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ONC To Farm Out Certification Testing To Private Sector – MACRA Monday

Posted on August 14, 2017 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

EHR certification has been a big part of the meaningful use program and is now part of MACRA as well. After several years of using health IT certification testing tools developed by government organizations, the ONC has announced plans to turn the development of these tools over to the private sector.

Since its inception, ONC has managed its health IT’s education program internally, developing automated tools designed to measure health IT can compliance with certification requirements in partnership with the CDC, CMS and NIST. However, in a new blog post, Office of Standards and Technology director Steven Posnack just announced that ONC would be transitioning development of these tools to private industry over the next five years.

In the post, Posnack said that farming out tool development would bring diversity to certification effort and help it perform optimally. “We have set a goal…to include as many industry-developed and maintained testing tools as possible in lieu of taxpayer financed testing tools,” Posnack wrote. “Achieving this goal will enable the Program to more efficiently focus its testing resources and better aligned with industry-developed testing tools.”

Readers, I don’t have any insider information on this, but I have to think this transition was spurred (or at least sped up) by the eClinicalWorks certification debacle.  As we reported earlier this year, eCW settled a whistleblower lawsuit for $155 million a few months ago;  in the suit, the federal government asserted that the vendor had gotten its EHR certified by faking its capabilities. Of course the potential cuts to ONC’s budget could have spurred this as well.

I have no reason to believe that eCW was able to beat the system because ONC’s certification testing tools were inadequate. As we all know, any tool can be tricked if you throw the right people at the problem. On the other hand, it can’t hurt to turn tool development over to the private sector. Of course, I’m not suggesting that government coders are less skilled than private industry folks (and after all, lots of government technology work is done by private contractors), but perhaps the rhythms of private industry are better suited to this task.

It’s worth noting that this change is not just cosmetic. Poznack notes that with private industry at the helm, vendors may need to enter into new business arrangements and assume new fees depending on who has invested in the testing tools, what it costs to administer them and how the tools are used.

However, I’d be surprised if private sector companies that develop certification arrangements will stay tremendously far from the existing model. Health IT vendors may want to get their products certified, but they’re likely to push back hard if private companies jack up the price for being evaluated or create business structures that don’t work.

Honestly, I’d like to see the ONC stay on this path. I think it works best as a sort of think tank focused on finding best practices health IT companies across government and private industry, rather than sweating the smaller stuff as it has in recent times. Otherwise, it’s going to stay bogged down in detail and lose whatever thought leadership position it may have.

The MACRA (QPP) API – MACRA Monday

Posted on August 7, 2017 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program (QPP) and related topics.

When the MACRA program was announced, CMS also announced a new API for MACRA as well. In that announcement, CMS really just mentioned that the MACRA API would give developers access to the complete list of Advancing Care Information (ACI), Improvement Activities (IA), and quality measures for QPP 2017 (now called the QPP Measures Data Repository). While it was nice of them to offer this API, it really didn’t seem that useful.

Since then, CMS has launched what they call the QPP Submissions APIs which allow developers to submit MACRA data to CMS. This is much more useful and something that I believe will be adopted by many EHR vendors, data registries, etc.

Here’s a quick look at what these MACRA APIs can do:

  • Submissions API
    • Submit data as a single file or a set of smaller files throughout the reporting period, using QRDA-III or a new, streamlined QPP data format
    • Submit, update or delete ACI, IA and quality measures data during the reporting period
    • Receive feedback on the content and accuracy of a submission
    • Receive the preliminary score for a submission, based on the finalized policy
  • CMS Web Interface API
    • If you are registered for the CMS Web Interface, download your group’s beneficiary sample, modify it and submit it to the CMS Web Interface
    • Receive feedback on the content and accuracy of a submission
    • Receive a real-time composite score for a submission

For those that prefer a picture explanation of how the API works, you’ll enjoy this diagram of the current process and how the API works:

It’s great to see CMS really embracing APIs as part of MACRA. Now if we could just get the rest of healthcare and EHR vendors to implement high quality APIs.

