Knowledge Base Article

PATIENTS OVER PAPERWORK INITIATIVE

CMS launched the “Patients over Paperwork” initiative in October 2017. This initiative allowed CMS to establish “an internal process to evaluate and streamline regulations with a goal to reduce unnecessary burden, to increase efficiencies, and to improve the beneficiary experience.” CMS is keeping stakeholders informed through information posted to the Patients Over Paperwork webpage as well as Newsletters highlighting ongoing efforts towards meeting their goal.  

July 2018 Newsletter

CMS posted the July 2018 Newsletter this past week making it the 6th Edition. This newsletter:

• Provides updates on how CMS is addressing Skilled Nursing Facility/Nursing Home burden.
• Describes how CMS is simplifying documentation requirements.
• Provides an update on where CMS is meeting with stakeholders to discuss burden.
• Reminds stakeholders about opportunities to provide feedback through requests for information from CMS.

Today, we delve into the specifics about reducing SNF/Nursing Home Burden and Opportunities for Providing Feedback to CMS

Addressing Skilled Nursing Facility/Nursing Home Burden

After what is described as spending hundreds of hours reviewing information, CMS indicates they listened, learned and acted.

• Listen: In response to Requests for Information (RFI) in 2017, CMS received 154 comments on burden related to the nursing home experience. In addition to soliciting comments and to capture customer perspectives CMS spoke with 93 people during visits to 3 nursing homes and hosted 22 listening sessions around the country.
• Learn: CMS found that Comments received from RFIs grouped into 9 themes. The themes were then grouped together and 15 actions that could be taken to address burden were identified. As a product of the site visits, CMS designed a Nursing Home Journey map depicting residents, families, and staff interaction in a nursing home.
• Action: One example provided in the newsletter are the changes being proposed in the Skilled Nursing Facility Prospective Payment System (SNF PPS) FY 2019 Proposed Rule. CMS highlights a proposed new case-mix model, Patient-Driven Payment Model (PDPM) “which would move Medicare towards a more unified post-acute payment system that better accounts for resident characteristics and unique care needs of the patients while also reducing significantly the administrative burden associated with SNF PPS.” They also highlight the proposal of a new factor to account for costs associated with a measure when evaluating measures for removal from the SNF Quality Reporting Program (QRP) measure set.

OPPORTUNITY TO PROVIDE FEEDBACK TO CMS

Medicare Physician Fee Schedule (MPFS) and Quality Payment Program

CMS touts in this newsletter the proposals being made are “historic” and if finalized,
“clinicians would see a significant increase in productivity – leading to substantially more and better care provided to their patients.” In addition to clinicians there are several proposed revisions that could affect hospitals. A discussion of these proposals can be found in a related FAQ. Public comments must be received no later than 5 p.m. on September 10, 2018.

Stark Law

Through the RFI process CMS identified compliance with the Stark Law and its accompanying regulations as being a top area of burden. CMS is requesting input on several issues with the Law and “is particularly interested in the public’s input on the structure arrangements between parties that participate in alternative payment models or other novel financial arrangements, the need for revisions or additions to exceptions to the physician self-referral law, and terminology related to alternative payment models and the physician self-referral law.”

The comment period ends August 24, 2018. The RFI can be downloaded at https://www.federalregister.gov/documents/2018/06/25/2018-13529/medicare-program-request-for-information-regarding-the-physician-self-referral-law.

In addition to the MPFS Proposed Rule and Stark Law RFI, CMS lists several 2019 Proposed Rules aiming to reduce burden and provides links to the individual Proposed Rule and Fact Sheets. MMP strongly encourages you to review relevant proposed rules and provide comments.