With the MACRA 2018 Quality Payment Program (QPP) final rule due any day now, CHIME’s vice president of federal affairs, Mari Savickis, expects stakeholders to be mostly pleased with the government’s final rulemaking.
At the CHIME (College of Healthcare Information Management Executives) 2017 Fall CIO Forum in San Antonio, Texas, Savickis caught up with Healthcare Informatics Managing Editor Rajiv Leventhal to give a few quick thoughts on the current health IT policy landscape. Savickis noted that the QPP 2018 final rule should be published today, Nov. 1, but if it doesn’t come by this afternoon, she expects it in the next day or two.
What will CHIME and its more than 2,000 CIO membership base be looking for in the rule? Says Savickis, “From our perspective, there are some very favorable pieces in the [proposed] rule that align nicely with the hospital side. The hospital pieces were finalized earlier than the physician ones. The IPPS [Medicare Hospital Inpatient Prospective Payment System] rule was finalized in August, and that gave us the requisite relief that we were so desperately seeking concerning the evolution to 2015 CEHRT [certified electronic health record technology], which of course is coupled with Stage 3 meaningful use [MU].”
Savickis is referring to the final rule released by the Centers for Medicare & Medicaid Services (CMS) in August that affirmed a 90-day reporting period for hospitals attesting to the MU program in 2018, as well as delaying the mandatory Stage 3 start date until 2019. Further, CMS, in that rule, adopted final policies to allow healthcare providers to use either 2014 Edition CEHRT, 2015 Edition CEHRT, or a combination of 2014 Edition and 2015 Edition CEHRT, for an EHR reporting period in 2018. Indeed, this relief seemed to make most stakeholders happy in the short term, and Savickis predicts similar reactions when the MACRA 2018 rule drops.
“There is no more meaningful use in the doctor world; it’s now ACI [Advancing Care Information], which supplanted MU [in MACRA/MIPS],” she says. “CMS has proposed doing the same things they did with the hospitals [in the IPPS rule], which is essentially shifting over to the right by a year, with the timeframe you’d have to meet Stage 3 ‘like’ measures by and also for [implementing] 2015 CEHRT. And I’m fairly confident they will advocate that proposal. We will be very supportive of them finalizing that. I think we’ll be looking at a good news story,” she says.
Another piece of the MACRA 2018 rule in question that CHIME supports is weighing the Resource Use (Cost) category in MIPS at 0 percent in 2018, before moving up to 30 percent in 2019. Cost is one of four categories of eligible clinician performance, contributing to an annual MIPS final score of up to 100 points. This category was originally slated to not be weighted for 2017 MIPS scores, but would be weighted for 2018 and beyond. But then in the proposed MACRA rule for 2018, CMS suggested to keep it at zero percent in 2018, but to go up to 30 percent in future program years (2019 and beyond). Savickis said, “We support going back to 0 percent for 2018.”
What’s more, regarding MU Stage 3, which has already been pushed back a year, Savickis theorized that there is a path in which the 2019 mandatory start date could be pushed back again, or perhaps even eliminated. She pointed out that the new administration needed 2017 to reexamine what’s under review and what has been recently finalized under the last administration. She also pointed out that this administration has been a “champion” for finding ways to relieve providers’ burdens via regulations. “So far we have not seen what this exactly will translate to, but we have seen steps taken in the right direction,” Savickis said, making note of the “Meaningful Measures” initiative that CMS announced this week.
“There is an evolution in which CMS is trying to move away from process and toward outcomes. And this is something that provider community had desperately sought,” Savickis said. “They’re done checking the box and collecting information just to collect it. You want to drive value, so duplicity is not good, and value outcomes are better. We’re seeing steps taken in that direction.”
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