On June 6, the Centers for Medicare & Medicaid Services (CMS) released a request for information (RFI) seeking new input from stakeholders related to the continued momentum behind its Patients Over Paperwork initiative. CMS and the Office of the National Coordinator for Health IT (ONC) began work on this initiative in 2017. It seeks ways to mitigate the regulatory, administrative, reporting and documentation burdens that contribute to clinician activity that does not serve patient interests, does not improve quality or safety, or regardless of intent, is highly inefficient. This burden has also proven to be a major contributing factor that dilutes the value of the patient-clinician experience and overarching relationship.
CMS’s RFI is looking for input from all health care community stakeholders, including patients, their families, and caregivers. This new RFI provides an opportunity to share innovative ideas not put forward during the first Patients over Paperwork RFI in 2017. CMS is especially seeking novel ideas that broaden perspectives on potential solutions to relieve burden and ways to improve:
- Modification or streamlining of reporting requirements, documentation requirements, or processes to monitor compliance to CMS rules and regulations
- Aligning of Medicare, Medicaid, and other payer coding, payment, and documentation requirements, and processes
- Enabling of operational flexibility, feedback mechanisms and data sharing that would enhance patient care, support the clinician-patient relationship and facilitate individual preferences
- New recommendations regarding when and how CMS issues regulations and policies and how CMS can simplify rules and policies for beneficiaries, clinicians and providers
CMS is particularly interested in recommendations on how the agency could:
- Improve the accessibility and presentation of CMS requirements for quality reporting, coverage, documentation, or prior-authorization
- Address specific policies or requirements that are overly burdensome, not achievable, or cause unintended consequences in a rural setting
- Clarify or simplify regulations or operations that pose challenges for beneficiaries dually enrolled in both Medicare and Medicaid and those who care for such beneficiaries
- Simplify beneficiary enrollment and eligibility determination across programs
CMS is requesting that respondents provide complete, clear and concise comments that include, where practicable, data as well as specific examples.
Earlier in 2019, HIMSS and Association of Medical Directors of Information Systems (AMDIS) collaborated to respond to CMS and ONC’s Strategy on Reducing Burden Relating to the Use of Health IT and EHRs. HIMSS and AMDIS offered feedback that focused on ideas to help reduce the burdens placed on clinicians – as time and attention clinicians spend on burden resolution is time and attention diverted from patient care.
The HIMSS and AMDIS letter emphasized that clinicians should be able to focus their time on actions that make sense, such as caring for patients and delivering better outcomes. Overall, we want to help the agencies reduce burden so that practitioners can deliver better and more efficient care.
Our organizations expressed interest in pushing for the continued development of demonstration and pilot programs to test different value-based service delivery and alternative payment models (APMs) in order to study the most prominent factors that mitigate clinician burden as well as how other care settings and clinicians can emulate those advances. We noted that any action to shift toward value-based care should be made with the goal of avoiding new and different types of burden.
While the CMS and ONC Strategy Document was consistent with the requirements of the 21st Century Cures Act, HIMSS and AMDIS asserted the importance of health IT tools in resolving any burden-related issues in our healthcare system. HIMSS and AMDIS described how – when properly designed and utilized – health IT can reduce the burden associated with documentation, administrative functions and regulatory compliance.
Moreover, full alignment of documentation and workflow requirements centers on burden reduction, and value improvement – for the patient, the clinician, as well as the healthcare delivery system as a whole. HIMSS and AMDIS want the healthcare community to evolve toward a system where clinicians can focus on documenting information and constructing workflows around delivering better care and more positive patient outcomes, rather than superior Current Procedures Terminology (CPT) or evaluation/management (E/M) coding. To implement such a system, we recommended the creation of several resources to help demystify documentation requirements as well as how they relate to coverage and reimbursement decisions.
HIMSS and AMDIS also recommended that the Department of Health and Human Services (HHS) make a strategic research investment to study how artificial intelligence can help relieve clinician burden issues. We noted that the healthcare enterprise is primed for greater use of AI technologies to improve care processes and deliver more effective care to patients resulting in optimal outcomes, all while reducing the burden that many current documentation requirements place on clinicians.
Comments on the new RFI are due on August 12. HIMSS is planning to collaborate with AMDIS again in developing an RFI submission and is currently reviewing these proposed policies in further detail to add to our previous work on this topic.
HIMSS Government Relations
The HIMSS policy team works closely with the U.S. Congress, federal decision makers, state legislatures and governments, and other organizations to recommend policy, and legislative and regulatory solutions to improve health through information and technology.