MACRA Twitter Roundup – MACRA Monday

Posted on July 31, 2017 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program and related topics.

There’s always a lot of activity on Twitter that’s relevant and interesting and this is particularly true for MACRA. So, I thought it would be fun for this MACRA Monday to do a roundup of some of the recent tweets providing resources, information and perspective on MACRA.


This is an important list to know about if you’re participating in MACRA. Make sure you’re using an approved registry (QCDR for those following along at home). I wish it wasn’t a pdf, but it is CMS.


This is a great side by side comparison for those preparing for what’s coming in MACRA 2018. I also found it interesting to see that it outlines MACRA’s main goals as:

  • Improve Health Outcomes
  • Spend Wisely
  • Minimize Burden of Participation
  • Be Fair and Transparent

I think if those are the goals, they might have the wrong program.


This is many doctors views of MACRA. Although, Kris Held, MD is very vocal about it. Her Twitter profile even says she has a mission to get government out of medicine. I don’t think enough doctors are going to follow her lead and opt out, but we’ll see very soon.


This tweet just made me laugh. I guess there’s a Miss Macra. I’m not sure what the Miss Macra Festival is, but I find it hilarious when terms overlap like this. Not really the point of MACRA Monday, but I thought you might enjoy the laugh that I got from the odd overlap.

HHS Office of Inspector General Plans To Review $1.6 Billion In Incentive Payments – MACRA Monday

Posted on July 24, 2017 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program and related topics.

The HHS Office of Inspector General has announced plans to review the appropriateness of a walloping $14.6 billion of incentive payments made to providers over a five-year period.  The upcoming report, which follows on a GAO study naming improperly issued incentive checks as the biggest threat to the Medicare EHR incentive program, addresses payments made between by CMS between January 2011 and December 2016.

The OIG’s current audit plans follow on research it previously conducted which estimated that the incentive program had wrongfully paid out $729 million incentive payments between just May 2011 and June 2014.

To conduct that review, the OIG sampled incentive payment records for 100 eligible providers, then used the level of erroneous payments found among them to extrapolate the total amount paid out wrongly by CMS during those three years.

This time around, the watchdog organization plans to audit all payments made during the entire past life of the incentive program, an exercise which could generate some even more dramatic numbers. If the prior research is any indication, the OIG could conclude that roughly 10 % to 12% of the entire $14.6 billion in incentive payments it issued shouldn’t have been made in the first place.

Of course, looked at one way this effort could be seen as closing the incentive door after the horses have left. Meaningful Use, by all accounts, is giving way to incentives under MACRA, which will apply distinctive criteria to its incentive payment formulas. Also, while I’m no numbers whiz, seems to me that you can’t really model the entire meaningful use program effectively using just 100 sample cases.

That being said, it does seem likely that the audit will find more situations in which physicians hadn’t submitted he right self-attestation data or couldn’t prove what they asserted, and if the federal auditor has any role to play, this research is probably a good idea

Sure, nobody wants to be audited, particularly when your healthcare organization has jumped through many hoops to comply with meaningful use rules. Even if you can afford to pay back your incentive money, why would you want to do so? And particularly if you’ve already played by the rules, you certainly wouldn’t want to prove it again. But since the audit is going to happen anyway, perhaps it’s best to get any possible pain it may generate out of the way.

To date, I haven’t read anything suggesting that CMS has immediate plans to claw back incentive payments from providers. My assumption, though, is that they will eventually do so. Governments need money to get their job done, and audits theoretically offer the added benefit of tightening up important initiatives like this one.

As someone who has worked exclusively in the civilian world, I have often made fun of the plodding pace at which federal and state government agencies operate. In this case, though, a slow, deliberate process — such as a gradually-widening payment review — is likely get the job done most effectively. Let’s establish carefully which incentive payments may have been issued inappropriately and clear the decks for MACRA.

eClinicalWorks Settlement Raises Question Of Customer Liability

Posted on July 19, 2017 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

Not much ago, my colleague John Lynn shared the news that EMR vendor eClinicalWorks had settled a whistleblower lawsuit for $155 million. The U.S. Department of Justice found that the vendor had skirted many EMR certification requirements, which in turn had caused providers using its software to file false claims for Meaningful Use incentives.

