Optimize CMS compliance with an AWS powered SaaS THA and TKA PRO-PM digital care pathway

By Snehanshu Bhaisare, Partner Solutions Architect, AWS
By Alexander Zusman, MD MPH, Chief Medical Officer, The Clinician
By Darryl Grauman, Head of Research and Development, The Clinician
By Katherine Thomas, Director of Strategic Alliances, The Clinician

For the first time, the Centers for Medicare and Medicaid Services (CMS) is employing a Patient-Reported Outcome Performance Measure (PRO-PM) to drive quality improvement in Total Hip Arthroplasty (THA) and Total Knee Arthroplasty (TKA) procedures.

This new PRO-PM will impact providers by reducing their annual payment update (APU) for non-compliance, as well as making quality data publicly available for patients to make informed decisions regarding their care based on quality. This change in CMS’s approach to quality improvement represents the adoption of value-based care on a large scale. It also presents new obstacles that providers will encounter when attempting to implement these measures.

In this blog post, we describe how The Clinician’s THA/TKA PRO-PM SaaS digital care pathway, powered by Amazon Web Services (AWS), offers a resilient solution to address these new challenges set forth by CMS. The Clinician’s SaaS solution meets global security standards including ISO27001, HIPAA, GDPR, CyberEssentials, and holds the SOC2 certification. The THA/TKA PRO-PM SaaS digital care pathway is an indispensable tool that will guarantee the ability to meet regulatory compliance mandates as well as provide actionable dashboards for organizations that need to implement targeted quality improvement. Ultimately, the THA/TKA PRO-PM digital care pathway offers providers an easy to use, low cost all-in-one SaaS solution to address the THA/TKA PRO-PM mandate at any scale built to be ready for implementation within 2 hours of purchase.

The Clinician is an AWS partner whose platform configures digital care pathways, deploys Patient-Reported Outcome Measures(PROMs), and collects patient-reported data to meet regulatory compliance requirements while providing robust analytics to providers.

CMS and the THA/TKA PRO-PM

The incorporation of PROMs into clinical reporting is being propelled by the movement toward value-based care models. Beginning in 2023, CMS rolled out its inaugural PRO-PM targeting primary elective knee and hip replacement surgeries in the Medicare population. By 2027, the data collected will be publicly reported. Collection of patient-reported outcomes data can be difficult and providers will be required to report on at least 50% or more of their eligible patients. Similar to the Comprehensive Joint Replacement Model (CJR), it is likely that CMS will increase the required response rate (percentage of patients who complete the required surveys) from 50% to 80% in subsequent years. In addition, providers are required to achieve clinical benefits thresholds for both Total Hip Arthroplasty (THA) and Total Knee Arthroplasty (TKA). If providers cannot collect 50-80% of their eligible patients or if they cannot meet the preset clinical benefit thresholds, CMS will levy a financial penalty.

According to the timeline set by CMS (1): (To access outside the US, use a VPN set to a US region.)

• By 2024, hospitals must start collecting PROMs data on inpatient procedures.
• By 2025, hospitals must start collecting PROMs data on outpatient procedures.
• Full compliance with data collection and reporting is required by 2027.
• By 2028, non-compliant inpatient providers will face a reduction in their Annual Payment Update (APU) by 25% for all Medicare Fee for Service Part A claims (including non-orthopedic claims).
• By 2030, non-compliant outpatient and ASC providers will face a reduction in their Annual Payment Update (APU) by 2%.
• Non-compliant providers will be disqualified from participation in all Medicare value-based purchasing programs.

The Clinician’s SaaS platform provides a comprehensive solution when it comes to data collection for the THA/TKA PRO-PM requirements as set forth by CMS, as shown in Figure 1.

Figure 1: Hospital-level THA/TKA Patient-Reported Outcome-Based Performance Measure (PRO-PM) Fact Sheet

What are PROMs and Why are They Important?

PROMs are instruments used to collect subjective data from patients regarding their quality of life and functional well-being before, during, and after medical care. These metrics gather information about health conditions and treatment outcomes directly from the patient, without any interpretation by healthcare providers. Effective delivery and collection of this data are crucial to the success of any PROMs program.

PROMs contribute significantly to improving clinical care by allowing healthcare providers to understand patients’ perspectives and adjust treatments to better meet their needs. They enhance patient satisfaction by engaging patients in their own care process, which increases adherence to treatment protocols. Additionally, hospitals can use PROMs data to benchmark performance, comparing effectiveness across different departments, treatments, and even with other institutions.

Challenges with the THA/TKA PRO-PM

Providers required to report specific THA/TKA PRO-PM data will face multiple challenges:

• Efficient and precise data collection: the collection of PROMs is burdensome, costly, and prone to errors when done manually or using basic survey tools.
• Technological integration: Integrating new systems for PROMs collection with existing Electronic Health Records (EHRs) is complex and resource-intensive.
• Data security and privacy: Ensuring the confidentiality and integrity of sensitive patient data according to HIPAA regulations is crucial.
• Patient engagement: Effectively motivating patients to consistently provide feedback through PROMs over a lengthy time period is challenging.
• Reporting results: Organizations must be able to collect, organize, and report results of collected patient data back to CMS in an efficient, timely manner using the specified formats required by CMS.
• Quality Improvement: It can be challenging knowing how to address quality problems identified by the review of patient-reported outcomes data.

