Indiana Mandates Electronic Prescribing

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Indiana Governor Eric Holcomb recently signed SB176 into law. This Act mandates Indiana healthcare providers to electronically prescribe all controlled substances with an effective date of January 1st, 2021.  This bill began as an 8-line document allowing patients to transfer their prescription to another pharmacy.  Several amendments were made in the two weeks it took the Indiana House and Senate to pass the bill bringing it to 15 pages in length.

Other subsections include:

  • The Act amends several sections of state code by adding the phrase “or electronically transmit” to add electronic prescribing as a valid means of prescribing.
  • There are provisions in the Act for a waiver system with similar circumstances for approval as other states have enacted.  Some of these include: economic hardship, technological limitations, and other circumstances determined by the board.
  • Pharmacies are not required to verify if a controlled substance prescription received via written, oral, or fax falls within the state and federal laws.
  • The Act allows for advanced practice registered nurses to send prescriptions under their own credentials once they have met the requirements established by the board, previously nurse practitioners were required to send prescriptions under a supervising physicians’ credentials.
  • Telemedicine is also addressed in this Act.  Indiana has allowed for the prescribing of controlled and non-controlled (excluding opioids) prescriptions for telemedicine providers so long as certain criteria is met.  One regulation is that an Indiana licensed practitioner has seen the patient in person and developed a medical plan that the telemedicine prescriber is following. (Note: Stay tuned for our next blog concerning U.S. Wide Telemedicine Prescribing that goes into more details about the uncertainty of telemedicine and the current laws governing it.)

Indiana has remained below the national average for opioid-related overdose deaths since 1999, following the national trend and increasing in number of deaths.  However, the rate has increased sharply in recent years catching up with the national average.  If the rate continues as forecasted, it will pass the national average for the first time since the National Institute on Drug Abuse has been collecting data.  Prescription opioid overdose deaths decreased in 2011 but have begun to rise again in recent years along with heroin and synthetic opioid deaths.  Indiana enacted SB226 on April 26th, 2017, the Act limits the first fill prescription of opioids to seven days for adults.  The law also limits opioid prescriptions for minors to seven days.  Prescriptions can exceed seven days under certain circumstances, such as the doctor determines that the patient requires it and if the patient is in palliative care.[1]

Indiana currently has a 30.5% provider enablement for electronic prescribing of controlled substances, which is just below the national average of 33.4%.  Pharmacy enablement for EPCS is 97.8% which is above the current nation average for pharmacies, which is 95.2%.[2]  There will likely be a big push leading up to 2021 to secure electronic prescribing, MDToolbox encourages providers not to wait!

Indiana now aligns with several other states mandating electronic prescribing.  MDToolbox looks forward to working with providers throughout Indiana to ease the transition and help provide tools and resources in combating the opioid epidemic.  With MDToolbox providers have access to tools such as Electronic Prescribing of Controlled Substances (EPCS) and convenient on the go mobile e-prescribing.  Contact us for more information or to start your free 30 day free trial.

[1]http://www.hallrender.com/2017/06/21/new-indiana-law-imposes-a-seven-day-limit-on-opioid-prescriptions/

[2]https://surescripts.com/enhance-prescribing/e-prescribing/e-prescribing-for-controlled-substances

Tennessee Amends and Delays E-Prescribing Mandate

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Tennessee Governor Bill Haslam recently signed SB0810 into law.  This Act mandates Tennessee healthcare providers to electronically prescribe all controlled substances with an effective date of January 1st, 2021.  Tennessee had previously passed HB1993 which mandated EPCS for Schedule II drugs by January 1st, 2020.  This latest Act makes several changes to the prior legislation:

  • The new Act replaces Schedule II drugs with Schedule II-V.  Now, all controlled substances are required to be electronically prescribed. 
  • The required date for prescribers to follow the mandate has been postponed to January 1st, 2021 from January 1st, 2020. 
  • Tennessee pharmacies are now required to be able to issue partial prescriptions in their electronic system of Schedule II drugs by January 1st, 2020 or face action by The Board of Pharmacy.  Tennessee previously passed 63-1-163 which regulated pharmacies when filling partial prescription orders.  The new amendment requires the pharmacy’s electronic system to be able to split the medication orders should a patient only want a partial order, or if the pharmacy is low on stock of the Schedule II drug.

