The Dear Doctor letter posted on July 17th by Seema Verma, CMS Administrator, has sparked some clear responses from the healthcare community. Interestingly, little feedback from the FQHC world has been heard up to this point.
The letter outlines adopting more of a “patient first” philosophy by changing E&M documentation requirements and promoting EMR interoperability with the goal of placing more health information in the hands of patients and providers.
Verma's letter and the July 12th CMS release discussing proposed changes to "modernize Medicare and restore the doctor-patient relationship" are a continuation of this administration's "Patients Over Paperwork" initiative (launched last year). Additional topics discussed include the promotion of telemedicine, lowering drug costs, and changes to MIPS/MACRA.
Although it might not be obvious on the surface, the proposed changes of the "Patients Over Paperwork" initiative could very well have far-reaching effects in the FQHC world, affecting reimbursements, quality programs, and more.
Some things to consider:
While FQHCs are not required to follow MACRA, Congress is on the record stating they would like to consider this program as part of health center requirements.
Many in the FQHC world overlook the importance of E&M coding requirements, as the reimbursement model differs from traditional outpatient care. However, these levels of care and cost are considered in forecasting cost and grant distributions, thus affect the health center world universally. Additionally, changes to E&M requirements may mean you'll need to review your existing templates and notes.
Health centers often have patient portals that are not working adequately and under-utilized by patients. Most of the centers we come into contact with have this item on their yearly "to-do" list, so now might be an ideal time to focus on making necessary improvements.
While health center guidance comes directly from HRSA and not CMS, we recommend that you stay ahead of the curve by keeping abreast of developments in this area.
Chuck Hutchings is the Director Healthcare Operations & Strategy at RDI.
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