Today, I read an interesting follow-up by Becker’s Hospital Review addressing the issue of whether eCW users faced any liability for the vendor’s failure to meet certification standards.  The Becker’s writer, who reached out to CMS to find out its policy on the matter, found that while eCW’s customers technically submitted false claims for MU reimbursement, the agency won’t be asking any them to return any of the money.

If anyone has calculated how much CMS paid them, I haven’t seen the figures, but I’m sure it’s a pretty substantial sum of money. It’s good to see that the feds aren’t putting the squeeze on these customers, who presumably weren’t aware of eCW’s apparent skullduggery.

The thing is, I find it hard to believe that eCW is the only vendor who fudged things to get certified for the MU program. In fact, I’d guess that virtually every vendor in the industry has skirted if not crossed the line when it comes to EMR certification. That’s the way it goes, realistically, when you’re dealing with federal oversight.

After all, doesn’t every company work to save as much on taxes as they can? Yes, some are very conservative and only take whatever deductions they see as clearly legal, but others push harder. A goodly number of firms are willing to adopt strategies a tax lawyer might call “aggressive” – which don’t clearly violate the law but may raise a few eyebrows – in an effort to maximize their profits.

The big question here is whether an EMR customers could be on the hook for incentives paid wrongly due to an invalid vendor certification. If vendors are coloring outside the lines, it’s likely some will be caught, and if so, I’m betting that CMS will eventually get tough with their customers.

In the absence of clear evidence of customer wrongdoing, CMS might let customers keep their incentive payments. But I imagine that under some circumstances, the agency might wonder if they knew they what was going on and decided to take, say, a price cut in exchange for keeping its mouth shut.

Also, particularly if other vendors are hit with whistleblower suits, CMS might decide that customers should have validated that the EMR they were using actually had a legitimate certification. I don’t know how (or if) EMR customers would do this, but I can imagine a scenario under which CMS might take this tack.

Bottom line, we’d all better hope that CMS doesn’t decide to audit every vendor’s EMR certification filings. As I see it, their customers could easily be caught in the backlash.

The Health Plans’ Role in Meeting MACRA Requirements – MACRA Monday

Posted on July 17, 2017 I Written By

The following is a guest blog post by Karen Way, Health Plan Analytics and Consulting Practice Lead at NTT DATA Services. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

When the Medicare Access and CHIP Reauthorization Act (MACRA) became an official federal ruling for the healthcare industry in 2015, the act replaced the previous Medicare reimbursement schedule with a new pay-for-performance program focused on quality, value and accountability. In short, the legislation rewards healthcare providers for quality of care, not quantity.

While many discuss the impact on providers, what is the health plans’ role in aiding health systems and physicians to meet MACRA requirements?

MACRA provides multiple opportunities for health plans to increase and improve collaboration with provider networks. Recommendations on how health plans can accomplish this include sharing information and services, creating new partnerships and bringing about financial awareness as the legislation continues to take effect.

Sharing Data

One of the requirements under MACRA is for providers to enhance clinical measures and data analytics to strengthen members’ experiences. Health plans can assist by recognizing where providers lack expertise in data-related facts to offer input and support where it’s most beneficial.

For example, a provider may not have as much knowledge on advanced data science, but health plans can share their predictive models and tools to strengthen analytics. Sharing advanced technical infrastructure to facilitate data exchange will enable providers to access a more complete picture of members’ profiles. In return, the picture will provide a higher quality service to individual members, as well as opportunities for health plans to continue offering tailored consulting and data support.

At its best, sharing data to improve clinical measures is a win-win scenario. The Healthcare Effectiveness Data and Information Set (HEDIS) is a tool used by more than 90 percent of America’s health plans to measure performance on important dimensions of care and service. Just as HEDIS calls for measurement, MACRA also encourages health plans to aid providers with reporting standards. Under these rules, health plans are required to record a wealth of information on members, and when shared with providers, the tide lifts all boats.