Tennessee has remained above the national average for opioid-related overdose deaths since 2003, rising even faster than the national trend in number of deaths.  While some states have had a flattening or reduction in prescription opioid overdose deaths in recent years, Tennessee has continued to trend upward.  The number of deaths from synthetic opioids and heroin had remained stable until 2014, when the numbers began to rise.

Last year, Tennessee passed HB1831: “TN Together Opioid Reform” which made several major strides toward the fight against opioid addiction.  The Act budgeted $30 million for prevention, treatment, and law enforcement tasks in relation to the opioid epidemic.  The Act also mandated that pharmacies check the State PMP registry.  The biggest change has to do with how much of a drug you can get and when. Under the new law, pharmacists can only partially fill a prescription for no more than half of the number of days it’s written for. And there are limits on prescriptions, too: General prescriptions are limited to a 10-day supply (and no more than 500 cumulative morphine milligram equivalents).[1]

Tennessee currently has a 23.5% provider enablement for electronic prescribing of controlled substances, which is well below the national average of 33.4%.  Pharmacy enablement for EPCS is 96.7% which is above the current nation average for pharmacies is 95.2%.[2]  HB1993, which was passed a year ago would have required EPCS of Schedule II drugs only 8 month from the writing of this blog.  There will likely be a big push leading up to 2021 to secure electronic prescribing, MDToolbox encourages providers not to wait!

Tennessee now aligns with several other states mandating electronic prescribing.  MDToolbox looks forward to working with providers throughout Tennessee to ease the transition and help provide tools and resources in combating the opioid epidemic.  With MDToolbox providers have access to tools such as Electronic Prescribing of Controlled Substances (EPCS) and convenient on the go mobile e-prescribing.  Contact us for more information or to start your free 30 day free trial.

 

[1]https://www.knoxnews.com/story/news/health/2018/06/29/tennessee-opioid-prescription-law-pharmacy/746208002/

[2]https://surescripts.com/enhance-prescribing/e-prescribing/e-prescribing-for-controlled-substances/

Colorado Mandates Electronic Prescribing

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Colorado Governor Jared Polis recently signed SB079 into law. This Act mandates Colorado healthcare providers to electronically prescribe controlled substances that are scheduled as II-IV with an effective date of either July 1st, 2021, or July 1st 2023.  The Act breaks down the medical field to several categories of healthcare providers: podiatrists, dentists, optometrists, advanced practice nurses, physicians, and physician assistants.  For each practitioner category there is a provision for those who are practicing in a rural area of the state or are a sole-practitioner to postpone the mandate from July 1st 2021 to July 1st 2023.  Dentists are mandated for EPCS by July 1, 2023 regardless of if they serve a rural or urban community.

Other subsections of this Act include:

  • The act contains provisions for a waiver to using EPCS as many State Mandate laws do, however Colorado allows for practitioners who write less than 25 prescriptions for controlled substances per year to not have to adopt electronic prescribing.
  • Prescribers are required to indicate on their license renewal whether they have complied with the EPCS mandate.
  • Pharmacies are not required to verify if a controlled substance prescription received via written, oral, or fax falls within the state and federal laws.

Colorado has remained slightly above the national average for opioid-related overdose deaths since 1999, following the national trend and increasing in number of deaths.  The rate then flattened in 2015 and 2016, falling below the national trend.  Heroin related deaths have been climbing; however, prescription opioid deaths have been slightly declining in recent years.

Several legislative initiatives have been enacted as Colorado continues the fight against the opioid epidemic.  In 2017, the general assembly enacted Senate Bill 17-074, which created a 2-year medication-assisted treatment (MAT) expansion pilot program, administered by the university of Colorado college of nursing, to expand access to medication-assisted treatment to opioid-dependent patients in Pueblo and Routt counties. The 2017 Act directs the general assembly to appropriate $500,000 per year for the 2017-18 and 2018-19 fiscal years from the marijuana tax cash fund to the university of Colorado board of regents, for allocation to the college of nursing to implement the pilot program. The pilot program repeals on June 30, 2020.[1]  Currently, Senate Bill 19-001 is under consideration to expand and continue the MAT in future years.  Colorado also passed Senate Bill 18-022 in 2018, which limits the quantity of opioids that a patient can receive.

