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MIPS Minute for August 8, 2017

Dr. Gale discusses a MIPS “surprise” that will help you determine your eligibility and success with reporting in this 1 minute video.

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Top 8 concerns around MIPS and MACRA in 2017

Last week we attended the Radiology Business Management Association (RBMA) Paradigm conference in Chicago. Our uber-smart peers in the radiology and medical billing arenas gave us many insights on ways to enhance the value of our registries and our actionable results auditing services. One attendee hit it home: “It’s all about relationships and how you can support patients.”  Medicine isn’t a competition; it’s about finding ways to collaborate so we can all benefit from a well-balanced healthcare system.


At RBMA Paradigm, we wanted to gain a sense of the climate around MACRA and MIPS (the new Medicare quality payment program that replaced PQRS and Meaningful Use this year). There was a pervasive chill and feelings of frustration when we brought up Quality Measures reporting. However, all agreed that CMS is on the right track with its initiative to improve quality by emphasizing that we are “making patients healthier”.


Why does such a warm idea feel so frigid? To help us answer this better, we met with several RBMA attendees to gauge problematic concerns. In previous years, research has shown quality reporting to be expensive and time consuming (Casalino et al., 2016), however we have higher hopes for 2017.


We collected the top eight concerns (below) and submitted them to Brian Gale, MBA, MD. Dr. Gale is a radiologist, registry manager and healthcare communications expert in New York City. He founded a quality and safety organization called SaferMD, LLC where he serves as Managing Member. He created additional CMS-approved reporting measures so that radiologists can maximize their reporting scores. Dr. Gale is currently advising practices on MIPS.


Solutions to Eight Common MIPS Concerns


  1. 1. Groups are struggling to extract the data required for MIPS measures reporting. Structured reports offer one way to find measures data more easily. Simplify measures data extraction by building macros into structured report templates to fix the location of the data required for Quality measures.


  1. 2. Reporting is expensive and time consuming. MIPS measure reporting may be easier than you think. The MIPS Quality category requires only six measures, compared to nine under PQRS. If that feels too burdensome, providers can report fewer measures to avoid negative payment adjustments.


  1. 3. Hurry up and wait. Some groups are ready to start reporting but they are just sitting on the data when they could be benchmarking. Your wait is almost over. CMS should announce approvals for Qualified Clinical Data Registries within the next two weeks. The NJII-SaferMD registry will enable providers to benchmark their measures performance against others in our database.


  1. 4. A lack of ongoing data management. Don’t wait until the last minute. Our registry allows you to submit and benchmark measures performance as you go along.


  1. 5. Lack of support. The process shouldn’t feel so elusive. Our NJII-SaferMD registry customers gave us glowing feedback about our support team. They were pleased with both their knowledge and their response times. There are also good online resources such as


  1. 6. Too overwhelmed with the process to aim high. Earning top Medicare payouts is possible but groups are often just trying to avoid penalties. CMS Acting Administrator Andy Slavin announced a “three speed” option for 2017 reporting. Providers that report just one measure can avoid negative payment adjustments in 2019.


  1. 7. There is a need for benchmarking. It’s beneficial to know how you’re doing compared to other practices in order to get the top scores. The NJII-SaferMD registry benchmarks your performance against all the other providers in our database. Submit data on as many measures as you’d like, then pick the highest performance measures to submit.


  1. 8. Not enough measures for radiologists to reach top score when reporting with a QDR. NJII-SaferMD QCDR with radiology-specific measures will allows radiologists to reach the top MIPS scores.


In moving forward with MIPS, practices can obtain guidance from an expert who can lead them through the current and upcoming changes. It’s still early enough to stay ahead and reach a top score. Our 30 exclusive radiology measures for MIPS 2017 should be approved within the next couple of weeks and you can then start the reporting process. We will be holding a webinar to discuss these concerns and help you simplify the process. Send additional thoughts to or visit


Upcoming:  Webinar with SaferMD and NJII on May 17, 1pm ET. Register here.


Casalino et al. (2016, March). US Physician Practices Spend More Than $15.4 Billion Annually To Report Quality Measures. Health Affairs. 35:3. Retrieved from:

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Could your quality measures qualify for MIPS?

The NJII-SaferMD’s MIPS registry is eligible to suggest new 2017 MIPS measures until January 15.  Once submitted, NJII-SaferMD cwill work with CMS to obtain approval as a MIPS measure.


Do you have effective measures that you monitor in your radiology practice? Would you like the NJII-SaferMD registry to nominate your measure(s) in MIPS for 2017? Send a description of your measure to us at

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Press Release: NJII-SaferMD “PQRS Made Easy” PQRS Registry


SaferMD Announces Unique Radiology Practice Reporting System Registry


Called ‘ PQRS Made Simple’ & Test Results Communications Auditing


NEW YORK, November 15 (PRNewswire)—SaferMD, LLC, a patient-safety organization and neutral third-party auditor of medical communications, today announced its unique PQRS reporting system created specifically for radiologists.

