It is widely agreed that the transition to value-based care requires the fuller engagement of patients and their caregivers to improve outcomes and lower costs. Data shows that when patients play bigger roles in their treatment, providers can better coordinate care and, therefore, lower costs and improve outcomes. Furthermore, engaging patients outside of the hospital and clinic walls increases patient loyalty and satisfaction.
With GetWell Loop, we’ve seen the benefits of actively engaging patients in their care, from lower readmission and complication rates to improved care team efficiency. Now, the Centers for Medicare and Medicaid Services (CMS) is beginning to view patient engagement as a fundamental component of healthcare as the agency continues shifting Medicare payments from volume to value.
CMS recently announced it will reimburse physicians for using remote monitoring technologies beginning next year. With the release of the 2018 Quality Payment Program Final Rule, the agency has further demonstrated its commitment to patient engagement to achieve better care, lower spending, and healthier people.
Improving MIPS Improvement Activities
As a practicing physician, one of my passions is informing national policy makers about opportunities for the smarter and more cost-effective design and practice of medicine. Through a long-standing relationship with leaders at CMS, I had an opportunity to meet at their offices last year to discuss how patient-generated health data (PGHD) could drive quality improvement.
As a result of those discussions, I became much more familiar with the various measures under the Quality Payment Program’s Merit-Based Incentive Payment System (MIPS). Under MIPS, clinicians earn a payment adjustment (up to +/- 9% by 2022) based on evidence-based and practice-specific quality measures. Three of the four reporting categories under MIPS – Quality, Advancing Care Information and Cost – replace legacy programs. The fourth category, Clinical Practice Improvement Activities, is new.
The Clinical Practice Improvement Activity category focuses on rewarding innovation and improvement activities that center around things such as care coordination, engaging beneficiaries, patient safety, expanding patient access and population management. As in 2017, this category is worth 15% of the total MIPS score in 2018.
As I reviewed the more than 90 Improvement Activities, however, I noticed that there wasn’t an activity that captured the essence of patient engagement – leveraging digital tools for ongoing guidance and assessments outside the clinic, including the collection and use of PGHD. The closest existing Improvement Activities were related to the use of a Qualified Clinical Data Registry (QCDR) to capture patient health data. While valuable, merely collecting medical and/or clinical data through a QCDR for the purposes of improvement in the quality of care is a far cry from engaging with patients outside of the care setting through contextual guidance, and an active feedback loop.
When I described GetWell Loop’s use case to my CMS colleagues, they suggested I submit a proposal during the MIPS Annual Call for Measures and Activities. In collaboration with colleagues at two other companies doing excellent work in patient engagement, we authored and submitted a proposal in February 2017 to add a patient engagement measure to the Improvement Activity category under MIPS.
CMS greenlights patient engagement Improvement Activity
We were pleased to learn first that the submitted Improvement Activity was included in the Proposed Rule which became available for public comment this past summer. After the public comment period ended, we were thrilled to see our proposed Improvement Activity added to the Final Rule with a weighting of “High,” and lovingly referred to as IA_BE_14 on page 1621 in the Federal Register.
Essentially, the Improvement Activity emphasizes the importance of engaging “patients and families to guide improvement in the system of care by leveraging digital tools for ongoing guidance and assessments outside the encounter.” It goes on to indicate that “Platforms and devices that collect patient-generated health data (PGHD) must do so with an active feedback loop, either providing PGHD in real or near-real time to the care team, or generating clinically endorsed real or near-real time automated feedback to the patient, including patient reported outcome measures (PROMs). Examples include patient engagement and outcomes tracking platforms, cellular or web-enabled bi-directional systems, and other devices that transmit clinically valid objective and subjective data back to care teams. Because many consumer-grade devices capture PGHD (for example, wellness devices), platforms or devices eligible for this improvement activity must be, at a minimum, endorsed and offered clinically by care teams to patients…”
Clearly, both CMS and the public shared the vision that activating patients in their care and keeping physicians and patients in contact through the appropriate sharing of PGHD was valuable. Further, because the new patient engagement Improvement Activity has a high weight, it’s worth 20 points toward the 60 points required for full participation in this category. High-weighted measures represent more comprehensive practice transformation activities than medium-weighted measures, which are worth 10 points each. The measure is also one of the Improvement Activities that earns providers 10 bonus points in the Advancing Care Information category.
A win for patient engagement reimbursement
The new rule is an important step forward for physicians and patients using digital engagement tools. For clinicians already using a patient engagement platform, these efforts will help satisfy the Improvement Activities category and earn 10 Advancing Care Information bonus points. Eligible clinicians must simply attest to completing the activity for at least 90 days to meet 2018 reporting requirements.
Financial incentives aside, engaging with patients is the right thing to do. Practices using automated patient engagement solutions like GetWell Loop see reduced readmission and complication rates, lower call center volume, better online ratings for physicians and, most important, happier, healthier patients.
The era of value-based reimbursement has begun. Through financial incentives and penalties around patient engagement, CMS has laid the groundwork for high-quality care delivery systems to bring the patient into the care team to improve outcomes and lower costs. The result is a win-win-win for patients, healthcare providers, and the healthcare system at large.