services, there is very little value
added in terms of improved quality
and lower costs. Therefore, we recommended that CMS use its waiver
authority as broadly as possible
and exempt those participating in
value-based arrangements from
the AUC program.
CMS has made progress toward
focusing quality measures on
holding providers accountable for
patient health outcomes and ensuring quality measures are important
to providers and patients under
the Meaningful Measures Initiative.
However, in our letter to the agency,
we argued that there is still a need
to focus on quality measurement,
as current quality reporting continues to be a burden on providers. Our
member groups invest considerable
time and effort in quality reporting
that adds little value or benefit but
takes many resources away from
their ability to provide high-quality
care. For example, a 2017 AMGA
Consulting survey found that for
every 100 physicians our members
employ, 17 information technology
(IT) professionals were needed to
support them. These costs are
better spent on caring for patients,
not maintaining an expensive IT
infrastructure. For this reason,
we stated that CMS should reduce
the number of quality measures
for all value-based providers and
move to a more outcomes-based
system supported by claims data.
Additionally, using a standard set
of value measures will help reduce
the variation in the measures that
are reported and help eliminate
unnecessary confusion and administrative burden.
We highlighted the 14 quality
measures that AMGA’s Board of
Directors endorsed in 2018 (see
“AMGA Quality Measures”). The
14 measures were selected to
address flaws with the current
quality measurement and reporting
system, which suffers from duplicative measures and a lack of data
standardization. Our board members believe these measures, which
are a mix of process and outcome
measures, are clinically meaningful to both patients and providers
and will lead to a more simple and
cost-reducing quality measurement
Requirements for DMEPOS
Chapter 5 of the Medicare Program
Integrity Manual requires a detailed
written order (DWO) for non-drug
DMEPOS to include the physician
or practitioner signature. Based on
this requirement, National and Local
Coverage Determinations require
that a physician complete and sign
a DWO for DMEPOS items, including
diabetes test strips. This signature
requirement for diabetes supplies
can create needless delays and
confusion about the regulations.
It also precludes provider organizations from including diabetes
testing strips in a standing order.
We proposed that CMS reduce these
documentation requirements, as the
rationale for the signature requirements is not commensurate with the
administrative burden it creates for
AMGA’s members, their patients, or
their DMEPOS supplier partners.
for Physician Signature
for Home Health Services
Currently, a physician signature
is required in order for a patient
to receive home health services.
Even when a nurse practitioner
(NP) or physician assistant (PA) is
the primary clinician caring for the
patient, these practitioners must
seek approval from a physician.
In our comments, we argued that
while this requirement may have
served an important purpose by
ensuring appropriate referrals or
reducing the potential for fraud and
abuse, requiring a physician signa-
ture creates a massive burden for
physicians with little value added
and can lead to care delays for
patients. As such, we asked CMS
to use its authority to waive the
physician signature requirement.
Our member groups practice care
in a team-based environment and
non-physician practitioners are a
part of this care process. Allowing
NPs and PAs to complete these
orders will contribute to the goals
of team-based care, reduce strain
on physicians, and ensure that
patients receive the right care at
the right time.
Burden to Aid Providers
in the Transition to Value
CMS has taken steps to reduce
provider burden through its Patients
over Paperwork initiative. The
positions we laid out in our comments to the agency will aid our
members as they provide care to
their patients, since unnecessary
regulations become superfluous in
a value-based system where providers are already incented to provide
the right care at the right time.
Emma Achola is coordinator, regulatory
affairs, at AMGA.
1. CMS News. 2019. CMS Seeks Public Input on Patients over Paperwork Initiative
to Further Reduce Administrative, Regulatory Burden to Lower Healthcare Costs.
June 6, 2019.