By the end of the month, healthcare providers may get a chunk of information they need: The final rule for implementing the Medicare Access & CHIP Reauthorization Act of 2015. It spells out changes in reporting requirements that will determine whether providers are reimbursed, basically helping build the pipeline for providers to get Medicare money.
Part of that will be an attempt yet again to clarify the Meaningful Use program. Ever since CMS acting Administrator Andy Slavitt told a J.P. Morgan Healthcare Conference in January that the “Meaningful Use program, as it existed, will now be effectively over and replaced with something better,” people have talked of the end of MU. And with Stage 3 still underway, that has created a lot of confusion. But MU was mandated by the Health Information Technology for Economic and Clinical Health (HITECH) Act, and it would take another act of Congress to do way with it.
CMS issued the proposed final rule in May. The proposed regulations would base clinician pay on four performance categories: quality, advancing care information, clinical practice improvement activities, and cost. It would also reduce the number of measures that providers are measured against from 15 in Meaningful Use Stage 3 to eight under the advancing care information (ACI) performance category.
The government conceived the MU program as a way to get providers to demonstrate “meaningful use” of a certified electronic health record. Those that do so get incentive payments. In 2015, 96% of non-federal acute care hospitals have adopted certified EHR technology, up from 71.9% in 2011, the Office of the National Coordinator for Health Information Technology reported. Eighty-four percent of hospitals had at least a basic EHR system.
EHR adoption by physicians has also grown considerably — to more than eight in 10, or 83%, according to an ONC report. The rate goes down to 74% when only certified EHR adoption is counted.
So does MACRA replace Meaningful Use?
“The program is not being sunset in any traditional sense of the word,” says Jeff Smith, vice president of public policy at the American Medical Informatics Association (AMIA). “I would say the program has been rebranded.”
Ross Seymour, CEO and founder of iHealthOne, agrees. “Providers should understand that Meaningful Use is not going anywhere; it will be consolidated under MIPS, and will still be a factor for how providers may receive incentive funding or be subject to penalties.”
While not yet finalized, MU Stage 3 is expected to hew to the realigned requirements published last fall for Modified Stage 2, Seymour says, noting those requirements were meant to help providers transition from MU Stage 1 to Stage 3, with more advance requirements like interoperability and patient engagement.
AMIA has put together a crosswalk of Stage 3 objectives, along with MU Stage 3 requirements and the proposed ACI measures. There are few substantive changes between the two programs, Smith points out. “From an IT perspective, if you are compliant in MU in 2015 and 2015, I don’t think your IT compliance or your IT strategy needs to change a whole lot for 2017,” he tells Healthcare Dive.
Beginning in 2018, providers could see some new requirements around patient engagement and use of application program interfaces (APIs) as the focus shifts from managing individual patients to managing the health of populations, Smith adds. “The name of the reimbursement game is changing. And unless your practice is prepared to understand how many of your diabetic population hasn’t been in for a checkup, then you’re, unfortunately, on the losing side of the equation moving forward.”
One thing to keep in mind is that there are essentially two programs now. Hospitals must abide by the requirements of MU Stage3, while clinicians follow MIPS. Smith says CMS has made “laudable progress” in trying to harmonize the two programs over the last six to eight months, which matters from a managerial and compliance standpoint given the increasing number of hospitals with affiliated physicians and physician practices who may be getting compliance or IT support from those hospitals. He expects to see more convergence of the MU Stage 3 program for hospitals and the ACI category for clinicians.
What are the challenges ahead?
With publication of the final rule later this month or next, Smith says three aspects will be worth watching. One is APIs and how they are used to enable patients to access their data and help clinicians do a better job. A lot of people are betting on API to be a silver bullet for interoperability, but there’s not enough experience with it to know if that will be the case, he says.
Another potential trouble spot is patient-generated health data and determining what counts as such and how to integrate it in a sensible way that improves patient outcomes. “The last thing that we want to do is inundate clinicians with more data than they can handle,” says Smith.
The challenge for providers will be clinical information reconciliation. One of the things Stage 3 is going to be raising the bar on is not just reconciling a patient’s medications, but reconciling specific health problems, allergies and certain other clinical data, Smith notes.
Seymour would add “time” to the challenges providers will face. “MACRA has an aggressive timeline and begins evaluating providers’ performances beginning Jan. 1, 2017. Providers may see an impact to their reimbursements as early as 2019 for not complying with the utilization of certified EHRs, which will be based on their 2017 performance,” he says.
But providers could get some wiggle room for complying with the Quality Payment Program, which is set to begin Jan. 1. In a recent blog, CMS’ Slavitt outlined a “pick your pace” approach for the first year of the program. Providers could participate for the full calendar year, submit data for part of the year, submit data to demonstrate capability and begin participating in 2018. As a fourth option, providers may forego reporting quality data and other information and participate in an Advanced Alternative Payment Model in 2017.
What’s on the horizon as CMS demands increasing levels of attestation?
Probably more integrated networks and infrastructures, for one. There are definite advantages to finding the right degree of scale with larger organizations merging with others, says Smith. There’s also the realization that it’s no longer about just certifying EHRs and we now live in a much more modular kind of technology environment.
Providers are starting to adopt much more complicated data systems that apply business intelligence principles and analytics to health care, with the goal of managing populations. These are positive developments and the result of public policy that says the government will reimburse based on how whether a patient gets better and not how many times they are seen.
Since 2009, there’s been a rapid coming of age of EHR technology, says Smith, along with a proliferation of standards on content, vocabulary and other aspects of these systems. The challenges now lie more around interoperability and usability.
“The writing is on the wall that certified EHRs will be mandated across the nation in different ways, overall effectively determining whether providers will be able to continue practicing medicine,” says Seymour. “Increased revenue from reimbursements and patient engagement are big factors. But integrating the technology we already have available in the healthcare system will allow you to provide improved quality of care to your patients, which is priceless.”