Partnering to Manage Risk

Some of the changes under MACRA are reminders for providers to be highly aware of risk management. Providers will seek strong partners with the necessary skills, experience and knowledge to ensure they do not take on risk greater than they can support. To assist, health plans should enter into risk-sharing relationships, such as value-based contracts, with high-performing providers.

Health plans should actively strive to be strong partners by enabling robust data analytics that support quantitative action plans in the areas of quality and clinical care gaps, medical cost and trend analysis, population health, as well as member-risk management. As health plans partner with providers, they should also stay flexible on potential changes to provider payments as the pay-for-performance model(s) mature over time.

Financial Awareness

Health plans also need to be aware of the financial considerations that result from increased value-based contracting for small and large providers.

Under MACRA, smaller providers and individual physicians are more likely to be exposed to potential increase in costs, which may result in additional provider considerations. As Medicare payments shrink, these providers will look to shift costs to other payers, making contract negotiations more difficult and potentially increasing unit costs for some services. Large physician groups, or those located in markets with progressive healthcare systems, will look to negotiate even higher reimbursement rates due to the potential for increased competition.

Health plans should also be aware of potential impacts beyond Medicare fee-for-service (FFS), which is the initial focus of the MACRA legislation. Pay-for-performance is likely to extend beyond Medicare FFS into other health plan lines of business, such as Medicaid or commercial plans. For example, under MACRA, Centers for Medicare and Medicaid Services stated it would consider permitting Medicaid Medical Homes to count as an alternative payment model if participating practices would risk at least four percent of their revenue in 2019 and five percent in 2020.

Why This Matters

Overall, MACRA creates a tall order as it aims to increase pay-for-performance and decrease care based on quantity. This notion is an altruistic adjustment for the health system and each party has a specific role to play to achieve the dream. But the backbone of this goal is collaboration between health plans and providers. Collaboration will result in shared clinical measures, awareness and management of risk, lower healthcare costs and, most importantly, improved patient outcomes.

The Top Three Hidden Impacts of MIPS – MACRA Monday

Posted on July 10, 2017 I Written By

The following is a guest blog post by Tom S. Lee, PhD, CEO & Founder, SA Ignite. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

While most providers know the Merit-based Incentive Payment System (MIPS) will have escalating financial impacts, there are additional strategic and operational concerns that go along with managing MIPS participation. The MIPS score will impact areas beyond just clinicians’ Medicare reimbursement, including public reputation, clinician recruiting and compensation, and reporting for participants in alternative payment models (APMs).

  1. Public Reputation

Clinicians participating in MIPS and most Medicare accountable care organizations (ACOs) will have a MIPS score that determines their Medicare Part B reimbursement. The same score can impact public reputation because CMS will publish the scores on the Physician Compare website and make the data freely available to the public. Companies like Google, Healthgrades, Consumer Reports, Yelp, and others can use that data to incorporate the MIPS score into its clinician ratings and review systems. If an organization chooses to do just the minimum in 2017 to avoid the penalty, it means its clinicians could have a public performance score as low as 3 out of 100, while competitors who fully perform and report could have much higher publicly reported scores.

MIPS scores become a permanent part of each clinician’s resume because CMS binds the annual score to the clinician’s unique national provider identifier (NPI). So even if a clinician switches organizations, the historical score, along with the reimbursement or penalty, will follow the clinician, with the new organization absorbing the financial impact earned by the clinician up to two years prior at a different organization.

Estimates indicate that the revenue impact of consumers swayed by MIPS scores can be significantly larger than just the direct reimbursement impacts of MIPS. According to this article, a 1-star increase on Yelp leads to 5 to 9 percent increase in a business’ revenue. Using CMS’ data on Medicare Part B payments by specialty, this could mean an increase ranging from $4,468 to $8,042 per year per clinician for an internal medicine doctor and up to $10,705 to $19,269 per year per clinician for a cardiologist.