Colorado currently has a 31.7% provider enablement for electronic prescribing of controlled substances, which is just below the national average of 33.4%.  Pharmacy enablement for EPCS is 97.4% which is above the current nation average for pharmacies, which is 95.2%.[2]  There will likely be a big push leading up to 2021 to secure electronic prescribing, MDToolbox encourages providers not to wait!

Colorado now aligns with several other states mandating electronic prescribing.  MDToolbox looks forward to working with providers throughout Colorado to ease the transition and help provide tools and resources in combating the opioid epidemic.  With MDToolbox providers have access to tools such as Electronic Prescribing of Controlled Substances (EPCS) and convenient on the go mobile e-prescribing.  Contact us for more information or to start your free 30 day free trial.

 

[1]https://leg.colorado.gov/bills/sb19-001

[2]https://surescripts.com/enhance-prescribing/e-prescribing/e-prescribing-for-controlled-substances/

Kentucky Mandates Electronic Prescribing

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Kentucky Governor Matt Bevin recently signed HB342 into law. This Act mandates Kentucky healthcare providers to electronically prescribe all controlled substances with an effective date of January 1st, 2021

Other subsections of this Act include:

  • The act contains provisions for a waiver to delay the mandate for a specified time period for e-prescribing in the event of economic hardship, technological limitations, or exceptional circumstances, these are to be determined.
  • Pharmacies are not required to verify if a controlled substance prescription received via written, oral, or fax falls within the state and federal laws.

Kentucky has remained above the national average for opioid-related overdose deaths since 2001, several years were double the national rate.  In 2000, only nine counties in the U.S. had overdose death rates of more than 20 per 100,000 people, and four of these were located in Kentucky.  By 2014, more than half of Kentucky counties had overdose rates that high.  This represents a quadrupling of deaths due to drug overdose, from less than 250 in 2000 to more than 1,000 each year since 2010.  According to the Kentucky Justice and Public Safety Cabinet, drug overdose deaths reached 1,248 in 2015. [1]

Over the past two decades, the Commonwealth has taken efforts to curb problems related to substance use. In 1998, Kentucky became one of the first states to launch a prescription drug monitoring program—the Kentucky All Schedule Prescription Electronic Reporting (KASPER) system to monitor medical use of controlled substances, such as prescription opioid painkillers. KASPER has since been enhanced and now offers health care providers and pharmacies real-time 24-hour access to prescription information that can be used to monitor and prevent overuse of prescription medications.  Policymakers have also adopted policies aimed at reducing the impact of illegal drugs, such as passing the 2015 Senate Bill 192, which authorized expanded use of naloxone, a drug that treats opioid overdoses, and funded substance use treatment programs.[2]

Kentucky currently has only 18.9% provider enablement for electronic prescribing of controlled substances, which is below the national average of 33.4%.  Pharmacy enablement for EPCS is 98.1% which makes Kentucky one of the states with highest percentage of pharmacies ready to receive electronic prescriptions.  The current nation average for pharmacies is 95.2%.[2]  There will likely be a big push leading up to 2021 to secure electronic prescribing, MDToolbox encourages providers not to wait!

Kentucky now aligns with several other states mandating electronic prescribing.  MDToolbox looks forward to working with providers throughout Kentucky to ease the transition and help provide tools and resources in combating the opioid epidemic.  With MDToolbox providers have access to tools such as Electronic Prescribing of Controlled Substances (EPCS) and convenient on the go mobile e-prescribing.  Contact us for more information or to start your free 30 day free trial.

 

[1]https://www.healthy-ky.org/res/images/resources/Full-Substance-Use-Brief-Final_12_16-002-.pdf

[2]https://surescripts.com/enhance-prescribing/e-prescribing/e-prescribing-for-controlled-substances/

Wyoming Mandates Electronic Prescribing

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Wyoming Governor Mark Gordon recently signed Enrolled Act No 66/SF0047 into law. This Act mandates Wyoming providers to electronically prescribe all controlled substances with an effective date of January 1st, 2021.  The Act has provisions for the state board to provide some exemptions to the requirement for emergencies and has the power to grant an extension to a dispenser or practitioner; however, being granted an extension is not guaranteed.

