AAFP Sustains Fight to Reduce Administrative Burden for Family Medicine

The AAFP continues efforts calling for an immediate reduction in the regulatory and administrative requirements family physicians and practices must comply with on a daily basis. These burdens range from onerous documentation guidelines to cumbersome prior authorization criteria and the unrelenting frustrations associated with electronic health records.

A 2016 study published in the Annals of Internal Medicine found that during a typical day, primary care physicians would spend 27 percent of their time on clinical activities and 49 percent on administrative activities. The authors of the study, “Allocation of Physician Time in Ambulatory Practice: A Time and Motion Study in 4 Specialties(annals.org),” concluded that for every hour primary care physicians spends in direct patient care, they spend two hours engaged in administrative functions.

In January 2017, the AAFP published its Agenda for Regulatory and Administrative Reforms. Family physicians are concerned with the ever increasing number of administrative requirements that detract from time that would be better spent on patient care. Studies have estimated that primary care physicians spend nearly 50 percent of their time on overly cumbersome administrative tasks, such as:

  • Prior Authorizations
  • Performance Measures and Reporting
  • Electronic Health Record Documentation
  • Care Management Documentation

Prior authorizations top the list of physician complaints about administrative burden. On January 25, 2017, the AAFP and a coalition of 16 other medical organizations called for the reform of prior authorization and utilization management requirements that bog down physicians and impede patient care. Through its "Prior Authorization and Utilization Management Reform Principles(www.ama-assn.org)," the coalition is "urging health insurers and others to apply the reform principles and streamline requirements, lengthy assessments and inconsistent rules in current prior authorization programs." The 19 principles address prior authorizations as they apply to the following areas:

  • Clinical validity
  • Continuity of care
  • Transparency and fairness
  • Timely access and administrative efficiency
  • Alternatives and exemptions

In April 2017, the AAFP published a new policy on prior authorizations to support its advocacy initiatives with facts. The policy explains how prior authorizations threaten patient care by delaying or halting the continuation of timely, evidence-based care.

The AAFP continues to advocate that all payers use the primary care core measure set developed by the Core Quality Measure Collaborative. Recently, the CQMC reinitiated work to update the core set and to ensure payers are adopting it.

CMS has expressed its intent to update the documentation guidelines for evaluation and management services to better align E/M coding and documentation with the current practice of medicine and thereby reduce the associated burden. AAFP staff and representatives continue to interact with CMS and other entities to determine direction and potential solutions.

On October 26, 2017, AAFP President Michael Munger, MD, traveled to Washington, D.C., to present the AAFP’s views to a roundtable discussion hosted by Seema Verma, the administrator for the Centers for Medicare and Medicaid Services. As one of only three panelists, Dr. Munger delivered three administrative reform recommendations for consideration to CMS:

  • Elimination/reduction of prior authorizations for certain drugs and supplies for established patients
  • Elimination of documentation guidelines for evaluation and management codes for primary care physicians
  • Repeal of the regulatory framework of the promoting interoperability (previously called Advancing Care Information) requirements under the Medicare Access and CHIP Reauthorization Act

In December 2017, the AAFP Board of Directors adopted the AAFP’s own host of principles aimed at reducing the administrative burden weighing down doctors. The four-part "Principles for Administrative Simplification" covers prior authorization, quality measure harmonization, certification and documentation of medical services and supplies, and medical record documentation.

The AAFP’s advocacy efforts to alleviate family physicians from undue administrative complexity are ongoing, as demonstrated by recent letters to the Trump administration and CMS.

In an April 23, 2018 letter to CMS Administrator, Seema Verma, the AAFP offered further input on questions asked by CMS during the “Documentation Guidelines and Burden Reduction” listening session held on March 21, 2018. The AAFP calls for the documentation guidelines to be eliminated for codes 99211-99215 and 99201-99205 for primary care physicians for all three domains: history, physical exam, and medical decision making.

