In a dramatic policy move, federal healthcare officials announced on Wednesday afternoon, Apr. 27, that the Centers for Medicare & Medicaid Services (CMS) is introducing a new program that will replace the meaningful use program under the HITECH (Health Information Technology for Economic and Clinical Health) Act, for physicians participating in the Medicare program (for the moment, hospitals will be unaffected). The new program, called Advancing Care Information (ACI), was introduced Wednesday as a Notice of Proposed Rulemaking by the Department of Health and Human Services (HHS), under the terms of the Medicare Access and CHIP Reauthorization Act (MACRA).
The new program, with its associated changes, was announced on the CMS website, and via two succeeding press conferences, the first one involving Andy Slavitt, Acting CMS Administrator, and Patrick Conway, M.D., Deputy Administrator for Innovation & Quality and Chief Medical Officer for the agency, and the second one involving Slavitt and Karen DeSalvo, M.D., National Coordinator for Health IT, along with Kate Goodrich, M.D., Director of the Center for Clinical Standards and Quality at CMS.
Details of the announcement were included online in The CMS Blog, and can be read here. In that announcement-blog, co-authors Slavitt and DeSalvo wrote that “Over the last several months, we have made an unprecedented commitment to listening to and learning from physicians and patients about their experience with health information technology – both the positive and negative. We spoke with over 6,000 stakeholders across the country, including clinicians and patients, in a variety of local communities. Today, based on that feedback, we are proposing to incorporate the program in to the Merit-based Incentive Payment System (MIPS) in a way that makes it more patient-centric, practice-driven and focused on connectivity. This new program within MIPS is named Advancing Care Information.”
Stating that “Our goal with Advancing Care Information is to support the vision of a simpler, more connected, less burdensome technology,” Slavitt and DeSalvo wrote in the announcement-blog that, “Compared to the existing Medicare Meaningful Use program for physicians, the new approach increases flexibility, reduces burden, and improves patient outcomes,” because among other things, it will:
> Allow physicians and other clinicians to choose to select the measures that reflect how technology best suits their day-to-day practice
> Simplify the process for achievement and provide multiple paths for success
> Align with the Office for the National Coordinator for Health Information technology’s 2015 edition Health IT Certification Criteria
> Emphasize interoperability, information exchange, and security measures and give patients access to their information through APIs (application program interfaces)
> Reduce the number of measures to an all-time low of 11 measures, down from 18 measures, and no longer require reporting on the clinical decision support and computerized provider order entry measures
> Exempt certain physicians from reporting when EHR technology is less applicable to their practice and allow physicians to report as a group
In his introductory remarks during the first press conference, Slavitt told journalists, “Today’s healthcare system as a nation, we often don’t pay physicians and clinicians for the best care they can give. Across the country, we believe there’s an opportunity to provide high-quality care while saving money. We agree that we need to move our system to one that delivers high-quality care. Thanks to the bipartisan MACRA legislation passed last year and supported by many stakeholders, we’ve had the tools So today, we’ve announced the next major step in Medicare payment reform.”
In comments regarding physicians’ options of participating either in approved alternative payment models or in the new MIPS (Meri-based Incentive Payment Program), under the MACRA law, Dr. Conway acknowledged that the uptake of physician participation in alternative payment models will inevitably be a gradual one. “In the first year,” he said, most physicians will most likely participate in the Quality Payment Program through MIPS.” Under this newly announced Advancing Care Information program, he said, “Physicians would select quality measures from a range of measures, and would report technology use.” The program will “simplify measures and eliminate redundant quality reporting. If clinicians do well in the program, they could earn more than a 4-percent quality bonus, with additional bonuses. CMS proposes to be measuring performance for doctors and other clinicians in 2017, with payment adjustments beginning in 2019,” he added.
So how will the introduction of this program affect physicians’ participation in the current meaningful use program? Under MU, participating physicians must complete Stage 2 requirements during program year 2016, with penalties ending in 2018. That is still true. What will happen with the introduction of the Advancing Care Information program is that physicians will be scored based on a range of measures, and if they are unable to report the successful use of approved information technology under the MIPS program, they would receive a 0 in that reporting category that would bring down their average score under MIPS. Similarly, all the alternative-payment model programs involve performance measures related to the successful use of EHRs and other clinical IT.
According to the fact sheet released Wednesday on the Advancing Care Information program, among the changes to physician reporting requirements are the following:
> Under meaningful use, physicians “must report on all objective and measure requirements, including clinical decision support and computerized provider order entry.” The “new proposal streamlines measures and emphasizes interoperability, information exchange, and security measures. Clinical decision support and provider order entry are no longer required.”
> Meaningful use requirements were “one-size-fits-all—every measure [had to be] reported and weighed equally.” The new program makes physicians’ reporting participation “customizable—physicians or clinicians can choose which best measures fit their practice.”
> Meaningful use has involved “all-or-nothing EHR measurement and quality reporting.” The new program involves “flexible” reporting, with “multiple paths to success.”
> According to the fact sheet, meaningful use requirements have been “misaligned with other Medicare reporting programs,” while the new program will be “aligned with other Medicare reporting programs,” with “no need to report quality measures as part of this category.”
In response to a question from Healthcare Informatics on the extent to which today’s announcement was related to provider dissatisfaction with elements of the meaningful use program during the second telephonic press conference, Slavitt responded by saying, “On what we heard from physicians, we conducted eight focus groups in eight different cities across the country to hear from frontline physicians in practice. We heard an overwhelming amount of feedback that fell into three principal categories,” he said.
“First, Slavitt said, “we heard that physicians are frustrated with the inability of the technology they’re using in their office to connect with other physicians and hospitals and to track patients as they go on referral or to communicate with patients. What other people call ‘interoperability,’ they described in much more tangible terms. Particularly because they’re so used to the rest of their technology working, that was their chief frustration. Second,” he said, “we heard that the meaningful use requirements were really inflexible, required them to spend time at a keyboard instead of enabling care, and in many cases, they wanted to use technology for their purposes, but that the requirements of meaningful use were one-size-fits-all and were burdensome, frankly. They wanted more flexibility and control, and to have a simpler program,” he said.
“And the third thing we heard” from practicing physicians in the eight focus groups that CMS officials recently conducted, Slavitt said, “was that the technology itself wasn’t intuitive and didn’t really meet them in the way they practice in their offices, but required them to adapt. And some of them were stuck, and there was a lack of innovators to create technologies that would replace or compete with some existing technologies, and that was stagnating for them, so those where the things we attempted to address.”
Karen DeSalvo, M.D.
“Exactly right, Andy,” DeSalvo then said. “And I’d add with respect to the evolution of our certification programs, there’s an expectation to see how we could improve the market transparency around product performance, to make that data available, so that we’re able to iterate and understand whether the products as they move through testing and into practice, how those results can be made transparent to the industry.”
Like any Notice of Proposed Rulemaking, this Notice will now be available for public commentary for 60 days, before it moves towards finalization.
Healthcare Informatics will continue to update readers on new developments in this evolving story.