Other subsections of this Act include:

  • Prior to writing a prescription for a controlled substance, providers are required to search the state PMP database, as well as every 3 months thereafter for as long as the patient remains on a controlled substance.
  • Pharmacies must submit their dispense data on controlled substances to the state daily.
  • All prescribing providers are required to take 3 hours of continuing education every two years related to the responsible prescribing of controlled substances when they renew their license.
  • All Schedule II prescriptions require either written or electronic prescription until the 1/1/21 mandate, oral orders will not be accepted.
  • All Schedule III and IV prescriptions shall not be refilled more than six months after the prescribed date, and not refilled more than five times unless renewed. 

In recent years, Wyoming has fallen below the national average for opioid-related overdose deaths.  However, prior to 2015 Wyoming was above the national average for 5 consecutive years[1].  The state trends continue to rise along with the national average of opiate-related deaths.  Wyoming currently has only 17.5% provider enablement for electronic prescribing of controlled substances[2], well below the national average.  There will likely be a big push leading up to 2021 to secure electronic prescribing, MDToolbox encourages providers not to wait!

Wyoming now aligns with several other states mandating electronic prescribing. MDToolbox looks forward to working with providers throughout Wyoming to ease the transition and help provide tools and resources in combating the opioid epidemic. With MDToolbox providers have access to tools such as Electronic Prescribing of Controlled Substances (EPCS) and convenient on the go mobile e-prescribing.  Contact us for more information or to start your free 30 day free trial.

[1]https://www.drugabuse.gov/drugs-abuse/opioids/opioid-summaries-by-state/wyoming-opioid-summary

[2]https://surescripts.com/enhance-prescribing/e-prescribing/e-prescribing-for-controlled-substances/

Electronic Prescription Directions Vary Greatly in Content and Quality

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Electronic prescriptions allow for providers to enter any free-text directions (Sig) they wish, just as if they were writing a paper prescription. The patient directions are one of the most critical parts of a prescription. It’s a huge safety risk if patients do not understand how to use their prescription or if a pharmacist has to try to interpret what the provider means. In a recent study that analyzed 25,000 electronic prescriptions issued by 22,152 community-based prescribers using 501 e-prescribing software applications, it was found that there was a large number of variations in the electronic prescription directions1. The quality of the directions also varied greatly.

The study was conducted by Yuze Yang, PharmD, from Surescripts and colleagues, and published online in the Journal of Managed Care & Specialty Pharmacy. Out of the 25,000 e-prescriptions, there were 3,797 unique Sigs concepts identified in the Sig text strings. However, more than half of all patient directions could be classified into just 25 unique Sig concepts. There were large numbers of variation of even what would be considered simple and straightforward directions found. For example, over 800 permutations of words and phrases used to convey "take one tablet by mouth once daily" were identified.

The researchers not only looked at the variations, they also analyzed the Sig text strings for quality-related events which were defined as “Sig text content that could impair accurate and unambiguous interpretation by staff at receiving pharmacies.” The biggest quality issue observed was incomplete Sigs. Prescriptions were commonly missing relevant dosages or administration frequency/timing information. They found that more than one in ten prescriptions contained some sort of quality issue.  Considering the number of electronic prescriptions that are sent and the not only time-wasting potential but possibly catastrophic results that could come from such quality issues, that figure is way too high.

The authors' recommendations for reducing the quality issues and variations include:

  • Enhancing e-prescribing application user interfaces and Sig creation tools
  • Improving end-user training and usability testing for optimal use of system functionalities
  • Adopting and implementing the currently available Structured and Codified Sig format by both prescriber and pharmacy systems to facilitate improved standardization and interoperability

At MDToolbox, patient safety and ease of use for prescribers are two of our main focuses when designing our directions input fields. We offer several options designed to make entering quality directions as easy as possible:

  • Sig builder – build complete directions in just a few easy clicks
  • Common Sigs – choose from the most commonly used Sigs already available in the system
  • Saved favorite directions – prescribers can enter directions that they commonly use and save them as a favorite with a shortcut that can be quickly accessed
  • Free-text directions – although free-text directions open it up to possible quality errors, MDToolbox has implemented quality checkers to ensure that free-text directions are not missing any of the information the contributes to many of the quality issues such as “how much” or “how often” the prescription should be used.