And, it may be much harder to convince a consumer who did not select a clinician based on an unfavorable MIPS score to re-evaluate that clinician in the future, even if the clinician’s score ultimately increases.

  1. Clinician Recruiting and Compensation

Understanding a clinician’s historical MIPS scores will be important to an organization properly evaluating and contracting with that clinician. When recruiting new clinicians or acquiring practices, healthcare organizations are mindful that they can inherit poor scores from other organizations’ program decisions. Conversely, clinicians will increasingly seek to join organizations with a good track record enabling its clinicians to achieve high MIPS scores, which positively impacts the resumes of all those clinicians.

In addition, organizations are seeking to align clinician compensation with MIPS financial and reputational impacts so look for an increasing number of compensation plan designs to directly incorporate MIPS scores and category scores as key performance indicators.

  1. Reporting Obligations of APM Participants

Although a healthcare organization may make a strategic decision to join an Alternative Payment Model (APM), such as a Medicare Shared Savings Program Accountable Care Organization (ACO), clinicians who are part of that organization are not necessarily exempt from MIPS. For example, if a clinician joins the organization after the final August 31st CMS determination of APM participation, then those clinicians will still need to fully report for MIPS or face a penalty. This is true for late-joining clinicians in both MIPS APMs as well as Advanced APMs, which typically qualify for a MIPS exemption.

Regardless of when clinicians join a Medicare Shared Savings Program (MSSP) Track 1 ACO, the ACO must manage MIPS eligibility, performance, and reporting for all clinicians, in addition to its ACO program obligations. This stems from the fact that MSSP Track 1 ACOs are not Advanced APMs.

How to Engage Clinicians Regarding MIPS

Beyond educating clinicians and leadership about the hidden impacts of MIPS, much of the important work to be successful under MIPS involves engaging clinicians in taking ownership of their responsibilities under the program. Some best practices:

  1. Recognize the importance of patient and clinician satisfaction
    • Reinvigorate support from leadership on the importance of both pillars
  2. Collaborate with clinicians
    • Let their voices be heard regarding both the explicit and hidden impacts of MIPS
  3. Provide feedback loop to clinicians and staff teams
    • Clinicians want to understand how they are being scored and where they have the best opportunities to improve
  4. Provide transparency
    • Communicating successful as well as failed efforts and the learnings accrued builds trust

Independent Primary Care Practice Success and MACRA – MACRA Monday

Posted on July 3, 2017 I Written By

The following is a guest blog post by Christina Scannapiego who currently writes the technical documentation and educational content for HealthFusion MediTouch. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

Can participating in a PCMH and programs like Chronic Care Management improve your MIPS total score?

The shift to fee-for-value healthcare may feel like discouraging, foreign territory. However, if you’re already participating in value-based models like a patient centered medical home or chronic care management, your practice is more poised for success during this transition.

Chronic Care Management

The Centers for Medicare and Medicaid Services (CMS) have increased reimbursement for Chronic Care Management (CCM) services. Now, a provider has the potential to earn more than $50,000 per year under the CCM program. Patient-centered care, patient engagement and better care coordination are the core objectives of CMS. Participation in CCM could weigh heavily on your total MIPS score. CCM helps patients by extending care support beyond face-to-face appointments. Participation in this program will help you move the needle in four performance categories by extending care between office visits, controlling costs, increasing care coordination, enhancing doctor-patient relationships to help improve patient outcomes.

CCM and MACRA overlap across several MIPS components:

  • Advancing Care Information: Previously Meaningful Use, meant to achieve patient engagement and promote the electronic exchange of information, practice analytics and reporting capabilities using an EHR.
  • Quality measures: At least 30 measures including many high priority items are common to the CCM program.
  • Clinical Practice Improvement Activities: Patient engagement is one of the main objectives of both CCM and MACRA. Providing 24/7 access to clinicians and coordinating care across provider settings plays an integral part in the CCM objectives and will boost your score in this performance category.
  • Cost: Although providers aren’t responsible for reporting data in this performance category, participating in CCM can lower costs due to preventable hospitalizations from poor medication adherence and care transitions to other providers. Patients with multiple chronic conditions can often pose the highest costs in healthcare. Effectively managing the care of patients will ultimately benefit their overall well-being and the health of your practice.