The system easily allows radiologists to comply with the Centers for Medicare & Medicaid Services’ (CMS’) 2016 Physician Quality Reporting System (PQRS), which is why SaferMD’s reporting system is called “PQRS Made Simple.”

As the patent-pending brainchild of radiologist and SaferMD founder and Managing Member Dr. Brian Gale, MD, MBA, “PQRS Made Simple” demonstrates SaferMD’s reputation for increasing patient safety by helping healthcare providers comply with new communications standards, thereby decreasing communication failures that injure patients and cost more than $6 billion annually in malpractice in the United States.

“CMS’ PQRS measures how well any medical provider has complied with best practices,” said Dr. Gale, “and requires each provider to report on at least nine quality metrics annually, lest they risk having their Medicare payments reduced. Our ‘PQRS Made Simple’ registry focuses on radiology-specific measures, including ‘Critical result: pulmonary embolism,’ ‘Urgent result protocol’ and ‘Result follow-up protocol.’”

Dr. Gale notes that starting in 2018, providers’ Medicare payments can increase by as much as 30 percent if they both report to PQRS and perform well in comparison to other providers. Providers who don’t report will be subject to a negative six percent payment adjustment (a six percent penalty).

SaferMD also offers comprehensive communications auditing for radiology practices and hospital radiology departments. Dr. Gale personally consults for these clients.

SaferMD operates in partnership with the New Jersey Innovation Institute (NJII), part of the New Jersey Institute of Technology (NJIT).

For more information, call (718) 682-2664; see; and watch Dr. Gale’s interview online regarding “The Big Problem with Diagnostic Test Results” at

About Safer MD, LLC

SaferMD is a patient-safety organization and neutral third-party auditor of medical communications. The organization helps healthcare providers decrease communication failures that injure patients. SaferMD also assists them in qualifying for risk management credits on malpractice insurance.

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Ebola and Medical Miscommunications

Texas Health Presbyterian Hospital in Dallas has offered differing accounts of what went wrong on September 25, the day their Emergency Department mistakenly sent the nation’s first Ebola patient back into the community instead of admitting him.  Over the next four days, that error put at risk for Ebola many of the individuals who came into contact with Thomas Eric Duncan. Delays in transmission of important clinical data can lead to delays in diagnosis.  In Mr. Duncan’s case, such a delay could have allowed the disease to progress from not receiving the appropriate treatment.  Thorough diagnosis and effective treatment increasingly depends on robust healthcare data communication.


The hospital’s two explanations, first blaming a “work flow” issue in its Electronic Health Record (EHR), and then denying the same issue, are not necessarily contradictory. (A) EHR’s can be configured to store nurse’s and physician’s notes separately, without any interface between the two.  If there were no interface, then there was arguably no  “defect” in the EHR nurse – doctor workflow.  Although the EHR was functioning as configured, one might still ask why the nursing staff did not notify the ER physicians that a patient from Liberia had just presented with a fever, a presentation highly suspicious for Ebola.  To paraphrase Cool Hand Luke, what we had here was a failure to communicate. (B) This may also explain why Texas Health Presbyterian reportedly has a higher re-admission rate than other hospitals in Texas.
Communicating important data is an increasing challenge in healthcare (C).  How big a problem?  In an investigation published in 2011, my colleagues and I learned that “failure to communicate” had been an increasing factor in medical malpractice lawsuits for the prior 20 years.  By the time of our investigation, malpractice awards paid for cases that included communications failure totaled about $4.8 billion annually in the US.  The problem was that the number of test results to communicate keeps increasing, while healthcare providers were under increasing pressure to spend less time on each patient.  Data we evaluated from Harvard’s Risk Management Foundation indicated that gaps most often arose in communications to patients, followed by physicians.


The leading US hospital-accrediting agency, The Joint Commission, emphasizes rapid communication of medical data, designating it National Patient Safety Goal #2.  Consequently, to maintain accreditation, it is incumbent on hospitals to manage healthcare providers’ communications performance.


The Duncan case illustrates that with healthcare communication, there is more at stake than hospital accreditation.   Robust communication is vital for the welfare of patients, and increasingly, the public.


Brian Gale, MD

Managing Member, SaferMD, LLC

Dr. Gale is a radiologist and the founder of SaferMD, LLC, a healthcare safety auditing organization.


A-  Manny Fernandez et. al.  Dallas Hospital Alters Account, Raising Questions on Ebola Case.  New York Times.  A1.  10/3/2014.