MDToolbox is also constantly looking for ways like our quality checkers to enhance these areas even more. Part of the way we do this is by conducting usability tests and end-user trainings in order to get feedback from users and ensure users are taking advantage of the available tools. We share a goal with Surescripts to have zero-error e-prescribing and are continually striving towards this goal.

 

  1. Quality and Variability of Patient Directions in Electronic Prescriptions in the Ambulatory Care Setting https://www.jmcp.org/doi/10.18553/jmcp.2018.17404 

E-Prescribing Growth Continues to Soar

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E-Prescribing makes the prescribing process easier and safer for patients, prescribers, and pharmacists alike, so it comes as no surprise that e-Prescribing rates continue to surge each year. Surescripts recently released its 2016 National Progress Report1 detailing the e-Prescribing growth they’ve seen on their network.

A total of 1.6 billion e-prescriptions were sent in 2016, up 12% from 1.4 billion in 2015. This accounts for 73% of all prescriptions being sent electronically.

The rates for e-Prescribing of Controlled Substances (EPCS) saw one of the biggest increases with a 256% jump from 2015. There were 45.3 million e-prescriptions for controlled substances sent in 2016 as compared to only 12.8 million in 2015. Part of this increase can be attributed to states such as New York, Minnesota and soon to be Maine mandating that all controlled substances be sent electronically.

The mandate helped New York be ranked number 1 in the Surescripts report with 72.1% of prescribers enabled for EPCS, 98.1% of pharmacies enabled, and 91.9% of controlled substances prescribed electronically. Minnesota, who doesn’t enforce their mandate, was ranked number 7 with 14.3% of prescribers enabled for EPCS, 93.8% of pharmacies enabled, and 19.8% of controlled substances prescribed electronically.

States are putting these mandates in place in an effort to combat substance abuse and increase patient safety. With software, like MDToolbox-Rx, incorporating EPCS into the existing e-Prescribing workflows, it really leaves little reason for those prescribers who are already e-Prescribing not to electronically prescribe controlled substances as well.

The ability to access patient medication histories electronically at the point of prescribing also plays an important role in patient safety. It allows prescribers the ability to see a more complete history and avoid adverse drug events. The amount of providers accessing medical histories on the Surescripts network also increased in 2016. More than 1.08 billion medication histories were accessed.

2016 also saw a 22% increase in the number of healthcare professional connected to the Surescripts network with 1.3 million healthcare professionals connecting. However, although the number of prescribers connected increased by 7%, it’s somewhat surprising that 36% of prescribers are still not connected. We are confident that the number of prescribers who connect will continue to increase though, as prescribers continue to realize the value of e-Prescribing and the ease of use provided by software like MDToolbox-Rx.

 

1. Surescripts 2016 National Progress Report http://surescripts.com/news-center/national-progress-report-2016/

Maine e-Prescribing Deadline Fast Approaching

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Prescribers in Maine have less than 3 weeks until the mandate requiring all opioid prescriptions be sent electronically goes into effect. As of July 1st, 2017, licensed practitioners in Maine may no longer write paper prescriptions for opioid medications according to Public Law Chapter 4881.

As we wrote about earlier, the mandate was put in place in an effort to combat opiate abuse and heroin addiction. E-Prescribing prevents forged prescriptions, eliminates errors from illegible handwriting and misunderstood oral prescriptions, and helps prevent overprescribing of pain medications. It’s hoped that by limiting the pain pills, it will prevent people from even trying heroin to begin with.  

The Office of Substance Abuse and Mental Health Services in Maine produced a document “Electronic Prescribing in Maine: A Guide to Understanding E-Prescribing and its Benefits2,” which addresses some frequently asked questions about the mandate.  Among the FAQs, it’s stated that an electronic prescription will be required for any amount of opioid medication being prescribed, even those for fewer than 7 days. Sending a prescription via facsimile will also not meet the requirements. Opioid prescriptions must be sent electronically using software that meets all of the federal security requirements and has been approved by the DEA for EPCS.

