Government Relations Committee Shines Light on Red Tape

Aug 31, 2019

By Sean Lyden, MD and Matthew Mell, MDSVS Government Relations Committee

The Centers for Medicare and Medicaid Services (CMS) and the Office of the National Coordinator for Health Information Technology (ONC) are working to address the burden regarding the use of health IT and electronic health records in physician’s practices. Per its Request for Information; Reducing Administrative Burden to Put Patients Over Paperwork (CMS-6082-NC), CMS is seeking innovative ideas that broaden perspectives on potential solutions to relieve burden and ways to improve:

Reporting and documentation requirementsCoding and documentation requirements for Medicare or Medicaid paymentPrior Authorization for proceduresPolicies and requirements for rural providers, clinicians and beneficiariePolicies and requirements for dually eligible (i.e., Medicare and Medicaid) beneficiariesBeneficiary enrollment and eligibility determinationCMS processes for issuing regulation and policies

The SVS, Society for Clinical Vascular Surgery, Vascular and Endovascular Surgery Society and the Association of Program Directors in Vascular Surgery and regional vascular surgical societies (Southern, Midwestern, New England, Eastern and Western) endorsed a set of proposed solutions that CMS and ONC may consider to address the regulatory administrative burden of IT and EHRs at part of their Strategy on Reducing Regulatory and Administrative Burden Relating to the Use of Health IT and EHRs. These recommendations were communicated to CMS on Jan. 19, 2019 in response to their proposed rule.

The communication also referenced a 2018 survey of 872 practicing vascular surgeons, noting that 30 percent of respondents met established criteria for burnout with 8 percent reporting suicidal thoughts during the preceding 12 months. The letter {put in link to SVS Letter} noted that electronic medical record documentation requirements were significantly associated with, and likely a significant contributor to, burnout. Additionally, surgeon participants of Wellness Focus Groups at the 2018 Vascular Annual Meeting identified EHRs as one of the most significant stressors of clinical practice. Current extensive requirements for documentation coupled with the unwieldly and time-consuming EHR platforms has decreased physician-patient time, resulting in a public health crisis.   

Specific recommendations to CMS included:

Development of metrics, measures and standards to improve the physician experience and decrease time spent on EHR documentation. These actions must be performed with full physician collaboration including vascular surgeons who remain at particular risk to EMR-related emotional exhaustion.Development of better interoperability of EHRs; all systems should be required to have a standardized import/ export function.Integration of Prescription Monitoring Programs into all EHRs.Development of documentation of patient encounters that is based on practice. The history, problem list, review of systems and physical exam should be specialty-specific. For vascular surgery, these guidelines and requirements should be set in coordination with the SVS.Requirement that each EHR vendor continuously consult clinicians from all essential medical and surgical specialties. This could be achieved by either submitting to each major clinical society or by nationally (or each state/ region) developing a team of clinician advisors from each specialty to review new EHRs. This team should include not only practicing physicians, but also residents, physician assistants and nurse practitioners who also regularly interact with the EHR.Requirement that health insurance agencies facilitate automatic authorization through communication with EHRs.Standardization of effective and efficient physician training and support for EHR instead of requiring purchase of specific “support package” by a health care organization.Development of quality measures that are universal across all payers.

Similarly, we are informing congressional leaders and CMS of the burden on our practices for prior authorization of imaging, surgical services and interventional procedures. In these and other efforts, we will work diligently to inform our government of the issues SVS members face and hope to lead to change in the administrative burden required for our care of Medicare and Medicaid patients.

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