B – Cool Hand Luke.   Warner Brothers/Seven Arts (1967)

C – Gale B, Siegel D. Davidson S and Juran D.  . Failure to communicate reportable test results:  Significance in medical malpractice.  Journal of the American College of  Radiology 2011;8:776-779.  Selected as JACR CME Activity of the Month.

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Are You Rolling the Dice with Your Test Results?

Emily left her 20-week sonogram appointment feeling confident and content after the technician told her that her baby’s anatomy appeared to be “perfect”.  A week later, she learned that her OBGYN never reviewed the electronic test results and missed some very important information that jeopardized the health of the baby and herself.  She quickly went from delighted to scared and uncertain.


What happened? One week following her sonogram, Emily met with her regular OBGYN for a standard 15-minute checkup and there was no discussion of the test results.  As she was leaving, she mentioned that the recent sonogram was an excellent experience. The doctor responded, “Oh great, let me just look and see if we got the results…have a seat”.  The doctor opened his computer to review the electronic test results and went on to explain that, according to the sonogram, she had Placenta Previa (her placenta was completely blocking the birth canal). The doctor then shared important tasks that needed to be done in order to keep herself and the baby safe.  These findings were common yet significant enough that someone should have explained them to her immediately.


As Emily got into her car to drive away, all she could think about was how she could have harmed herself or the baby because the doctor wasn’t going to say anything about the sonogram.  She wondered if the technician was supposed to notify her doctor but hadn’t. Or maybe he had received the results but didn’t realize he needed to review them right away. Something so easily preventable could have fallen through the cracks, but why?  Regardless, she felt she was gambling with her health even though she did everything she was supposed to do.


Miscommunications like this happen everyday and cost lives. A young woman recently died after her mammogram results were never reviewed.  A boy with a serious internal infection was discharged from the hospital and lost his life because his test results were never sent to his doctor.  The process of communicating test results needs to be safeguarded. With unlimited access to information online, we can be more proactive and accountable for our own health.  But even with the world at our fingertips, this information can only take us so far.  Following up with the doctor on our own is always a good idea but there must be a more airtight, timely communication procedure between practitioners, especially these days when everyone is bombarded with EMRs and crowded offices. Most importantly, this communication procedure must involve and empower patients.  It really doesn’t have to be a roll of the dice.


This post was contributed by a concerned patient. 

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Turning up the HEAT on Healthcare Fraud

In order to increase patient safety and protect taxpayers, the federal government is serious about reducing fraud and abuse in the Medicare and Medicaid programs and have zeroed in on health care providers.  The Department of Justice (DOJ) joined forces with the Department of Health and Human Services (HHS) to form the HEAT task force (Health Care Fraud Prevention and Enforcement Action Team).


HEAT has significantly increased recovery of improper Medicare and Medicaid charges.  HEAT has also used the False Claims Act to pursue criminal charges against practitioners.  The False Claims Act was enacted by Abraham Lincoln to prosecute Civil War profiteers.  HEAT uses the Act to prosecute healthcare providers who submit fraudulent charges for medical services.  CMS reports that the value of charges recovered nearly doubled between FY 2009 and FY 2011 to $4.1 B


When practitioners don’t communicate diagnostic test results sufficiently, they put patients at risk.  Under the False Claims Act, they may also be accused of fraud.  Criminal prosecutions increased 75% between 2009 and 2011 and they’re still on the prowl.


The best protection for both patients and practitioners is robust notification, and documentation of communication.

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Why did my medical test results fall through the cracks?

You’ve just had a diagnostic medical test performed at a reputable facility.  “The test will be read in a few days,” the staff tells you.  A week goes by and you haven’t heard from anyone about your test results.  You say to yourself, “No news is good news.”


Or, is it? Unfortunately, sometimes not.  The Washington Post reported on the case of Peggy Kidwell.  Her screening mammogram report clearly stated that the exam was abnormal and needed follow up.  The findings demonstrated early cancer, but the abnormal report was sent to the wrong physician (where it sat on his desk for a year). Subsequent testing indicated that the cancer had grown to a later stage and had spread, worsening Peggy’s prognosis.  Something could have been done sooner.


Cases like Peggy’s occur more often than you think.  For any number of reasons, diagnostic test results do sometimes “fall through the cracks.”  Whether diagnostic test result notifications are misdirected or simply delayed, patients face potential harm.


SaferMD aims to eliminate missed test results.  We monitor health care providers’ test result notification activity to help insurance companies offer risk reduction discounts, enabling health care facilities to optimize test result communications.  Our system uses financial incentives to make sure that important results reach the right healthcare provider promptly, speeding up communications so that patients get the right care as soon as possible.

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