On April 24, the Centers for Medicare & Medicaid Services (CMS) released an 1,883-page proposed rule on meaningful use rebranding with new emphasis on interoperability and burden reduction, along with indications that the agency may be raising the interoperability stakes.
The meaningful use (Medicare and Medicaid EHR Incentive Programs) program has been around since 2011 with the intent to encourage eligible providers to demonstrate meaningful use of certified EHR (electronic health record) technology. CMS is now proposing a shakeup of the initiative with a rethinking of industry priorities. In a press release, the federal agency said that it will be proposing to re-name the meaningful use program to “Promoting Interoperability.” CMS said the goals of the new program will be to: make it more flexible and less burdensome; emphasize measures that require the exchange of health information between providers and patients, and incentivize providers to make it easier for patients to obtain their medical records electronically. According to CMS, the rule applies to about 3,300 acute care hospitals and 420 long-term care hospitals, and would take effect Oct. 1.
Since the rule dropped, there has been ongoing discussion about the changes in the proposed rule and if the government will be forcing providers to participate in health information exchange activities, and you can read some of that reaction in this article posted last week. For that article, Healthcare Informatics Associate Editor Heather Landi spoke with Jeff Smith, vice president of public policy at AMIA (the American Medical Informatics Association) about CMS raising the interoperability stakes. Below are excerpts from that interview.
What are your initial takeaways of this proposed rule?
This is the first rulemaking cycle that the new Administration has the ability to put its fingerprints on. The thing I’m struck most with is the fact that they have been talking about the need to reduce reporting burden and the need to improve interoperability, particularly patient data access. I do think those themes come through pretty loud and clear with these proposals. Now, one quibble is whether or not the total effort is reduced by how many measures they removed. CMS states that they have reduced total measures and objectives from 16 down to six. The question is, is it three times easier to do? The answer is, probably not. But, certainly, there is in these proposals an attempt to try to align meaningful use (MU) more with what I presume will be the strategy for MIPS [Merit-based Incentive Payment System) and Advancing Care Information (ACI). Now, we have to wait for that rule to come out. I think if the goal here is to reduce the reporting burden, align MU with MIPS and to try to make progress on interoperability and patient data access, I think these proposals, in total, at least on paper, are pointed in the right direction.
In this proposed rule, CMS is proposing a new scoring methodology. What is your perspective on the scoring methodology?
I think that they’re taking a page out of the MIPS and ACI playbook. It will be interesting to see what the reaction is. I think clearly what they are trying to do is create the opportunity for more flexibility and the preamble does reference the Bipartisan Budget Act of 2018, that was just passed at the beginning of the year. That legislation has allowed CMS to propose policies that are not intrinsically more difficult over time by eliminating the provision requiring more stringent measures of meaningful use. And, you can see that by how CMS is giving people the ability to submit data on fewer measures and by setting the overall composite score at 50 [points needed to avoid Medicare payment adjustments]. So, again, it borrows from the MIPS playbook by recalibrating a composite score and I think this will be largely helpful for those who are worried about the all-or-nothing component of MU. How much extra work and headache it’s going to save, is still another question
CMS also changed the name of the meaningful use program to Promoting Interoperability. How do the changes to the scoring methodology and the metrics support that?
I think there’s nothing you could do within the measures and objectives themselves to improve interoperability in a meaningful way. What you have to do is look at the totality of the program and the requirements, and that is inclusive of a 90-day reporting period and inclusive of the need to adopt 2015 edition certified EHR technology. I think the other thing that we have to keep in mind here is that it will probably take more policy levers than just these measures and objectives to improve interoperability.
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