Early Indicators Suggest Reason + Logic May Be Expected From HHS & CMS

Part 1 - The Promise

If you follow the RBMA Forum and other professional society forums, as well as frequent input and updates provided by the ACR, 2017, thus far, has been a period in which most all of radiology has been consumed with desperately trying to navigate the government-designed MACRA/MIPS reporting requirements in an attempt to avoid downside potential financial impacts (penalties) - and/or optimize the opportunity to capture upside incentive payments for the practice.

Adding to the angst and confusion for all of us has been 'on-the-fly' changes by CMS, from 2016 through 2017, regarding important details of reporting required metrics of the various categories of QPP reporting (what, when and how), clarification notifications regarding quality metrics, calculations of patient-facing and non-patient facing determinations, improvement activities, advancing care activities, and a whole host of other moving targets, as CMS rolled out MACRA/MIPS in earnest for implementation in 2017 and 2018 (already being revised). The costs of compliance are mounting every day. New cottage industries like QCDR agents, other registries, and more, are popping up regularly - and they are not inexpensive.

Rational Thinking & A New Culture of Leadership Appears To Be On The Way

In addition to keeping up with this important subject matter, I have been watching closely, with great interest, the arrival of the new leadership team at HHS and CMS. Make no mistake, the early indicators coming from the actions - not just the words - of Dr. Price, Secretary of HHS, and Seema Verna, CMS Administrator, are the breath of fresh air we've been waiting to feel from HHS and CMS for years. Disappointedly, none of this gets the press coverage it deserves, and little of this hits the headlines of our industry-specific publications. Too bad that's the case. We could all use some good news and hope for the future right now.

Indications are things may change for the better soon. MACRA/MIPS will not go away - but may become kinder, gentler, and better thought through than its current form. Here are a number of notable insights into this new administration's culture and approach worth celebrating while we are mired in the 'dirty work' of complying with the current regulations as written by the last administration.

> Executive Order (January 20, 2017), President Donald J. Trump (excerpt): "To the maximum extent permitted by law, the Secretary of Health and Human Services (Secretary) and the heads of all other executive departments and agencies (agencies) with authorities and responsibilities under the Act shall exercise all authority and discretion available to them to waive, defer, grant exemptions from, or delay the implementation of any provision or requirement of the Act that would impose a fiscal burden on any State or a cost, fee, tax, penalty, or regulatory burden on individuals, families, healthcare providers, health insurers, patients, recipients of healthcare "services, purchasers of health insurance, or makers of medical devices, products, or medications."

> HHS Press Release (March 17, 2017): "We are going through every page of regulations and guidance related to the Affordable Care Act to determine whether or not they work for patients and whether or not they are making our health care system better."

> Secretary Price Address to CAPG (June 26, 2017) (excerpts): "The administration's job isn't to dictate to docs and others providing care what kind of payment models to use or must use," Price said. "Our job is to make it easier for physicians to use the payment models that work for them, and to put in place a system that incentivizes and accommodates innovation."

Price stressed that for certain settings and procedures, maintaining "fee for service may not be the end of the world." Price also asked the audience for ideas on how "we collect data on physician performance without inundating doctors and nurses and administrators with costly, time-consuming paperwork." He added, "That's kind of where we are right now. We've turned a lot of folks in the healthcare professions into data entry clerks."

Under the current rule, low-volume clinicians exempted from MIPS are those with $30,000 or less in allowed Part B charges annually, or 100 or fewer beneficiaries. That's 32.5% of clinicians. The latest CMS proposal expands the exemption threshold to $90,000 in Part B charges and 200 beneficiaries, "the effect of which is that now, 64% of physicians in this country are exempted."

"You might think that because HHS is responsible for implementing MACRA -- that, as Secretary -- I'm the one who needs to answer the question 'what now?' That's why you're all seated. What are you going to do?"

Price said he prefers to ask another question: "who decides?" -- adding that he believes "physician payment innovation should be in the hands of physicians and healthcare providers across the country. It shouldn't be in the hands of Washington, D.C. We need to facilitate it, yes. But you're the ones with all the good ideas of how we can make our system work better for patients."

HHS and CMS have not been sitting on their hands under the new Secretary and Administrator, although you would never know that for the lack of coverage in the media. For example, I encourage all of us to see the following HHS/CMS announcements made so far this year:


I am looking forward to the day when:

-- sharing on the RBMA Forum, and commentary in radiology-specific publications, will be focused on practice strategic positioning for success in the new healthcare environment - sharing great ideas and action plans which will enable radiology groups to demonstrate value and differentiate their practice from competitors and potential substitutes;

-- radiology will lead in collaboration efforts with referring physicians and health systems on how to make the patient experience what it should be - developing effective communication channels throughout the care team, and educating all payors, not just Medicare and Medicaid, what true patient-centric, cost-efficient care can look like for 'We The People'.

Radiology leaders should be spending their valuable time, talent and treasure on these transformational discussions and strategic action plans necessary to a flourishing new healthcare space - not trying to figure out what they need to do to make it through administrative hoops created by well-meaning bureaucratic ideas about how to move from volume to value with programs like MIPS/QPP and APM investigations.

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Coming Next:

Part 2 - "The Opportunity" - The second part of this series will explore organized radiology's opportunity to accept the invitation to come to the table with HHS/CMS, influence policy rather than commenting upon it, and take back control of the profession through innovation and collaboration.

Part 3 - "Taking Action" - The third part of this series will explore and address strategies and actions others are already taking (and many should consider) in order to maintain relevance in the marketplace and, more importantly, craft a path to financial stability, professional job satisfaction and personal achievement.

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