The DEA requirements for EPCS include:

  • Using certified software that has gone through a 3rd Party Audit – software systems must show that they meet the DEA requirements for signing, transmitting, and processing controlled substances prescriptions
  • Identity proofing – all prescribers must prove they are who they say they are and have the proper credentials to prescribe controlled substances
  • 2-Factor Authentication – prescribers must use 2-factor authentication to sign controlled substance prescriptions electronically. This involves using 2 of the following: something you know (a password), something you have (most commonly a software or hardware token), or something you are (biometric information).

While the requirements can make it seem overwhelming, MDToolbox has simplified the process. Signing up for MDToolbox-Rx e-Prescribing with EPCS is a simple process with only a few steps that can be completed within minutes. Once signed up, utilizing the software is just as easy with an intuitive workflow.

Although it’s quick and easy to get started with MDToolbox, we do not recommend waiting any longer. If you prescribe opioids in Maine and still need e-Prescribing software to meet the mandate, contact us today at info@mdtoolbox.com or 206-331-4420! We are ready to answer any questions you have and help make your transition to EPCS as smooth as possible.

 

1.  https://legislature.maine.gov/legis/bills/bills_127th/chapters/PUBLIC488.asp

2. Electronic Prescribing in Maine, A Guide to Understanding E-Prescribing and its Benefits. http://www.maine.gov/dhhs/samhs/osa/data/pmp/Electronic-Prescribing.pdf

37 States Now Sharing Prescription Data

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Massachusetts, New Hampshire, New York and Texas are the four most recent states to join the prescription monitoring program (PMP) run by the National Association of Boards of Pharmacy (NABP) – NABP PMP InterConnect1. This brings the total number of states connected to 37, making it the largest prescription data sharing network. Over 3.9 million requests and 8.2 million responses are processed through the system each month.

The complete list of connected states includes: Alaska, Arizona, Arkansas, Colorado, Connecticut, Delaware, Georgia, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Nevada, New Jersey, New Hampshire, New Mexico, New York, North Dakota, Ohio, Oklahoma, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, West Virginia and Wisconsin.

It is expected that other states will be joining soon too. “We’re excited about the growth and response to PMP InterConnect,” said NABP President Hal Wand, MBA, RPh. “Our goal is to reach every state with a PMP to guarantee a true connection across our country in an effort for greater medical knowledge and our patients’ safety.”

There is no charge to the states to use the system and it’s setup to enforce each state’s data-access rules. Authorized healthcare professionals including physicians and pharmacists in each of the connected states are able to access multi-state histories of their patients’ controlled substance prescriptions. This is an important tool in combating prescription drug abuse and identifying potential problems by allowing providers to see a comprehensive history, especially for those patients who cross state lines.

1. "Four States Join NABP PMP InterConnect, the Nation’s Largest Prescription Data Sharing Network," National Association of Boards of Pharmacy (NABP) https://nabp.pharmacy/four-states-join-nabp-pmp-interconnect-nations-largest-prescription-data-sharing-network/

2017 Brings Changes to Medicare Incentive Programs and Meaningful Use

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As we ring in the new year, medical providers now can say goodbye to the CMS’s “Meaningful Use Incentive Program” (MU) and start preparing for the new Medicare incentive program.

Providers who used qualified systems in 2016 can still attest to Meaningful Use for the 2016 year (you must have been a “meaningful user” of certified electronic medical record system(s) for the minimum reporting period. Visit this website for more info on how the previous year’s MU programs worked and deadlines for attesting: 

https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/2016ProgramRequirements.html

Now in 2017, Meaningful Use will become one of four components of the new “Merit-Based Incentive Payment System” or MIPS. MIPS is part of the bigger Medicare Access and CHIP Reauthorization or MACRA.

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) ended the Sustainable Growth Rate formula, which threatened clinicians participating in Medicare with potential payment penalties for 13 years.  

The MACRA program introduces two paths that Medicare providers can choose from for participation:

  • Advanced Alternative Payment Models (APMs) (providers apply for a special payment model program) or
  • The Merit-based Incentive Payment System (MIPS)  (a performance-based program)

 

Who Does this Affect?

