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AAFP Offers Strategies to ONC, CMS to Reduce Regulatory Burden

Suggestions included reducing health IT utilization measures in the MIPS advancing care information performance category.

AAFP recommended ONC and CMS change policy to reduce regulatory burden.

Source: Thinkstock

By Kate Monica

- The American Academy of Family Physicians (AAFP) recently requested CMS and ONC work to reduce regulatory burden to allow clinicians to spend more time interacting face-to-face with patients.

In a letter submitted earlier this month, the academy claimed current regulations and federal requirements are daunting and “often demoralizing” for primary care physicians. AAFP cited a 2017 study showing family physicians spend nearly 6 hours a day interacting with EHR systems as exemplary of the significant burden clinical documentation requirements place on providers.

“In addition to the time burden, 2016 and 2018 studies show that family physicians and other physician experience high cognitive load while working with the EHR,” wrote AAFP.

AAFP also pointed to regulatory burden as being one of the primary reasons independent practices go out of business.

“Despite the good intent of underlying health care policies, the burden on the practicing physician has expanded to an untenable level and is a significant barrier to achieving the Quadruple Aim of enhancing patient experience, improving population health, reducing costs, and improving the work life of clinicians and staff,” wrote the academy.

In an effort to help reduce regulatory burden, AAFP developed consensus principles to ensure patients have timely access to treatment and decrease the likelihood of physician burnout.

“We encourage CMS and ONC to adopt policies and practices consistent with these principles to alleviate unneeded regulatory burdens and to improve patient care,” AAFP stated.

First, AAFP recommended the federal agencies minimize health IT utilization measures in the Merit-Based Incentive Payment System (MIPS) advancing care information (ACI) performance category. 

“Now that MIPS utilizes measures of quality, cost and practice improvement, the AAFP calls for all HIT utilization measures to be eliminated,” wrote AAFP. “Because we recognize that some of these uses are mandated in statute, we urge CMS and ONC to work with Congress to remedy this unfortunate and outdated approach.”

Specifically, AAFP clarified policies that mandate or financially penalize physician health IT use should be analyzed for practical benefit prior to implementation. Additionally, AAFP suggested policies should be designed to meet the varying needs of diverse patient populations to improve care accuracy.

AAFP also recommended CMS eliminate EHR clinical documentation requirements part of the Quality Payment Program (QPP) related to evaluation and management services for primary care physicians.

“The primary purpose of medical record documentation should be to record essential elements of the patient encounter and communicate that information to other providers,” wrote AAFP. “The use of templated data and box-checking should be viewed as administrative work that does not contribute to the care and wellbeing of the patient.”

As part of the effort to ensure EHR clinical documentation is as efficient and effective as possible, AAFP also recommended EHR vendors, physicians, and workflow engineers collaborate to redesign and optimize EHR systems.

Third, AAFP recommended the federal agencies prioritize reducing information blocking and health data exchange when crafting interoperability policy.

“Family physicians receive ‘summaries of care’ (and other Consolidation-Clinical Document Architecture documents) that are filled with clinically irrelevant information and are unnecessarily long,” stated the academy. “Because family physicians must wade through this documentation to find clinically relevant information, physician time becomes more unproductive and cognitively burdensome.”

To reduce the amount of clinically irrelevant data physicians receive in exchange, AAFP recommended CMS and ONC reform requirements to focus on how and when data is exchanged rather than the kind of data being exchanged.

“Policies should be focused on “pulling” interoperability by aligning financial incentives, such that interoperability is good business,” wrote AAFP.

The academy also emphasized the need to improve standard representation of clinical data models, streamline prior authorization, and align quality measures with improved patient health outcomes.

 “Most of the measures are disease-specific process measures, rather than more meaningful evidence-based outcomes measures,” stated AAFP.

“Quality measures should be focused on improving processes and outcomes of care in terms that matter to patients,” the academy emphasized.  

In closing, AAFP emphasized the need to streamline authorization for obtaining medical supplies.

These recommendations are intended to assist CMS and ONC in reducing clinician burden as part of the Patients Over Paperwork initiative.



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