Patient engagement and patient satisfaction have been a core principle of healthcare reform under ACA and MACRA. The Centers for Medicare and Medicaid Services (CMS) recently released for public comment its proposed physician-patient relationship categories, a first step toward a Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requirement that the agency establish classification code sets for such physician-patient relationships. The patient relationship categories and codes are intended to help CMS more effectively measure resource use, a major performance category under the Merit-based Incentive Payment System (MIPS). The patient relationship categories and codes also could be utilized through alternative payment models (APMs).
The public comment on the draft category list is due August, 15 2016. As far as next steps, CMS has a statutory timeframe to release a list of proposed codes by November 9, 2016. Following a public comment period for the proposed codes, an operational list of groups and codes will be available by Dec. 14, 2017. See a timeline on page 7 of the announcement.
By developing patient relationship categories and codes for the new MACRA quality pathways, CMS is better able to accurately hold physicians responsible for care that can be attributed to themselves. Because this is a new endeavor for CMS, the agency used five policy principles to determine the patient relationships and ensure that it is appropriately considering the role of the physicians and practitioners in patient care and to determine accurate resource use measurements:
- Develop a clear, simple classification code set to identify patient relationship categories that define and distinguish the different relationships and responsibilities physicians and practitioners have with a patient at the time of furnishing an item or service.
- Ensure that the majority of clinician relationships are captured with the patient relationship codes.
- Ensure flexibility in and ease of submission of codes as part of claims, reflecting that the relationship a clinician has with a given patient may change depending on the clinical situation.
- Ensure that CMS is open and transparent during the development of patient relationship categories and codes and educate clinicians on the intent and use of the categories and codes.
- Enable accurate and effective resource use measurement.
The proposed categories, excerpted from the announcement, include:
Continuing Care Relationships: The clinician who is the primary health care provider responsible for providing or coordinating the ongoing care of the patient for chronic and acute care. Examples include but are not limited to: Primary care physician providing annual physical examination (outpatient); geriatrician caring for resident (Nursing Home); nurse practitioner – providing checkups to adult asthma patient (outpatient).
This can also be the clinician who provides continuing specialized chronic care to the patient. Examples include but are not limited to: Endocrinologist (inpatient or outpatient) treating a diabetes patient; cardiologist for arrhythmia; oncologist (inpatient or outpatient) furnishing chemotherapy or radiation oncology
Acute Care Relationships: Clinician who takes responsibility for providing or coordinating the overall health care of the patient during an acute episode. Examples include but are not limited to: Hospitalist caring for a stroke patient (inpatient); gastroenterologist performing a colonoscopy (outpatient ambulatory surgery); Orthopedist performing a hip replacement; urgent care practitioner caring for a patient with the flu (ambulatory); emergency room physician assistant treating a motor vehicle accident patient (outpatient), attending at a Long Term Care Hospital or Inpatient Rehabilitation Facility.
Additionally, clinicians who are a consultant during the acute episode. Examples include but are not limited to: Infectious disease specialist treating a patient for sepsis or shingles; gastroenterologist performing an upper endoscopy on a hospitalized patient (inpatient); rheumatologist performing an evaluation of an acutely swollen joint upon referral by a primary care physician; dietician providing nutritional support to an Intensive Care Unit patient (inpatient).
Acute Care or Continuing Care Relationship: This includes clinicians who furnish care to the patient only as ordered by another clinician. Examples: Non-patient facing Clinicians such as pathologists, radiologist, and other practitioners who care for patient in specific situations ordered by a clinician but have very little or no relationship with a patient.
In the announcement, CMS solicits comment on these relationship categories and a series of other issues related to their development – like how to capture relationships of doctors in Skilled Nursing Facility or Long Term Care settings, for example. See a full list of topics for which CMS seeks comment on page 5 of the announcement.