SaaS THA/TKA PRO-PM Solution

The Clinician, a cloud-based platform, has been carefully designed to optimize the process of gathering, overseeing, and evaluating Patient-Reported Outcome Measures (PROMs). This section provides an in-depth analysis of how this SaaS solution tackles the complex obstacles associated with the implementation of the THA/TKA PRO-PM digital care pathway, as shown in Figure 2.

Figure 2: THA/TKA PRO-PM digital care pathway Patient App and Provider Portal

THA/TKA PRO-PM Data Collection

The timeline for delivery and collection of these measures, as mandated by CMS, has been developed into a digital pathway within the platform and has been designed to engage eligible THA/TKA patients before and after their procedure. Specific survey instruments designated by CMS are delivered to patients via text or email at specified times and patients are engaged to return their responses in a timely manner using scheduled reminders. The platform functions as a progressive web app that doesn’t require a user to download any software or install new apps. This is essential for providers who will need to scale their PRO-PM delivery and collection when outpatient, HOPD, and ASC procedures are included in the CMS requirement, as shown in Figure 3.

Figure 3: Patient App for data collection

Automated Data Capture and Reporting

The Clinician’s THA/TKA PRO-PM SaaS solution reduces administrative burden and mitigates the likelihood of manual errors and redundant data entry by automating the information flow, starting with the distribution and completion of PROMs by patients, and culminating in our various dashboards to enable immediate feedback and support decision-making. The platform performs data aggregation and normalization of patient responses into formats amenable to analysis, and the production of compliance reports into specifically formatted CSV files, which can be submitted directly to CMS. Providers can use these data outputs and visualizations to address specific areas of quality concern.

Real-Time Analytics for Response Rates and Clinical Benefit

With its real-time analytics capability, The Clinician’s SaaS solution delivers healthcare teams real-time insights and alerts into the two main CMS mandated parameters: Response Rates and Substantial Clinical Benefit (SCB:RSIR). Clinicians can oversee these metrics by utilizing visual representations on different interactive dashboards.

• Required response rates (> 50% of eligible patients) can be tracked using interactive charts that allow staff to identify and then easily contact patients with missing survey results. Automated text and emails can be triggered via The Clinician’s platform.
• Clinical benefit threshold requirements can also be easily tracked using interactive charts. Providers have the ability to monitor this principle quality measure in real time. Through early data validation of Post-op survey results, providers receive a 90 day window of time to address quality concerns for a given patient prior to finalization of data for CMS submission, as shown in Figure 4.

Figure 4: Provider Portal with real-time analytics, including response rates and clinical benefit

Exceeding Global Cybersecurity Standards for Management of PHI data

In addition to being optimized for adherence to HIPAA regulations in the United States, this SaaS solution satisfies stringent data security standards on an international scale. The Clinician’s THA/TKA PRO-PM solution is ISO27001 certified, GDPR compliant, and carries the SOC2 certification. The platform is hosted on AWS and is fortified with a comprehensive security framework delivered by AWS services. This framework comprises identity and access management, data encryption both at rest and in transit, and ongoing security monitoring.

The Clinician’s SaaS solution is specifically engineered to take advantage of the complete range of benefits offered by cloud computing, such as scalability, dependability, and advanced security. Let’s dive into the individual components:

The Clinician’s SaaS solution leverages a comprehensive suite of AWS services to ensure robust security and compliance for managing Protected Health Information (PHI). The platform utilizes Amazon VPC for a secure, isolated environment, Amazon S3 for durable and private data storage, and Amazon DynamoDB for efficient data management and real-time analytics. Scalable computing is achieved through AWS Lambda and Amazon EC2, while AWS IAM ensures strict access control. The solution is distributed across multiple AWS Availability Zones for enhanced fault tolerance and availability. Additional security measures include Amazon CloudFront for content delivery, AWS WAF for web application protection, Amazon Route 53 for DNS management, and AWS Shield for DDoS protection. This multi-layered approach, built on AWS infrastructure, enables The Clinician to meet and exceed global cybersecurity standards for PHI management.

Conclusion

The THA/TKA PRO-PM represents a significant shift towards patient-centered care, requiring providers to collect and report PROMs data or face financial penalties. The Clinician’s AWS-powered cloud-based platform offers a comprehensive SaaS solution that addresses the challenges of PROMs deployment, collection, automated data capture, reporting, real-time analytics, and adherence to global data security standards. Healthcare organizations seeking to comply with CMS mandates on PROMs data collection can visit The Clinician’s website to purchase their SaaS digital care pathway solution and implement it within 2 hours of purchase.

The Clinician – AWS Partner Spotlight

The Clinician an AWS Technology Partner, drives patient-centric care with a digital health platform that automates PRO and Patient-Reported Experience (PRE) data collection, reducing costs and improving outcomes for healthcare providers worldwide.

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