The College of Healthcare Information Management Executives (CHIME) is calling on federal officials to lessen the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) burden for eligible Medicare physicians through a variety of means.
In CHIME’s comments to the Centers for Medicare & Medicaid Services (CMS) following the agency’s release of the MACRA final rule in October, the CIO-driven healthcare association supports some of the steps CMS has taken to improve the flexibility by which clinicians use health IT to drive better outcomes, but is still pushing for more flexibilities.
Indeed, in recent months, federal officials announced flexibilities that will allow eligible Medicare physicians to pick their pace of participation for the first performance period of the outcomes-based program that begins Jan. 1, 2017 that will enable physicians to ease into the program without getting hit with negative payment adjustments right away. CMS referred to these flexibilities as “picking your pace” for MACRA.
What’s more, CMS has also proposed adopting a 90-day reporting period at the outset and reduce the number of measures that must be met under the Advancing Care Information (ACI) performance category within the Merit-based Incentive Payment System (MIPS). In addition, however, the letter from CHIME CEO and President Russell Branzell is also calling for CMS to:
- Make 2018, in addition to 2017, a year of transition;
- Adopt a single set of standards to facilitate more seamless data exchange;
- Align health IT reporting requirements across all provider settings to include:
a) Establish a 90-day reporting period for all reporting requirements in perpetuity;
b) Postpone any Stage 3-like measures and use of electronic health records (EHRs) certified to Version 2015 until no earlier than 2019;
c) Remove pass / fail policies—particularly as they remain intact for hospitals—and replace them with policies that allow providers to meet at least 75 percent of the mandates and still meet the requirements;
d) Allow facility-based clinicians to elect to use their institution’s performance rates as a proxy for the MIPS’ clinician’s quality score;
- Include improvement activities that incent clinicians to take steps to better defend against cybersecurity threats and engage in good cyber hygiene as soon as possible; and
- On data blocking provisions:
a) Limit the data blocking attestation to statement one at this time (compared to the three statements CMS is asking providers to attest to);
b) Do not require providers to attest to the exchange of structured data; and
c) Adopt an appeals process.
What is perhaps most noteworthy in CHIME’s comments is the request to make 2018 a transition year as well as 2017, and that clinicians should not be required to move to Stage 3 measures any sooner than the 2019 reporting year. To these points, CHIME said in the letter, “While we support the new onboarding policies, we believe additional clarity is needed. For instance, there appears to be some confusion about how the new reporting policies will work. Further education from CMS would be helpful. We have received some questions from members on whether a clinician would need to report for the entire year or just 90 days in order to receive a score of 100 under MIPS. It is our understanding that it is indeed possible for a clinician to achieve the highest score by only reporting for 90 days, though the likelihood of hitting a score of 100 is increased if reporting occurs for more than 90 days. It is therefore our understanding that a clinician can achieve the same score whether they report for a full year or as little as 90 days. We recommend CMS conduct further outreach around this topic.”
Meanwhile, the letter stated that CHIME members have expressed concerns that managing the complexity associated with having to meet three sets of Meaningful Use requirements—one for MIPS, another for Medicare hospitals, and yet another for Medicaid providers—will become untenable. CHIME noted that with less than a month until January 1, the date by which providers have been given the option to begin voluntarily meeting Stage 3 and for which Version 2015 would be required for use should they elect to do so, it is clear most vendors are not yet ready. “In fact, some of our members have already alerted us to the fact that they will not receive their upgraded products until well into 2018,” CHIME said.
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