In a March 14, 2018, letter to CMS Administrator, Seema Verma, the AAFP praises the agency for its recently announced MyHealthEData initiative, which is designed to empower patients through greater control and portability of their health care data. However, the AAFP objects to placing responsibility for the adoption of interoperable systems on physician practices, insisting the creation of standardized interoperable systems should instead be the responsibility of vendors.

In a February 27, 2018 letter to Demetrios Kouzoukas, Principal Deputy Administrator and Director, Center for Medicare, Centers for Medicare & Medicaid Services, the AAFP calls for CMS to go beyond “merely reminding and encouraging” Medicare Advantage insurers about the multiple, inconsistent and time-consuming preauthorization requirements imposed by MA plans, prescription drug plans and durable medical equipment suppliers. Instead, the AAFP says CMS should require and enforce preauthorization principles that are transparent and consistent across all plans.

In a February 7, 2018 letter to CMS Administrator, Seema Verma, and Don Rucker, MD, Office of the National Coordinator for Health Information Technology, the AAFP urges CMS and ONC to alleviate unneeded regulatory burdens related to health information technology. Doing so would guide physicians closer to achieving the Quadruple Aim of enhancing patient experience, improving population health, reducing costs, and improving the work life of clinicians and staff.

In an October 19, 2017 letter from the AAFP to John R. Graham, Acting Assistant Secretary of the U.S. Department of Health and Human Services, the AAFP provided guidance for the agency’s draft strategic plan for 2018-2022. The AAFP used the bulk of its seven-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.

In a June 8, 2017 letter from the AAFP to CMS Administrator, Seema Verma, the AAFP weighed in on the 2018 Hospital Inpatient Prospective Payment proposed rule as published in the April 28 Federal Register. The AAFP expressed a mixture of praise and concern regarding the alignment and simplification of various reporting requirements, as well as ongoing concerns about the readiness of 2015 edition certified EHR technology for 2018 reporting. In addition, the AAFP reminded CMS that the Medicare Access and CHIP Reauthorization Act was intended to simplify Medicare payment, quality improvement and performance measurement programs, rather than introduce new and cumbersome administrative requirements for physicians that do not improve patient care.

In a May 11, 2017 joint letter to CMS Administrator, Seema Verma, the AAFP and a long list of other medical specialty organizations expressed concerns over the agency’s planned enactment of the Social Security Number Removal Initiative. While supportive of the need to protect seniors from identity theft, the signatories called for the change to be made through the traditional notice and comment rulemaking process so that valuable industry feedback may be considered. In addition, the signatories asked that CMS develop a mechanism for providers to quickly and securely access Medicare beneficiary identification numbers to avoid back-office billing headaches and disruptions in access to care for patients.

In an April 26, 2017 letter from the AAFP to CMS Administrator, Seema Verma, the AAFP notes its support of President Trump’s executive order, Reducing Regulation and Controlling Regulatory Costs, but calls for CMS to step back and reconsider the current approaches to the Medicare Access and CHIP reauthorization Act of 2015 (MACRA), which we view as overly complex and burdensome to physicians.

On March 21, 2017, the AAFP and nearly 90 other medical organizations sent a letter to CMS Administrator, Seema Verma, calling for the agency to establish a strategy to relieve the electronic health record documentation burden. The letter also called on CMS to create a hardship exemption for physicians who attempted to report PQRS in 2016 but were unsuccessful due to the complexity of the reporting requirements and the significant number of measures that were required.

A January 31, 2017, letter from the AAFP to President Trump cites research demonstrating how family physicians face a regulatory burden that is unmatched among the various medical disciplines.

A December 16, 2016, letter from the AAFP to acting CMS Administrator, Andy Slavitt, expresses concern about patient relationship categories and related coding documentation required under the Medicare Access and CHIP Reauthorization Act. The requirement will significantly increase the administrative burden that Medicare participating physicians already experience.