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Fulfill Your Board of Medicine Requirements on Your Time

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percent die of non-natural causes while they are hospitalized, from errors somewhere in the course of their care. That 10 percent is even worse when you consider that many of those total 2.4 million deaths were older patients who died because, in some sense, their ‘time had come.’ For those 250,000, though, many were younger and clearly died ‘before their time.’ Years-of-life-lost were not calculated in this study, fortunately for us. Doubtless you’ve struggled to wrap your head around the enormity of this number and the insidiousness of a problem that has simmered beneath the surface for so long. But when you think about the complexity of what goes on in American hospitals, it’s really not so hard to understand. Thirty-six million admissions, 145 million ER visits, 129 million surgeries. Every one of those situations involves multiple physicians, dozens of ancillary staff, multiple medicines, tests, critically timed decisions, and easily misunderstood person-to-person hand-offs. You might be tempted to accept the tiny, tiny percentage of fatal errors as inevitable and acceptable but it is certain that your patients don’t. Two hundred fifty thousand deaths, the third leading cause of death in Americans of all ages, is simply too, too high a number and, if we are going to continue to have the trust of our patients, we are going to have to act. The model for a solution exists… in the airline industry. Millions of miles flown, but the airline industry does not accept the occasional error, the occasional crash and death of their customers. They aim for zero deaths, and they do it by ruthlessly rooting out any and all errors. And have they succeeded? Absolutely they have. And we can too. With THRIVE’s ZERO HARM INITIATIVE, which on May 26, in front of 650 witnesses, 12 top executives from our regional healthcare organizations solemnly swore to uphold. These are the powerful management people who engage actual fiscal responsibility in our hospitals. They hire and fire staff. They set up training programs. They buy computer programs and upgrades. They reward employees who come forward with issues, small and large, before those issues lead to critical errors. They reward staff financially for ideas to fix those problems. In summary, one clear failure of the American healthcare system is its insufficient attention and progress in addressing errors. Doing so would clearly improve the overall health and longevity of the American public. Perhaps it has never been realistic to look solely to doctors as the sole protectors of America’s health. Too many patients are being impacted by factors beyond the control of we physicians alone, and we need a total systems solution here. We can give our all to patient care. Our best efforts, the most up-to-date treatment; the most skilled resuscitation; the most brilliant surgical technique; the most inspired diagnosis; literally pulling our patient from the jaws of death just may not be recognized because these successes are eclipsed by all the deaths caused by medical error. Perhaps every life we save is negated by a life lost to medical error? Such a terrible thought, but it would explain a lot! Looking forward, though, we should be proud of our hospitals, and their administrators, that they have taken this step. The thought that, in the future, in our hospitals, no patients will die from avoidable causes is simply an incredibly awesome goal. It is good for all of us. For the hospitals, for us doctors, and especially for the patients!

In summary, one clear failure of the American healthcare system is its insufficient attention and progress in addressing errors. Doing so would clearly improve the overall health and longevity of the American public. Perhaps it has never been realistic to look solely to doctors as the sole protectors of America’s health.

Fulfill Your Board of Medicine Requirements on Your Time

MSMS offers numerous on-demand webinars that fulfill the Michigan Department of Licensing and Regulatory Affairs requirements for continuing medical education, including: • A series of 12 covering Pain and Symptom Management • Three on Medical Ethics • Human Trafficking Download and watch at your convenience 24/7. For a complete list and to register click HERE

JOINT CYBERSECURITY ADVISORY Ransomware Activity Targeting the Healthcare and Public Health Sector

The Federal Bureau of Investigation (FBI) and two federal agencies are warning of an "imminent cybercrime threat" to U.S. hospitals and health care providers, noting that several hospitals across the country have already been hit. In a joint advisory, the Cybersecurity and Infrastructure Security Agency (CISA), FBI and the U.S. Department of Health and Human Services (HHS) said they have "credible information" that cybercriminals are taking new aim at health care providers and public health agencies as the COVID-19 pandemic reaches new heights. "Malicious cyber actors" may soon be planning to "infect systems with Ryuk ransomware for financial gain" on a scale not yet seen across the American healthcare system. Hospitals, physician practices and public health organizations should take "timely and reasonable precautions to protect their networks from these threats." Malware targeting techniques often lead to “ransomware attacks, data theft and the disruption of healthcare services." The agencies recommend several mitigation steps and best practices for health care entities to take to reduce their risk, including the

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following: • Patch operating systems, software and firmware as soon as manufacturers release updates. • Regularly change passwords to network systems and accounts and avoid reusing passwords for different accounts. • Use multi-factor authentication where possible. o Disallow use of personal email accounts • Disable unused remote access/Remote Desktop Protocol (RDP) ports and monitor remote access/RDP logs. • Identify critical assets; create backups of these systems and house the backups offline from the network. • Set antivirus and anti-malware solutions to automatically update; conduct regular scans.

The AMA and the American Hospital Association (AHA)

have created two resources to help physicians and hospitals guard against cyber threats. Those resources and additional cyber security information can be found at the AMA’s

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MSMS ADVOCACY LEGISLATIVE ALERT

Health Can’t Wait is a coalition of patients, physicians and health care providers dedicated to putting Michigan patients first and ending delays in patients’ access to health care.

#FixPriorAuth because #HealthCantWait: Support SB 612

Senate Bill 612 is currently on the Senate Floor. We are preparing for a vote shortly after the election.

Prior authorization (PA) and step therapy/fail first requirements hamstring treatment, drive up nonadherence to medication and lead to diminished health. It’s onerous and needless insurance company bureaucracy, and it’s negatively affecting patients, physicians, providers and their practices. It’s time we cut out the red tape, because at the end of the day, health can’t wait. And now we can do just that. State lawmakers are preparing to take up SB 612, a bill that reforms PA and step therapy/fail first process by introducing new transparency, fairness and clinical validity requirements, ensuring our patients receive timely coverage decisions, and ultimately, the care and treatment they need. This is the kind of reform our patients deserve - it’s time to put them first.

