CHIME Calls for Ending Pass/Fail Construct to Meaningful Use
Key Takeaway: CHIME submitted comments on the CMS Request for Information (RFI), which sought input in operationalizing Section 101 of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).
Why it Matters: The law sunsets and consolidates the current penalty framework under the Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier (VM), and the MU program into the new Merit-based Incentive Payment System (MIPS) Program. Meaningful Use is one of four areas physicians will need to meet under MIPS. The law also aims to advance physician involvement in value-based reimbursement by exempting eligible professionals (EPs) participating in an alternative payment model (APM) from MIPS. As we to new models of care, health care providers will increasingly be reimbursed based upon their performance and patient outcomes. As CMS operationalizes this new payment system CHIME recommended:
- Creating parity for both eligible professionals (EPs) and eligible hospitals (EHs) by removing the existing pass/fail approach for MU. MACRA only applies to EPs and creating different program requirements for hospitals and physicians creates added complexity. CHIME specifically called on CMS to deem providers successful if they meet 75 percent of the MU requirements.
- Aligning and streamlining quality reporting by eliminating duplicative and burdensome measures, which often take time away from direct patient care.
CMS Offers More Guidance on Meaningful Use
Key Takeaway: CMS published new Meaningful Use frequently asked questions (FAQs). Further clarifications on the Stage 3 regulation are also expected.
Why it Matters: CMS continues to publish guidance further clarifying requirements for meeting MU. CMS has shared with CHIME that they will be publishing a technical correction to the Stage 3 regulation. You can expect to see, as an example, clarification around the ePrescribing requirements. There is some confusion with the way the regulation discusses ePrescribing of Controlled Substances (EPCS). CMS intends to clarify that EPCS will be optional to include in the denominator. CMS also recently published the following two frequently asked questions (FAQs):
- Public health reporting objective (FAQ 13409): For 2015, how should a provider report on the public health reporting objective if they had planned to be in Stage 1 meaningful use which required sending a test message and continued submission if successful, but did not require registration of intent? Read the answer here.
- Specialized registries (FAQ 13413): Does integration of the PDMP (Prescription Drug Monitoring Program) into an EHR count as a specialized registry? Read the answer here.
CHIME is still seeking volunteers to join a workgroup that will assist in developing the organization's response to the Meaningful Use Stage 3 Final Rule. To volunteer for CHIME's workgroup please contact Mari Savickis at email@example.com. The last two CHIME Stage 3 Comment Workgroup calls with take place on:
Monday, November 30th at 11:00 a.m. ET
Wednesday, December 2nd at 11:00 a.m. ET
VA, DOD tell Congress Interoperability Challenges Nearing an End
Key Takeaway: The Departments of Defense (DOD) and Veterans Affairs (VA) respond to congressional concerns about interoperability between the two agencies, which was a key requirement in a 2014 funding bill.
Why It Matters: In addition to expressing concern about health data exchange in the private sector, Congress has focused heavily on existing interoperability challenges between the DOD and VA electronic health record (EHR) systems. Congress has securitized the decision to pursue two different EHR platforms despite the hefty federal investment.
Under the 2014 Defense Authorization bill (NDAA), the two departments were required to share information in 25 clinical domains, including medications, allergies and problem lists,to support continuity of care. In a Nov. 16 letter to the House Appropriations Committee, Undersecretary of Defense Frank Kendall noted that progress is still underway at the VA, but that the DOD had gone above the requirement of complying with national data sharing standards.
Kendall wrote that “medical data interoperability requires steadfast commitment and continuous improvement.” Citing ongoing efforts to evaluate information sharing capabilities and to improve upon them, Kendall affirmed, “providing high quality healthcare for current Service members, their families, and our Veterans is among our nation's highest priorities.”
Doc Caucus Draft Letter Calls on Speaker Ryan to Consider Legislative Fixes to MU
Key Takeaway: The GOP Doctors Caucus, comprised of lawmakers that are also healthcare providers, is planning a letter for submission to House Speaker Paul Ryan (R-WI) encouraging him to enable congressional action on the Meaningful Use program.
Why It Matters: Interest in the Meaningful Use program continues to grow among lawmakers, especially as the end of the 2015 legislative calendar nears. The draft letter circulated by the Doctors Caucus speaks to the perception that CMS has ignored the requests of healthcare providers and lawmakers alike to improve the current state of the program.
The letter, as drafted but not submitted, references the need for CMS to have the authority to grant blanket hardship exemptions in 2015 due to the delayed release of the Meaningful Use Modifications Rule, which put in place a90-day reporting period of 2015. In early November, Rep. Tom Price (R-GA) introduced a bill, the Meaningful Use Hardship Relief Act of 2015 (H.R. 3940), to give CMS the authority to grant blanket hardships for 2015 program participation. The letter also speaks to the need for a “legislative remedy” to save providers from the existing flawed Stage 3 rule.