With the release of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) final rule last week, healthcare leaders quickly turned to look at the regulation’s many provisions that directly relate to the use of certified electronic health record (EHR) technology and more broadly, health information technology.
Indeed, MACRA’s Quality Payment Program, which includes two tracks for eligible Medicare clinicians—the MIPS (Merit-Based Incentive Payment System) path, and the advanced alternative payment models (APMs) path— requires the use of certified EHR technology to exchange information across providers and with patients to support improved care delivery, including patient engagement and care coordination, federal officials noted in a fact sheet with the release of the Final rule last week. The idea is that the better providers are able to utilize and leverage health IT, the more likely Medicare’s value-based transformation for hundreds of thousands of physicians and other eligible clinicians will be successful.
In a call with health IT press on Oct. 14, Centers for Medicare & Medicaid Services (CMS) Acting Administrator Andy Slavitt said, “If the HITECH Act allowed big EHR companies to form and grow, MACRA is the next shift and arguably a much richer opportunity, where customer needs begin to takeover.”
On the MIPS front, the track that most participants will initially partake in early on in the program, doctors will be scored on Quality; Advancing Care Information; Clinical Practice Improvement Activities; and Cost (which begins in 2018).
When the proposed MACRA rule was released in April, much of the conversation centered on the Advancing Care Information (ACI) category, which effectively replaces Meaningful Use for Medicare physicians. The objectives of the ACI performance category of MIPS emphasize measures that support clinical effectiveness, information security and patient safety, patient engagement, and health information exchange, and computerized provider order entry (CPOE). The final rule does not require reporting on the clinical decision support and the measures. Additionally, the final rule reduces the number of measures clinicians must report to five measures that are focused on interoperability; this is reduced from 18 measures in Stage 3 of Meaningful Use and from 11 measures in the MACRA proposed rule.
On the call with HIT press, Slavitt said, “Many of you have heard me call out CMS for losing the hearts and minds of physicians. As we met with doctors around the country, we learned about how technology doesn’t support physicians,” noting that CMS reduced the number of ACI required measures from 11 to 5, and adding that the final rule offers flexibility so physicians can pick the quality measures to report on that are right for their practice.
Vindell Washington, M.D., National Coordinator for Health IT, added during the call, “Our collective goal is a simpler approach to technology that [will help] providers get better outcomes for patients. Health IT is foundational to providing quality care,” he said. Washington said it’s not just about implementing the health IT, but “unlocking the data within and putting it into work.” He added, “The health IT elements [of the final rule] are laser focused on making information sharing easier. We focused specifically on what will advance the broader view for the future in which electronic health information flows through the system wherever and whenever needed.”
Plenty of HIT Implications
Drilling down, MACRA participants will need their IT infrastructure to be ready for the big leagues. Tom Lee, Ph.D., founder of SA Ignite, a Chicago-based vendor firm whose software platform is focused on reimbursement analytics, says it is important to keep in mind that every MIPS point matters financially. “If you look at the financial and scoring rules in depth, you find that every incremental MIPS point translates into more dollars starting with next year. So having more efficient IT systems to give you a very tight and quick performance improvement feedback loop—in terms of capturing data, looking at where your performance is, and then quickly remediating and monitoring your score on a more frequent basis, which also relies on IT—will be absolutely critical to doing well in this program, he says. “You are still being rated against national benchmarks, and the people who are scoring higher will get more dollars,” Lee says.
One of the existing quality reporting programs that MACRA streamlines into the Quality Payment Program is PQRS (Physician Quality Reporting System), which is now labeled the “Quality” category under MIPS. Lee gives an example of one particular PQRS method—called the measure group method—that was used primarily by specialists and small providers and didn’t require a lot of IT. “You could basically get away with reporting on 20 patients,” Lee explains. But under the Final rule, the ‘measures group’ is being completely eliminated, so other quality reporting approaches will be required, which takes a higher IT requirement than simply reporting on 20 patients,” he says.