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EHRA, HIMSS Comment on CMS Value-Based Payment Models

November 23, 2015
by Heather Landi
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The Electronic Health Record Association (EHRA) and the Health Information and Management Systems Society (HIMSS) last week weighed in on the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) and voiced concerns about new data reporting requirements and new certification criteria for alternative payment models.

In October, CMS asked for stakeholder comments regarding MACRA and implementation of a Merit-based Incentive Payment System (MIPS), Alternative Payment Models (APMs) and physician-focused payment models. The comment period ended last week.

In a letter to the Centers for Medicare & Medicaid Services (CMS), EHRA, on behalf of more than 30 of its member companies, cautions CMS against overreliance on the use of electronic health records (EHRs) and health IT “to report on MIPS performance categories that are outside the scope of EHRs, or are not currently defined and implemented today.”

And, EHRA voiced concern that electronic records vendors may not be able to incorporate new reporting and quality measures in time to meet the 2017 deadline when MARCA programs start.

“For items that may be appropriate to add to an EHR for measuring or reporting, both vendors and providers need sufficient time to develop and implement new functionality or reporting capabilities, which may not be possible in time for the 2017 performance year,” EHRA stated.

In its comments to CMS, EHRA stated that it does not support the creation of an additional set of certification criteria for APMs or MIPS.

“We reiterate our position that it should be a subset of certified electronic health record technology (CEHRT) used for the EHR incentive program as applied to MIPS, not a new certification program or new certification criteria focused on APMs,” the association wrote.

ERHA also encouraged consistency between the MIPS and APM technology requirements.

“Technology adoption should not be a barrier to transitioning from MIPS to the APM program,” the association wrote.

HIMSS made a similar point in its comments to CMS last week.

“HIMSS does not recommend adoption of a large set of criteria due to the variability that exists across current models, and variability that will continue to exist as payment models evolve. We discourage adoption of any components that may not be relevant to all providers and all APMs. HIMSS recommends that these criteria should primarily focus on interoperability, patient engagement, and care coordination, which are essential components across all potential models,” the letter stated.

The College of Healthcare Information Management Executives (CHIME) used its comments to CMS last week as an opportunity to urge policymakers to streamline  the meaningful use program and reduce the reporting burden on providers by better aligning quality measures. As reported by Healthcare Informatics and noted in a CHIME Washington Debrief this week, CHIME is advocating for the removal of the pass/fail methodology of the meaningful use program.

The American Medical Informatics Association (AMIA) also responded to the RFI with specific suggestions, as reported by HCI Senior Contributing Editor David Raths. AMIA also commented on quality measurement and urged CMS to focus on outcome measures rather than process measures.

As Rath reported, AMIA recommends that federal officials do not “reflexively expand the current approach to quality measurement in developing these new policies.” Rather, AMIA stated that opportunities should be sought to retire existing process-based measures while looking for ways to develop more outcomes-based measures.

HIMSS, however, stated in its letter that outcome measurement and reporting “are limited in their ability to inform effective workflow analysis and improvement by providers,” whereas process improvement clinical quality measures “allow providers to conduct effective root cause analysis.”

“HIMSS recommends maintaining the current mix of process and outcomes-based measures currently reflected in the Meaningful Use eCQM (clinical quality measures) measure set. HIMSS also suggests that CMS craft guidance language directing eligible professionals (EPs) to select a mix of eCQMs that reflect both process improvement and outcomes for similar populations,” the letter stated.

Commenting on the quality reporting measures for the MIPS program, HIMSS recommended CMS consider the following criteria – the measures accurately reflect care delivered; are collected and reported as part of an EHR-enabled clinical workflow and not overly burdensome to providers and the clinical quality data are actionable and drive clinical improvement.

HIMSS also recommended that CMS offer technical assistance for rural providers, especially by working in partnership with HRSA’s Office of Rural Health Policy (ORHP) to select and manage the technical assistance contract.



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