The Journal of the Arkansas Medical Society Issue 11 Vol 114 | Page 7

indicate that there will always be losers. If we are “If you are going to hold providers account- measured relative to our peers and split into quar- able on the tail-end (threat of reduced reimburse- tiles, there will always be relatively low performers, ment if not performing well re: cost and quality) then thus there will always be penalties, no matter the the reasonable trade-off should be removal of the level at which the entire pack is performing. If the onerous process of prior authorization on the front- goal is to increase overall quality, why not decide on end. Failure to do so is the health care analogy of a reasonable standard to which the program might double-jeopardy: requiring us to deal with adminis- aspire to raise the quality bar, and reward all pro- trative headaches and paying someone in our offices viders who perform above the mark? As planned, if to jump through hoops on the front end, then being there were a theoretical situation in which all provid- penalized on the tail end with lower reimbursement.” ers were providing a high level of Threat to Primary Care. “Val- care, there would still be providers ue-based programs should bolster who would be penalized despite primary care, not present a threat to their collectively high level of per- them.  The threat of narrowing the formance. I would suggest that set- already thin margins under which ting a mark of acceptable perfor- many of our rural primary care phy- mance (above which there would sicians operate does not incentivize be no penalty) would be a way to improvement as much as it presents raise quality while allowing for the a threat to practice viability. I be- (albeit unlikely) scenario in which lieve that the constantly rising cost all providers could avoid penalty issues being faced by BCBS ARE if meeting an acceptable level of NOT significantly impacted by the Lonnie Robinson, MD, performance. This approach has habits of primary care providers … FAAFP already been utilized successfully we are not the ‘big spenders’ in this with the pattern seen in APII, both for the Episodes situation. And yet my colleagues feel this initiative of Care and PCMH programs, in which BCBS al- is targeting the physicians who bring more value to ready participates. It is my understanding that the the table than any other specialty. As you probably only way to continue to receive the traditional/his- know, despite all its short-comings, FFS income toric rate of reimbursement from BCBS is to be a top continues to be the ‘bread and butter’ of primary performer. This is quite concerning, since the costs care practices, since we are charged with providing involved in clinical practice for all providers have not E/M-dependent care to our populations, rather than decreased and are, in fact, rising.” procedures and surgeries.  No Relief of Administrative Burden (Prior Authorization). “As you present VBCI as a way for BCBS to gain control of rising costs, the administra- tive burden on practices continues to rise as well. We have already had discussions about removal of prior authorization and other utilization-management strategies employed by payers that present an ex- cessive administrative burden for practices as we move increasingly away from FFS, and I have heard the argument by BCBS that studies demonstrate a rise in utilization with removal of the PA process. I would argue that none of those studies took place in an environment in which providers were ultimately held accountable for both quality (adherence to Choosing Wisely and other guidelines) and cost.  “The AAFP agrees with me … in their Prin- ciples for Administrative Simplification, they state:  ‘Physicians strive to deliver high-quality medical care in an efficient manner. The frequent phone calls, faxes, and forms physicians and their staff must manage to obtain prior authorizations (PAs) … impede this goal.’ and ‘PA for imaging services should be eliminated for physicians with aligned financial incentives (e.g. shared savings, etc.) and proven successful stewardship.’ ” “As Kent Moore, senior strategy analyst for the AAFP recently said, ‘While payment is mov- ing toward value-based care, fee-for-service (FFS) remains the dominant method of payment. Family physicians provide high quality, cost-effective care but are financially dependent on the thin margins associated with current FFS payments to pay for the increased administrative and clinical personnel needed to transition to and be successful in value based contracts. To reduce payment in any amount for the services done by primary care physicians is detrimental to their ability to provide high-quality, low-cost care in the current FFS care environment.’  An initiative that seeks to decrease reimbursement in such a manner (i.e., there will always be losers) is a threat to primary care practice viability. Unfor- tunately, those who are most vulnerable are going to be those in small practices in rural parts of our state, and this represents a significant portion of the Arkansas primary care workforce.” Alignment. “We are bombarded with new pro- grams and new ways in which we are measured. We have literally dozens of disparate quality metrics by which we are evaluated. What reassurance do we have that there will be near-perfect alignment with On a quarterly basis, 100 percent of the value pool funds will be distributed to providers based upon a set of value-based performance metrics using the most recent and available 12-month performance period, which will roll forward every quarter. existing programs (CPC+, PCMH, MIPS, etc.)?  All of the programs have some measures in common, but there are always some/many that are different.  This too, creates additional administrative burden the practice must bear [while] at the same time figur- ing out a way to staff adequately despite declining reimbursement.  “According to the AAFP Principles for Admin- istrative Simplification, ‘Quality measures have proliferated in the past 15 years, leading to a sig- nificant compliance burden for physicians. Most of the measures are disease-specific process measures, rather than more meaningful evidence- based outcomes measures. With many family phy- sicians submitting claims to more than 10 payers, the adoption of a single set of quality measures across all public and private payers is critical,’ and similarly, ‘All payers … should implement the core measure sets developed by the multi-stakeholder Core Quality Measures Collaborative to ensure par- simony, alignment, harmonization, and the avoid- ance of competing quality measures.’ ” Data. “Every program in which we participate has a secure website at which we may obtain ac- cess to our performance data. Every one of those sites requires a secure password and often asks us to change that quarterly. The CMS CPC+ portal takes me at least five minutes to login and get to the in- formation I need. The AHIN site makes me change my password often, I typically don’t have ready ac- cess when I need it. Same story with the Arkansas PDMP. I know that there will be a similar process for this program, one that presents data in the way YOU want me to see it, not necessarily in the way I need to have it. I don’t really need another login. If we are being asked (forced?) to participate in a program such as VBCI, real data access and transparency is a must. Additionally, we need the opportunity and a reasonable period of time in which to review and validate the data by which we are being measured before the financial implications are applied. I have NUMBER 11 > Continued on page 248 MAY 2018 • 247