On Feb. 14, officials at the federal Centers for Medicare and Medicaid Services (CMS) opened a comment period, seeking input from physicians and other providers regarding one aspect of the MIPS (Merit-based Incentive Payment System) program under the MACRA (Medicare Access and CHIP Reauthorization Act of 2015) law. Specifically, CMS officials asked healthcare providers to submit comments in three areas under MIPS: measures around quality, around advancing care information, and around improvement activities.
The letter from CMS began thus: “The Centers for Medicare & Medicaid Services (CMS) opened the submission period for the Annual Call for Measures and Activities for the Merit-based Incentive Payment System (MIPS) track of the Quality Payment Program. The Annual Call for Measures and Activities,” the letter continued, “allows providers and measure stewards from stakeholder organizations to identify and submit measures and activities for three of the four MIPS performance categories. To be considered, proposals must include measure specifications, related research, and background.”
It suggested submissions in three areas: “Quality,” “Advancing Care Information,” and “Improvement Activities,” asking for input from the field in all three areas. In that regard, physicians participating in the Medicare program in 2017 who are not participating in advanced payment models (APMs) will automatically be subject to the provisions of the MIPS program, with 60 percent of the incentive-based payment they receive under MIPS being tied to their fulfillment of quality measures, 25 percent being tied to Advancing Care Information-related requirements, and 15 percent tied to “Improvement Activities.” Of those three areas, the “Improvement Activities” area remains perhaps the least well-defined so far.
In that regard, Mari Savickis, vice president, federal affairs, at the Ann Arbor, Mich.-based College of Healthcare Information Management Executives (CHIME) spoke exclusively to HCI Editor-in-Chief Mark Hagland on Sunday, February 19, during the annual CHIME-HIMSS Forum, being held at the Hyatt Regency Orlando, immediately prior to the annual HIMSS Conference, about this subject. The Washington, D.C.-based Savickis urged the leaders of patient care organizations, including CIOs, CMIOs, and other healthcare IT leaders, to take advantage of the opportunity provided by CMS to offer suggestions for the “Improvement Activities” section of the MIPS program. Below are excerpts from that interview.
This letter from CMS was just released to the field, correct?
Yes, it came out on February 14—just last week.
And you see this as a real opportunity for providers to influence the direction of this federal program, correct?
Yes, I do. The window is actually fairly short, in terms of the chance to get something for 2018. CMS announced a week ago that the deadline for inclusion for measures and activities for 2018 is February 28. So we encourage folks to take a look at the form that CMS has published. We still have an opportunity after February 28; the next deadline is in June, but that’s for inclusion after 2018.
To me, what’s really interesting is that this is in a sense, unprecedented. They’re starting this category by asking for input from the field. That seems totally new to me.
They mention it in the regulation, as I recall; and I’m sure they’ll be talking about it as the week progresses into HIMSS; so I’m sure we’ll be learning a little bit more about it. But this is an opportunity for clinicians and opportunities to weigh in, for CIOs to offer up their ideas.
And you mention that one of these activities could be cybersecurity assessment?
That’s something that CHIME has strongly recommended. Providers often, especially small ones, are under-resourced. So why not give credit for doing the right thing, which is trying to engage in some activities around cyber-hygiene, such as patching your system, or implementing anti-phishing software?
Right. And here we are with a new administration dealing with a regulation that came through legislation two years ago, so it’s rather an interesting situation. And we’re about to have a new CMS Administrator confirmed. Do you have any clue as to how Seema Verma might handle this part of MIPS?
It’s hard to say, since she hasn’t yet been confirmed. So I think there are a lot of unknowns. Obviously the career staffers at CMS have to keep the trains running, so it behooves us to act as though it’s still business as usual. We need to keep moving forward. Unfortunately, it’s too soon to tell, without the political appointee in place.
But MACRA seems solid, because it has nothing to with the ACA [Affordable Care Act]?
For right now… There are a number of changes that people would like to see, and those are changes that are going to offer up to Secretary [Tom] Price and to CMS, once the administrator is confirmed. This is a fluid situation. Things have slowed down somewhat since the beginning of 2017. So I think it’s a little bit hard to predict, but I think that by the summer, we’ll have a fuller picture.
But you would encourage providers to make their thoughts known to CMS?
Absolutely. The worst thing that they can do is to say, ‘no thank you.’ This is an opportunity for providers, and I would urge them to take advantage of it.
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