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The overall goal of Merit-based Incentive Program System (MIPS) performance activities is to improve clinical practices and the healthcare delivery model. The hope is that the performance activities will result in improved health outcomes, engage and support patients in the treatment process, promote more clinically relevant evidence for patients, and provide greater transparency. Below are a few recommendations I developed how to achieve MIPS performance activity requirements through the use of Telemedicine.

Activity Name: Provide 24/7 Access to MIPS Eligible Clinicians or Group Who Have Real-Time Access to Patient’s Medical Record.

Activity Description: Provide 24/7 access to MIPS eligible clinicians, groups, or care teams for advice about urgent and emergent care (e.g., MIPS eligible clinician and care team access to medical record, cross-coverage with access to medical record, or protocol-driven nurse line with access to medical record) that could include one or more of the following:

· Expanded hours in evenings and weekends with access to the patient medical record (e.g., coordinate with small practices to provide alternate hour office visits and urgent care);

· Use of alternatives to increase access to care team by MIPS eligible clinicians and groups, such as e-visits, phone visits, group visits, home visits and alternate locations (e.g., senior centers and assisted living centers); and/or

· Provision of same-day or next-day access to a consistent MIPS eligible clinician, group or care team when needed for urgent care or transition management.

Proposed workflows:

· Telemedicine visits are an alternative method of increasing access to the care team. A few examples are:

1. A care manager can meet with his/her patient weekly, bi-weekly, or monthly to follow up on their progress. Patient engagement is vital in improving health outcomes.

2. An eligible clinician can meet with a patient and his/her caregiver to discuss treatment progress and treatment options. Additionally, this will allow the patient to ask the eligible clinician detailed questions regarding their treatment plan, diagnosis, referrals, education, etc.

3. A behavioral health counselor can meet with his/her patient weekly, bi-weekly, or monthly to follow up with the patient on his/her status.

· This method also enables patients to have family members (i.e. children, parent, caregiver, etc.) participate in their medical treatment process.

· Once the telemedicine visit is documented, whether on the telemedicine platform and/or in the Electronic Medical Record (EMR), the patient will have real-time access to their visit information and discussion on their patient portal or on the telemedicine platform.

· A policy and procedure should be created for the workflows above.
Activity Name: Use of telehealth services that expand practice access.
Activity Description: Use of telehealth services and analysis of data for quality improvement, such as participation in remote specialty care consults or teleaudiology pilots that assess ability to still deliver quality care to patients.

Proposed workflows:

· Due to COVID-19, expanding practice access has become critical for delivery of healthcare services. Telehealth services allows patients to gain access to acute, chronic, primary, and specialty care. This model is very essential for patients that live in rural areas to connect to specialty physicians (i.e. dermatologist; psychiatrist; pulmonologist, etc.) that may not practice in their community. Patients can connect to telehealth via a computer, iPad, laptop, or smartphone.

· A policy and procedure should be created for the workflows above.
Activity Name: Advance Care Planning
Activity Description: Implementation of practices/processes to develop advance care planning that includes: documenting the advance care plan or living will within the medical record, educating clinicians about advance care planning motivating them to address advance care planning needs of their patients, and how these needs can translate into quality improvement, educating clinicians on approaches and barriers to talking to patients about end-of-life and palliative care needs and ways to manage its documentation, as well as informing clinicians of the healthcare policy side of advance care planning.

Proposed workflows:

· Advance care planning has become more significant due to COVID-19. Advance care planning enables patients to have their wishes documented and have end-of-life wishes discussion. Among the uncertainty of the COVID-19, these discussions are critical for families to have, and not knowing how to navigate advance care planning can be difficult for patients and their families. With the use of telemedicine, clinicians, patients, and/or caregivers can meet via telemedicine to have the discussion about the purpose, need, benefits, etc. of advance care planning. Advance care planning discussions should be documented on the telemedicine platform and/or in the patient’s Electronic Medical Record.

· The information once documented can be available to patients via their patient portal and/or the telemedicine platform.
· The proper MOLST, Living Will, or other advance care plan document(s) should be completed and uploaded into the patient’s EMR.

· A policy and procedure should be created for the workflows above.
Activity Name: Regularly assess the patient experience of care through surveys, advisory councils and/or other mechanisms.

Activity Description: Regularly assess the patient experience of care through surveys, advisory councils and/or other mechanisms.

Proposed workflows/process:

· Due to COVID-19, social distancing restrictions, patient experience of care can be gathered through a telemedicine meeting, such as an advisory council. This can be performed through other means, such as having a survey designed as a pre-questionnaire before the patients participate in the telemedicine meeting discussion. Through the pre-questionnaire the organization can assess the patients’ comments/feedback to identify trends, benefits, disadvantages, etc. Then the facilitator of the telemedicine meeting can use the trends identified from the pre-questionnaire to drive the telemedicine discussion as part of advisory council.

· A policy and procedure should be created for the workflows above.
Activity Name: Use group visits for common chronic conditions (e.g., diabetes).
Activity Description: Use group visits for common chronic conditions (e.g., diabetes).

Proposed workflows/process:

· Due to COVID-19, having an in-person group visit can be challenging due to the cleaning and social distancing requirement. Through the utilization of telemedicine; clinicians, care managers, diabetics educators, etc. can meet with patients that share the same chronic conditions such as diabetes, hypertension, depression, etc. This method gives clinicians an effective and efficient method to coach, support, and manage their patients’ treatment and progress that share common chronic conditions via telemedicine.

· A policy and procedure should be created for the workflow above.

Remember that for every performance activity that you are implementing, it must be performed for a minimum of 90 consecutive days during the performance period!

Kowsilliya Ramnaresh is the Vice President of Operations at Simply Speak and has over 15 years of healthcare experience, focusing on physician relationships and Informatics. Prior to joining Simply Speak, Dr. Ramnaresh was AVP of Innovation at Health Quest, where she managed the Cerner Ambulatory implementation. Dr. Ramnaresh holds a PhD in Information System Studies, a Masters in Healthcare Administration, and a dual bachelor’s degree in Healthcare Administration and Health Information Management, all from Long Island University/C.W. Post.

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