Providers who are in an Advanced APM or who bill Medicare for more than $30,000 a year and care for more than 100 Medicare patients a year are affected. Providers with less than that are not affected and not part of the program.3  This includes:

  • Physician
  • Physician assistant
  • Nurse practitioner
  • Clinical nurse specialist
  • Certified registered nurse anesthetist

 

Advanced Alternative Payment Models (APMs)

The Advanced APMs program allows certain providers to apply for the APM track. This gives added incentive payments to provide high-quality and cost-efficient care. See the APM website for more information on the special programs and how providers can apply:

https://qpp.cms.gov/learn/apms

 

The Merit-based Incentive Payment System (MIPS)

Most Medicare Providers will be part of MIPS. They will earn a payment adjustment based on evidence-based and practice-specific quality data submitted. According to CMS, the Quality Payment Program policy will reform Medicare payments for more than 600,000 clinicians across the U.S.

Providers participating in the program in 2017 will submit their data by March 2018 and based on submission, their 2019 Medicare payments will be adjusted up, down, or not at all. 

MIPS is broken down into four categories and is setup so that the more Providers participate (and attest to), the higher score (and incentive) providers will get. A Medicare provider who does not participate at all (0%) may see up to 4% negative adjustment in 2019. A provider with a minimal amount of participation (e.g. submit one measure) may be able to avoid adjustment. For partial submission (submit the minimums for a partial year) they will see neutral or positive adjustments, and submit a full year and earn a positive payment adjustment.

CMS has setup a new website for the Quality Program4 which breaks down the four components of the MIPS:

  • Quality (replaces PQRS)   (60%)
  • Improvement Activities (new)  (25%)
  • Advancing Care Information (replaces Meaningful Use)   (15%)
  • Cost (replaces Value Based Modifier)   (0% in 2017)

Image Credit:  MIPS Quality Payment Program Website:  https://qpp.cms.gov/measures/performance

 

If we take a quick look at how each category works:

  •  Quality
    •  Most Providers will report up to 6 quality measures (including an outcome type measure). Quality measures selected should be focused based on type of care and specialty as appropriate.
    •  Reporting period must be a minimum of 90 days.
    • There are over 250 quality measures available, be sure to check your health record software system to see which ones they support (can help gather data for you) when planning.
    • Measures go across many specialties and problem sets:  For example, “Age Appropriate Screen Colonoscopy” – Report the percentage of patients greater than 85 years old seen by the Provider who received a colonoscopy screening Jan 1 to December 31.
  •  Improvement Activities
    • Most Providers will attest to completing a minimum of 4 improvement activities for at least 90 days.
    • As of the writing of this blog, the CMS tools shows 92 activities to choose from.
    • Activities range from care coordination, patient safety changes and beneficiary engagements.
    • Examples: Join and participate (for a minimum of 6 months) in your States Prescription Monitoring Program (PMP). Or another example: Engage patients, family and caregivers in developing a plan of care and prioritizing their goals for action, documented in the certified EHR technology.
  • Advancing Care Information
    • Use a qualified (certified) product (or products) for a minimum of 90 days.
    • There are two different programs to pick from depending on your Electronic Health Record Software Certification. For 2017, you will be able to use either a 2014 Certified Product (previously called Stage 2 MU Certification) or a 2015 certified product (certified for the MU Final Ruling criteria). Attest to a minimum of:
      • E-Prescribing
      • Provide Patient Access
      • Send Summary of Care Records
      • Receive Summary of Care Records
      • Report up to 9 additional measures for bonus credits
  • Cost
    • No actions required: Cost will be computing from your claims
    • The cost category will be calculated in 2017, but will not be used to determine your payment adjustment. In 2018, CMS will start using the cost category to determine your payment adjustment.

 

Medicare Providers will want to research the programs and decide their level of participation early in 2017. Full year participation would require making sure their Electronic Health Record system is setup for minimal data tracking and other required features like E-Prescribing and Direct Messaging.

 

References

  1. 2017 Program requirements:

    https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/2017ProgramRequirements.html

  2. MIPS and MACRA:

    http://www.impact-advisors.com/meaningful-use/mips-macra-mu-the-next-evolution-of-healthcare-payment-reform/#sthash.vMkVGSvN.dpuf

  3. https://qpp.cms.gov/docs/Quality_Payment_Program_Overview_Fact_Sheet.pdf

  4. MIPS Quality Payment Program Website: 

    https://qpp.cms.gov/measures/performance