Patient Centered Medical Home

The PCMH model was established to help deliver patient-centered care through care coordination, preventative services, population health management and extended access to care services. This model thrives from robust patient engagement, which is one of MACRA’s most important goals. MIPS scoring methods favor those participating in PCMH by automatically scoring providers with 100% in the Advancing Care Information performance category. PCMH recognized practices will also likely get credit in the Advancing Care Information performance category because of their experience with NCQA standards.

The importance of both CCM and PCMHs in the new healthcare regime have placed primary care physicians in a unique and opportune position; one in which the independent provider stands to find success amidst change. The impact of MACRA on healthcare is “monumental” and “herculean,” said the Director of Provider Innovation Strategies at DST Health Solutions in her presentation, “The Role of PCMH Under MACRA.” MACRA isn’t a momentary, passing legislation — it’s had bipartisan support from the beginning and it’s here to stay. Luckily for PCHM and CCM participators, this new legislation and enormous impact becomes more manageable.

About the Christina Scannapiego:
Christina Scannapiego has been a technical, health and lifestyle writer for more than 10 years. Christina currently writes the technical documentation and educational content for HealthFusion MediTouch, an Electronic Health Records software platform. HealthFusion and its MediToch cloud software suite is a subsidiary of Quality Systems/next Gen. MediTouch is comprised of a range of web-based software solutions for physicians, medical practices and billing services.

2018 QPP Proposed Rule: What it Means for MIPS & Quantifying the Impact on Specialty Practices – MACRA Monday

Posted on June 26, 2017 I Written By

The following is a guest blog post by Justin Barnes, Board Advisor at iHealth Innovations. This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

The Centers for Medicare and Medicaid Services (CMS) recently released a Proposed Rule highlighting recommended updates to the 2018 reporting period of the Quality Payment Program (QPP). Like flexibilities extended in 2017, the proposal seeks to further reduce reporting burdens on small practices and rural providers in the program’s second-year reporting period.

Merit-based Incentive Payment System (MIPS) reporting track updates include:

  • Increased low-volume exemption thresholds (<200 patients or <$90,000 in payments)
  • New virtual group options for solo practitioners and groups with 10 or fewer Eligible Clinicians
  • Extending “pick your pace” flexibilities into 2018
  • Postponing introduction of the Cost category to MIPS composite scores
  • Factoring MIPS performance improvements into quality scores
  • Permissions for facility-based providers to report through the facility where they do most of their work instead of the practice
  • Permitting the use of 2014 CEHRT in 2018 reporting

The Rule introduces new MIPS bonus point opportunities for:

  • The use of 2015 CEHRT
  • The care of complex patients

Recommendations also extend small practice relief including:

  • Up to 5 bonus points for practices with 15 or fewer Eligible Clinicians
  • Hardship exemption for Advancing Care Information category measures
  • Additional points on Quality measures that don’t meet completeness requirements

Comments on the Proposed Rule are due by August 21, 2017. Physicians have until October 2, 2017, to begin collecting performance data for the inaugural 2017 MIPS reporting period.

Calculating MIPS: The Financial Impact on Specialty Practices

Results from a crowdsourced survey fielded by Black Book Research among nearly 9,000 physician practices from February through April of 2017 reveal that 94 percent of physician participants were unaware or unsure of how to predict their 2017 MIPS performance scores. Seventy-seven percent of practices with three or more clinicians reported intentions to purchase MIPS compliance technology solutions by the fourth quarter of this year, largely driven by an inability to independently determine earning potential under MACRA.

Orthopedics, cardiology and radiology are among the highest incentivized specialties under MIPS. To help specialty practices quantify the fiscal impact MIPS poses, we evaluated average Medicare earnings by specialty to establish the MIPS calculations below. These estimates are based on bare minimum earnings and losses that could be greater for practices with larger Medicare patient populations and/or more physicians. (Calculations are strictly illustrative estimates.)

