AAFP GIVES GUIDANCE FOR HHS STRATEGIC PLAN THROUGH 2022

The US Department of Health and Human Services (HHS) has released a draft strategic plan for fiscal years 2018–2022 and invited stakeholders such as the AAFP to provide feedback. Because the Academy welcomes every opportunity to help guide HHS activities, AAFP Board Chair John Meigs, MD, of Centreville, Alabama, responded on behalf of the AAFP in an October 19, 2017 letter (http://www.aafp.org/content/dam/AAFP/documents/advocacy/legal/administrative/LT-HHS-Draft2018-2022Framework-101917.pdf) to HHS Acting Assistant Secretary John Graham.

The HHS draft plan lays out how the agency will achieve its mission over the course of the next few years through 5 strategic goals—with objectives outlined for each. Those goals, in order, are to:

• Reform, strengthen, and modernize the nation’s health care system

• Protect the health of Americans where they live, learn, work, and play

• Strengthen the economic and social well-being of Americans across their lifespans

• Foster sound, sustained advances in the sciences

• Promote effective and efficient management and stewardship

The AAFP used the bulk of its 7-page letter to respond to an objective for the first goal that touches on the need to reduce administrative regulatory and operations burdens. The AAFP argued that the final strategic plan “must specifically address” the need to reduce those burdens for practicing physicians. “Administrative simplification represents an industry-wide commitment to reducing health care costs by removing unnecessary burdens throughout the compliance, claims and billing processes,” said the AAFP, and the final strategic plan should reflect HHS’ commitment to such.

The AAFP produced a list of priorities and called on HHS to tackle longstanding issues that frustrate family physicians such as prior authorizations, chart documentation, Medicare certification and documentation, electronic health record (EHR) interoperability, interpretation service costs, quality measure harmonization and alignment, and inconsistent claims review.

Regarding prior authorizations, the AAFP noted that “frequent phone calls, faxes and forms (that) physicians and their staffs must manage to obtain prior authorization for an item or service” are obstacles to patient care that are “becoming increasingly common.” Furthermore, prior authorizations “must be justified in terms of financial recovery, cost of administration and workflow burden,” said the AAFP. Among other things, rules and criteria for prior authorization determination “must be transparent and available to the prescribing physician.” In situations of denials for a service or medication, “the reviewing entity should provide the physician with the criteria for denial,” and for medications, alternative choices should be provided.

On chart documentation, the AAFP noted that “documentation burdens have escalated dramatically without relief from adoption of electronic records. Indeed, current electronic record products have only added to that burden.” The AAFP made it clear that “the primary purpose of medical record charting should be to document essential elements of the patient encounters and to communicate that information to other providers.” Further, “the use of templated data and checking boxes should be viewed as administrative work” that does not contribute to the care and well-being of patients.

Regarding Medicare certification and documentation, the AAFP said, “Physicians want to efficiently order what their patients need to manage their disease conditions in a way that maintains their health. Unfortunately, the current procedures surrounding coverage of medical supplies and services impede this goal and add no discernible value to the care of patients.”

Among other points, the AAFP said:

• Physicians’ orders should be sufficient

• Physicians should not have to recertify durable medical equipment supplies annually for patients with chronic conditions

• Authorizations for supplies should be generic so physician don’t need to fill out a new form when patients switch brands

• Authorization forms should be universal across payers

On the topic of EHRs, the AAFP noted that surveys indicate current health IT infrastructure and products are not efficient or effective in supporting practice transformation. “Therefore, all physicians need the national health IT ecosystem to undergo more rapid transformation than has been the case to date,” including systems that provide interoperability, said the AAFP. Physicians also need population management and patient engagement functionalities, and they need a user-centered design. The AAFP urged HHS to “place the burden of compliance on EHR vendors and not on physicians.” Vendors “must be held accountable for the inadequate design and poor performance of their products,” said the letter.

Interpretation service costs have been a burden for physicians since the implementation of new regulations in 2000, and even more so after “new and costly limited English proficiency policies went into effect” on October 17, 2016, said the AAFP. “Family physicians already operate on slim financial margins,” said the letter. “We believe that HHS must fund the increased costs practices will bear to comply with these requirements,” or else the requirement should be eliminated, said the AAFP.

Regarding quality measure harmonization and alignment, the AAFP noted the complexity of family medicine practices and said “family physicians experience a more significant burden when multiple performance measures and quality improvement programs have no standardization or harmonization.” The AAFP urged HHS to “align quality measures as part of their overall approach to reducing administrative burden” and to use the core measure sets developed by the multi-stakeholder Core Quality Measures Collaborative.

The issue of inconsistent claims review has also been a chronic source of irritation to family physicians. The AAFP pointed out that “there are a multitude of post-claims review processes under Medicare alone.” “Within these audit programs, there are a multitude of requirements, appeals processes (if any), differing deadlines and governing agencies. Communications from these entities are not easily understood by busy physicians nor are their deadlines easy to meet,” said the AAFP. The Academy urged HHS to streamline the programs and to “utilize one set of criteria that is universal.”

The AAFP also took advantage of the opportunity in the feedback to make mention of some important work it is undertaking. In reference to HHS’ stated goal to “protect the health of Americans where they live, learn, work and play,” the AAFP noted HHS’ failure to acknowledge the importance of advancing health equity to improve the health of all citizens.

The AAFP then said that as an organization it has “made addressing social determinants of health—as they impact individuals, families and communities across the lifespan and striving for health equity—a strategic priority.” The letter provided a link to the AAFP’s Center for Diversity and Health Equity, http://www.aafp.org/patient-care/social-determinants-of-health/cdhe.html, where HHS can also get further details about a new Academy initiative to advance health equity in all communities dubbed “The EveryONE Project.”

HHS will take recommendations received from the AAFP and others to build on progress made in strategic and performance planning efforts for the future.

• © 2018 Annals of Family Medicine, Inc.