Please contact your lawmakers today and urge them to support SB 612.

Health Can’t Wait Talking Points

The purpose of utilization review programs incorporating PA and step therapy is to screen for appropriateness of hospital admissions, high-cost procedures, and newer, highcost specialty drugs for which the risks, benefits and overall value are still being evaluated.

Recently, PA and step therapy have quickly expanded to include common procedures and established generic products (e.g., topical corticosteroids, sulfonylureas for diabetes, oral antineoplastic drugs for cancer, etc.). • 86% of physicians report PA burdens have increased over the last five years. Physicians and other health care professionals are spending too much of their time dealing with burdensome and archaic PA requests when they should be caring for patients. • On average, 33 PAs per physician per week. • Physicians and their staff spend an average of almost two business days each week completing PAs. • 30% of physicians have staff who work exclusively on PA. This unwarranted intrusion into medical decision-making and the clinician-patient relationship causes real problems for patients and adds waste to the health care system. • Hamstrings treatment and diminishes health 3 90% of physicians report PA has a somewhat or significant negative impact on clinical outcomes. 3 Prescription PA implementation for medications to treat diabetes, depression, schizophrenia and bipolar disorder has been associated with worsening disease status. 3 24% of physicians report PA has led to a serious adverse event. 3 16% of physicians report PA has led to a patient’s hospitalization. • Drives up medication nonadherence and treatment abandonment 3 37% of prescriptions rejected at the pharmacy are abandoned, never to be picked up by patients. 3 74% of physicians report PA can at least sometimes lead to treatment abandonment. • Results in onerous and needless insurance company bureaucracy, costs

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3 The U.S. Office of Inspector General found Medicare Advantage Organizations overturned 75 percent of their own denials during 2014-16, overturning approximately 216,000 denials each year. 3 The U.S. consumes far more of its health expenditures on administrative tasks than virtually any other country in the world; PA requests contribute greatly to these costs that are borne by health professionals and health plans.

Time to right size, simplify, and share the “playbook” with patients and health professionals.

PA has a place in helping to ensure the right care at the right time… when it is applied properly. When it’s transparent. When it’s timely. And, when it supports shared decisionmaking between a patient and his or her health care provider over insurance company paperwork. Health Can’t Wait supports SB 612, introduced by Senator Curt VanderWall, to reform the PA and step therapy/fail first process by introducing new transparency, fairness and clinical validity requirements, ensuring our patients receive timely coverage decisions, and ultimately, the care and treatment they need.

Senate Bill 612 (S-1) does the following: Increases transparency in the PA process:

• Sets standards and provides more transparency over how PA is utilized. • Makes PA requirements accessible on the insurer’s public website. They also must be described in detail, written in easily understandable language, and readily available to the health provider at the point of care. • Ensures statistics regarding PA approvals and denials are publicly available. • Requires PA requirements to be based on peer-reviewed clinical review criteria and annually evaluated and updated, if necessary. • Requires insurers, upon issuing the denial, to notify the health professional and insured/enrollee of the reasons for the denial and related evidence-based criteria.

Gives physicians and health care professionals fair input on the PA process:

• Ensures input on changes to clinical review criteria from actively practicing physicians representing major areas of the specialty who are not employees or consultants of the insurer. • Promotes the modification of PA requirements based on the performance of the health care providers with respect to adherence to evidence-based medical guidelines or other quality criteria (e.g., gold carding). • Adverse determinations must be made by a physician, and appeals of such decisions must be reviewed by a physician actively practicing in the same specialty as the service provided.

Simplifies the PA process for physicians, patients, and insurers:

• Establishes a clear timeline for insurers to respond to PA requests and specifies the circumstances under which a PA request would be considered granted by an insurer. • Urgent requests must be acted upon within one business day after the time of submission. Non-urgent requests must be acted upon within two business days after the time of submission. • Establishes a timeline for health care providers to respond to requests for additional information from insurers. • Requires insurers to make a standardized electronic PA request transaction process utilizing an online system by April 1, 2021.

Protects patients and continuity of care:

• Provides that PA requests are valid for not less than 60 calendar days and not more than one year depending on the clinical conditions of the care needed. • Prohibits insurers from requiring that an enrollee’s health care provider participate in step-therapy protocol if the physician considers that the step therapy protocol is not in the patient’s best interest and specifies what constitutes “the patient’s best interest” (e.g., drugs are contraindicated or will likely cause an adverse reaction, drug already tried and determined to be ineffective, patient stable on a drug).

Common Sense Reforms

Administrative costs of PA and step therapy apply across the board to all stakeholders including insurers. For physicians, an average of $82,975 per physician per year is attributed to insurer administrative hassles; equating to roughly $23-$31 billion dollars annually nationwide. Health care spending for administrative costs incurred by private and public insurers is much higher in the U.S. as compared to other developed countries - 14 percent vs. 3-10 percent. Time spent on burdensome paperwork and seeking authorizations, is time that could otherwise be spent taking care of patients. Despite the active engagement of physicians in quality improvement initiatives and value-based care models, insurers are escalating and broadening the use of PA and step therapy to medically necessary, routine services and commonly prescribed medications, which negatively impacts care delivery and results in inappropriate denials… • Recent studies reflect 265 million claims nationally require PAs, with the volume increasing 20 percent or more per year. • 90 percent of physicians report PA has a somewhat or significant negative impact on clinical outcomes. • 24 percent of physicians report PA has led to a serious adverse event. • 16 percent of physicians report PA has led to a patient’s hospitalization. continued on page 27