Resources

POSTED: January 18th, 2019
POSTED IN: Forum Topic, HHS and CMS Updates, Resources,

ACEP Comments on HHS Request for Information on Social Risk Factors
On November 16, ACEP responded to a request for information (RFI) put out by the Department of Health and Human Services (HHS) that seeks input on how health care providers and health plans are working to improve care for Medicare patients with social risk factors. In our comments, ACEP states that we are committed to improving the quality of care that is delivered to all our patients, and we are cognizant of the specific challenges facing patients that do not have access to adequate social support services. We note that many interventions help identify barriers to health such as transportation and access to food and housing. One such tool that ACEP supports to help manage care for patients with complex needs is the Collective Medical Technologies’ (CMT) Edie™ (a.k.a. PreManage ED) software. We are continuing to explore other innovative ways our physicians can help coordinate care for high-risk patients, including through participation in alternative payment models. Finally, we argue that it is difficult to disentangle beneficiaries’ social and medical risks and that it is more prudent to address these risks together.

ACEP’s full response can be found here.

As an aside, MOCEP is actively looking at the CMT’s Edie for use in Missouri hospital. It has the potential increase care coordination and decrease costs.

 

ACEP Comments on CMS Proposed Rule Related to Regulatory Burden Reduction
On November 16, ACEP responded to a Centers for Medicare & Medicaid Services (CMS) proposed rule that aims to reduce regulatory burden on providers. In our response, ACEP states the while we support the Administration’s overall goal to eliminate unnecessary documentation requirements, we want to make sure that any possible changes do not have any unintended consequences that could pose a detrimental impact on the patients we serve.

The proposed rule includes a number of proposed changes to the existing requirements around emergency preparedness. In general, these changes relate to the frequency of updating a facility’s emergency preparedness program and conducting training and testing sessions. ACEP believes that these proposed changes would move us down a slippery slope that could potentially weaken our disaster preparedness efforts going forward.

ACEP also opposes another proposal in the rule that would eliminate the requirements that: 1) an ambulatory surgical center (ASC) have a written transfer agreement; and 2) the physicians performing surgery in the ASC have admitting privileges with a hospital that is a local, Medicare-participating hospital or a local, nonparticipating hospital that is eligible for payment for emergency services. ACEP believes that having a transfer agreement in place is a key check to make sure that both the ASC and the accepting hospital manage patient care appropriately and that the accepting hospital offers evidence-based treatments and has staff that is able to take care of all possible patient complications. Furthermore, we think that the physicians performing surgery in the ASC must continue to have admitting privileges with the hospital. This current requirement helps ensure that emergency departments are appropriately staffed and that hospitals are able to maintain reliable on-call systems that enable the hospitals to fulfill all the obligations of EMTALA.

ACEP’s full response can be found here.