Cardiology Practices
Estimated average payment adjustment for a 5-clinician cardiology practice in 2019 alone: $43,601
Number of cardiology-specific QPP measures: 20

Orthopedics Practices
Estimated average payment adjustment for a 6-clinician orthopedics practice in 2019 alone: $34,603
Number of orthopedics-specific QPP measures: 21

Radiology Practices
Estimated average payment adjustment for a 6-clinician radiology practice in 2019 alone: $30,117
Number of radiology-specific QPP measures: 22

Note: The above projections assume the full incentive and penalty will be paid out as outlined in the MACRA law. However, the positive and negative payment adjustments will be scaled so the program is budget neutral. This means that the positive payment adjustments will have to be offset by penalties.

Navigating the Transition to MIPS
As clinicians prepare for reporting under MIPS, establishing specialty-specific expertise on financial, clinical and technical objectives can help practices thrive rather than just survive.

Tips as you for prepare for MIPS:

  • Know your reporting options and pick your path.
  • Choose measures that play to the strengths of your specific specialty practice. Review your current billing codes and Quality and Resource Use Report to help determine these areas.
  • Do a technology asset inventory to make sure you can track the required CQMs.
  • Customize your EHR for track your selected measures or ID an outsource vendor to assist.
  • Work towards minimum reporting requirements to avoid a penalty with a stretch goal to report on the full required measures to maximize positive adjustment earnings potential.

Additional resources:
QPP website
An overview and support documentation is available at the CMS QPP website here.

MIPS EDU Program
A new “Quality Payment Program in 2017: Pick Your Pace Web-Based Training” course with Continuing Education Credit is available through the Learning Management System. Learn more here.

2017 CMS-Approved Qualified Clinical Data Registries
Additional specialty-specific measures are available via approved 2017 QCDRs to meet MIPS reporting requirements. Options for cardiology, radiology and orthopedic practices are included. Learn more here.

About the Author:
Justin Barnes is a nationally recognized business and policy advisor who serves as Chairman Emeritus of the HIMSS EHR Association as well as Co-Chairman of the Accountable Care Community of Practice. As Board Advisor with iHealth, Justin assists providers with optimizing revenue sources and transitioning to value-based payment and care delivery models. Justin has formally addressed Congress and the last three Presidential Administrations on more than twenty occasions on the topics of MACRA, value-based medicine, accountable care, interoperability, consumerism and more. He is also host of the weekly syndicated radio show “This Just In.” Justin can be found on Twitter at @HITAdvisor.

MACRA Video Training – MACRA Monday

Posted on June 19, 2017 I Written By

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of InfluentialNetworks.com and Physia.com. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

This post is part of the MACRA Monday series of blog posts where we dive into the details of the MACRA Quality Payment Program.

I did a quick search on YouTube for the term MACRA and it found 23,300 search results. It’s not surprising to find so much MACRA content. It seems to me that healthcare has an insatiable appetite for MACRA information.

While it’s great that so many organizations are producing MACRA content, no doubt some of it is not all that valuable and a bunch of it isn’t accurate. Case in point, the first video returned in the YouTube search for MACRA was a video from eClinicalWorks (eCW). Is there anyone that would want eCW to train them on government regulations after the recent eCW settlement that revolved around their decision to not properly certify their EHR and the meaningful use program? Maybe all the information is accurate, but that’s not where I’d go to for my source of MACRA information.

If you wanted a really brief, high level overview of MACRA, I found this 2 minute cartoon video from MediSync to be a nice intro to the intent of MACRA:

If you want a much more in depth look into MACRA’s MIPS program, you’ll want to check out Answers Media’s 25 videos in their The ABCs of MIPS series:

We all know that the government MACRA website is the first place to go for really high quality MACRA information. Do you have another go to source for your MACRA information that we should know about? Let us know in the comments.