I know all of us are a flutter about the pending regulatory changes which will phase out Meaningful Use as we know it. And yes, without a doubt, the changes underway will have an impact that extends well beyond the HIT world. But while big shifts are underway in federal incentives programs, it’s worth noting that it could be a while before these changes actually fall into place.
As readers may know, the healthcare industry will be transitioning to working under value-based payment under the Medicare Access and CHIP Reauthorization Act, which passed last year. But as ONC’s Karen DeSalvo noted last week, the transition could take a while In fact, proposed draft regulations for MACRA rollout will be released this spring for public comment. When you toss in the time needed for those comments to be submitted, and for the feds to digest those comments and respond, my guess is that MACRA regs won’t go live until late this year at the earliest.
The truth is, this is probably a very good thing. While I don’t have to tell you folks that everyone and their cousin has a Meaningful Use gripe, the truth is that the industry has largely adapted to the MU mindset. Maybe Meaningful Use Stage 3 wouldn’t have provided a lot of jollies, but on the whole, arguably, most providers have come to terms with the level of process documentation required — and have bought their big-bucks EMRs, committing once and for all to the use of digital health records.
Value-based payment, on the other hand, is another thing entirely. From what I’ve read and researched to date, few health organizations have really sunk their teeth into VBP, though many are dabbling. When MACRA regs finally combine the Physician Quality Reporting System, the Value-based Payment Modifier and the Medicare EHR incentive program into a single entity, providers will face some serious new challenges.
Sure, on the surface the idea of providers being paid for the quality and efficiency they deliver sounds good. Rather than using a strict set of performance measures as proxies for quality, the new MACRA-based programs will focus on a mix of quality, resource use and clinical practice use measures, along with measuring meaningful use of certified EHR technology. Under these terms, health systems could conceivably enjoy both greater freedom and better payoffs.
However, given health systems’ experiences to date, particularly with ACOs, I’m skeptical that they’ll be able to pick up the ball and run with the new incentives off the bat. For example, health systems have been abandoning CMS’s value-based Pioneer ACO model at a brisk clip, after finding it financially unworkable. One recent case comes from Dartmouth-Hitchcock Medical Center, which dropped out of the program in October of last year after losing more than $3 million over the previous two years.
I’m not suggesting that health systems can afford to ignore VBP models, or that sticking to MU incentives as previously structured would make sense. But if the process of implementing MACRA gives the industry a chance to do more preparing for value-based payment, it’s probably a good thing.