead of regulatory oversight.

2.  Care coordination is important and there is a role for government to drive consensus around standards selection.   Certification could be limited to an application’s ability to perform a few key interoperability functions such as

a.  Look up a recipient address from a national provider directory and send a clinical summary of care (transition, referral request, consult note) to that address securely

b.  Query a record locator service/master patient index and retrieve a list of electronic addresses where patient data is stored, then be able to retrieve a small common data set from those locations (problems, meds, allergies, labs, notes)

c.  Be able to send a clinical summary of care to a patient provided electronic address.

d.  Be able to send a small number of data elements to a relevant registry

e.  Be able to participate in a prescription drug monitoring program

Each of these functions would use a single standards implementation guide without significant optionality,  tested in the marketplace and deemed mature enough for use.  How these transactions are implemented in workflow would be up to each vendor.    Certification would test nothing more than successful transactions against a publicly available test bed.

3.  All other Meaningful Use criteria and quality measures would be eliminated so that clinicians can focus on just the three goals per year relevant to their specialty while  working in an environment that thrives on the simple information exchanges listed above.

We need to avoid unnecessary burden for clinicians, hospitals and software developers.   Think about all the effort (and dollars) spent during the Meaningful Use Stage 1 and 2 processes to report quality measurements, which were never used for anything.   Think about all the certification done that was not related to health policy goals or outcomes.  Think of all the data entry required which resulted in clinicians  spending time practicing below the top of their licenses.  

Focusing on 3 outcomes per specialty which are easily measurable, while radically focusing certfication on a few key interoperability transactions is likely to be acceptable to provider and developer stakeholders.   The big question - would it satisfy CMS goals for MACRA based on Congressional mandates?  I hope to have that dialog in several forums over the next few weeks.


MB said...

Again and again, you have hit the bullseye with what front line providers really need from MACRA. If EHR vendors had those simple interop hurdles for certification, they could focus many more resources to what the provider needs to make those 3 outcome measures work and without a doubt, improve care, efficiency, safety, security and patient satisfaction. Innovation would sprout up, and that is do desperately needed now. Basically, let the real market work. MACRA reads like more of the same complex regulatory scheming, trying got please everyone but pleasing no one. I mean really, CMS/ONC wants me to now participate in a Clinical Practice Improvement Calculation? Really? Along with More MU and PQRS just renamed and reconfigured? And now sign off that I am not data silo-ing, like I have some ability to do that? If you read the comments on the proposed rule, its hard to find even one that doesn't start with "nightmare" "abomination" "unconstitutional" etc. Is there ANY way that you can get through to these folks at ONC and CMS, John? We need your voice heard!

Melissa said...

All these MU, PQRS, and other measures - are they really doing anything to provide better care for patients? I ask the question as a patient, and also as a person who has worked in the Healthcare IT field for a very large software provider. I get why metrics matter - but what and for whom is the real value for?