As part of its continuing “Patients over Paperwork” initiative, the Centers for Medicare & Medicaid Services (CMS) has released another request for information (RFI) on regulatory or subregulatory changes the agency could make to “reduce unnecessary administrative burdens for clinicians, providers, patients and their families.” In particular, CMS seeks new ideas for:

  • Streamlining reporting requirements, documentation requirements, or processes to monitor compliance with CMS rules and regulations;
  • Aligning Medicare, Medicaid and other payer coding, payment, and documentation requirements and processes;
  • Enabling operational flexibility, feedback mechanisms, and data sharing that would enhance patient care, support the clinician-patient relationship, and facilitate individual preferences; and
  • Determining how and when CMS issues regulations and policies, and how CMS can simplify rules and policies for beneficiaries, clinicians, and providers.

Additionally, CMS solicits recommendations regarding ways the agency could:

  • Improve the accessibility and presentation of CMS requirements for quality reporting, coverage, documentation, or prior authorization;
  • Address specific policies or requirements that are overly burdensome, not achievable, or cause unintended consequences in a rural setting;
  • Clarify or simplify regulations or operations that pose challenges for beneficiaries dually enrolled in both Medicare and Medicaid and those who care for such beneficiaries; and
  • Simplify beneficiary enrollment and eligibility determination across programs.

Comments on the RFI will be accepted until August 12, 2019. In an appendix to the RFI, CMS highlights what it views as Patients over Paperwork accomplishments to date, including steps the agency has taken to:

  • Reduce regulatory burdens (e.g., removing Outcomes and Assessment Information Set (OASIS) data elements);
  • Simplify documentation requirements (e.g., streamlining certain Durable Medical Equipment, Prosthetics, Orthotics, and Supplies (DMEPOS) order requirements);
  • Focus on “Meaningful Measures” in various Medicare quality programs;
  • Improve operational efficiencies and interoperability (e.g., consolidating data submission under the Quality Payment Program);
  • Enhance transparency and consistency (e.g., greater transparency in the Local Coverage Determination process); and
  • Offer burden-reducing flexibilities in payment model demonstrations (e.g., the Telehealth Expansion waiver in the Next Generation Accountable Care Organization model).