PROBLEM:
We had this issue as well although our TOCs are not as high as it would be for primary care. The challenge is that most medical practices are clueless about the TOC process and the direct protocol. Many providers have a direct account but they have no idea what their account name is much less how to check it.
SOLUTION:
We faxed a communication form to all of the providers we refer patients to and asked them to provide us with the secure direct accounts for their physicians or a direct account that they use for their entire practice. (Click this link to access our form: tocfax ) The communication included instructions on how they could request a secure direct account for their practice and/or providers (i.e. we made it very simple for them). If they did not provide us with a direct account, we gave them the option of providing us with an email account that we could use to notify them that a TOC was sent to an account on our secure portal (ezAccess). Our patient portal has a physician facing component that allows a physician to login and retrieve information securely (this meets the TOC objective as well). In the absence of a direct account, we can set up a secure account on our portal using an email address they provide us. We do not rely on CQR because our providers found the workflows GE requires you to follow were cumbersome and the data being reported was not accurate or trustworthy. We built out our own reporting system for that reason; I recognize many practices don't have that luxury.
RESULTS:
We kept track of the responses to our communication form as well as those that did not respond. Only about 20% that responded had a direct protocol account. About 40% provided us with a standard email account. The other 40% never responded or designated they were not interested in participating. Of the 40% that didn't respond, we set up a secure account anyway on our portal so that we would not be penalized for circumstances beyond our control.
CONCLUSION:
I have no problem defending our ability to show that we took every reasonable effort to accommodate the TOC objective. As it turns out, we had enough direct protocol referrals to meet the reporting requirement, but I can see how other practices (esp. primary care) might have a problem meeting the "letter of the law." Regardless, I think you could defend yourself in an audit if you show you took measures similar to those outlined above. As far as reporting accurate numbers; I suspect CPS identifies that the TOC checkbox was checked when submitting the referral order (assuming that's your process), even if CQR doesn't give you credit because the recipient didn't have a direct protocol address. If that's the case, a query could be run directly against the database to identify the total number of referral orders that had the TOC checkbox checked, and that is the numerator I would report, so long as you can demonstrate you have taken efforts to meet the "spirit of the law." I have found that CMS is not unreasonable and penalizing a practice for making efforts to accommodate an objective that largely depends on circumstances beyond your control is counterproductive to their mission.
Hope this dissertation helps you in some way. 🙂 Cheers.
Posted : December 20, 2016 9:55 am
