By Jeff Kabachinski
The Centers for Medicare and Medicaid Services (CMS) are about to add to the Meaningful Use (MU) incentive program with the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA, CHIP = Children’s Health Insurance Program). The idea is to simplify the way health care is paid for and create an infrastructure to move from a fee-for-service to a value-based reimbursement or a pay-for-value system.
This installment of Tech Savvy takes a look at the new program and attempts to understand what this might mean to the Hospital Information System (HIS) network. Another aspect of this installment of Tech Savvy is to get familiarized with the new language and terminology – yippee another new language to learn. In the new rule the Department of Health and Human Services (HHS) and CMS indicate three central main concerns of MACRA:
- Better system interoperability for physicians and patients to access information from other health care systems
- More flexibility in the Meaningful Use portion of the program
- Technology designed around physician workflow and interactions with patients
Overall, this a fundamental change in the incentives and penalties of the MU program. The MU program had a list of quality measures that must be met to show you’ve moved to a certified EHR (Electronic Health Record) system and are simply getting a meaningful use out of it. Within MACRA we must now instead show that it has a positive effect on patient health care outcomes, clinical workflow and reimbursement methods. This can be a big deal if the health care organization depends on the CMS reimbursements which can be as much as two-thirds of the overall revenue. The MU program will now be called the Advancing Care Information program (ACI) and becomes a point-based ACI performance category score.
There are two major portions of MACRA – the MACRA-Related Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM). ACI now falls under the MIPS portion.
MIPS
MIPS consolidates components of three current programs: the Physician Quality Reporting System (PQRS); Physician Value-Based Payment Modifier (VM); and the Medicare Electronic Health Record (EHR) Incentive Program (ACI). Some of the current requirements within ACI no longer need reporting such as the Computerized Provider Order Entry (CPOE) measure. This includes orders for scans, tests, medications and treatments and is core to system operation. Since it’s such a core piece of system operation not much would happen without it. So, why measure it?
Interestingly the MIPS portion of the program is intended to be budget neutral meaning that the amount of awarded incentives would match the amount of assessed penalties. They’ve estimated that to be around $800 million the first assessment period – pocket change in government monetary terms.
The MIPS assessment period will be the calendar year two years prior to the year in which MIPS is used. As the initial MIPS payment year is scheduled to begin in 2019 that means it has a January 1, 2017 start date. The new quality measures would be assessed, established and can change every year with input from the health care community. The next year’s measures will be published in the Federal Register on November first of every year.
Four Performance Categories
The MACRA rule recommends measures, reporting, and data standards in four performance categories: quality, use of resources, clinical practice improvement activities (CPIAs), and ACI. MACRA also has incentives for participation in particular APMs.
APMs
MACRA has incentives for participation in particular APMs that support the goals of turning from fee-for-service payments into APMs that center on improved health care, intelligent spending and healthier patients. MACRA also has proposed measures for use by the Physician-Focused Payment Model Technical Advisory Committee (PTAC) in sending comments and recommendations on physician-focused payment models (PFPMs).
Health care providers must also show their commitment to interoperability and data exchange routines. The three-part attestation contains answers to this main question: the provider did not knowingly disable functionality to restrict interoperability of certified EHR technology from patients, and health care providers, despite the requestor’s technology vendor.
Ready or Not
It’s difficult at this point to exactly determine what the resulting healthcare IT requirements will be without knowing the quality and performance measures involved. We know that interoperability and cybersecurity will be a major part of the quality measures. The new rule also emphasizes information exchange and that patients have access to their health information through use of APIs.
A recent survey by the Healthcare Information and Management Systems Society (HIMSS) showed that while health care providers were not opposed to the big change, most didn’t think that they were ready to make the move into the next phase of participation for the Quality Payment Programs. They’re looking to the rest of the health care industry to help define a consistent approach to MACRA with tools to build infrastructure support mechanisms. The HIMSS site (www.himmss.org) has a wealth of information, some informative recorded webinars and fact sheets about MACRA. Stay alert regarding this one – don’t get caught flatfooted!