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Details for 3 MIPS Performance Categories – MACRA Monday

Posted on September 19, 2016 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.

Last week we got a bit side tracked on MACRA Monday as we covered the news about modifications to the MACRA timeline. That seems to be a welcome change. As we mentioned at the end of our post on the MIPS performance categories and MIPS composite score, now we’re going to start diving into the details of those performance categories starting with: Quality Performance, Resource Use (Cost), and the new Clinical Practice Improvement Activities Category.

Quality Performance Category
This category is a replacement for PQRS, but is a reduction from 9 to only 6 measures. Plus, there is no longer a domain requirement. MIPS also expands the program to include close to 300 measures. To combat this explosion of options, they’ll also be offering specialty specific measure sets so that each specialty can more easily identify the measures that might be best for their specialty.

The Quality Performance category makes up 50% of the MIPS composite score.

Resource Use (Cost) Category
The resource use category is also often called the cost category and is a replacement of the value based modifier. The great part of the resource use category is that there is no data submission required to report your work in this category. Instead, this MIPS category will be calculated based on your Medicare claims. MACRA will add 40+ episodic specific measures so providers have more options to participate in this category.

The Resource Use (Cost) category makes up 10% of the MIPS composite score.

Clinical Practice Improvement Activities Category
The CPIA (Clinical Practice Improvement Activies) category that is the new category created as part of MACRA. It will include 90+ activities to choose from and you must participate in a minimum of one activity. Small practices (ie. 15 or fewer professionals) can participate in 2 activities and receive full credit for CPIA. Practices participating as a Patient Centered Medical Home (PCMH) also receive full credit for this category. Participation in an APM gives you 50% credit.

The Clinical Practice Improvement Activities category makes up 15% of the MIPS Composite Score.

That’s the general overview for these three MIPS performance categories. We’ll cover the Advancing Care Information category next week since it’s a bit more complicated.

Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA Quality Payment Program.

Modifications to the MACRA 2017 Reporting Period #PickYourPace – MACRA Monday

Posted on September 12, 2016 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.

As we mentioned near the start of the MACRA Monday series, many were predicting a delay or at least a modification to the MACRA timeline. While we’re still waiting for the MACRA final rule to come out with the official changes, Andy Slavitt, Acting Administrator of CMS, has announced some of the changes that will be in the MACRA final rule. Here’s the introduction to why they’re making these changes to MACRA (or the Quality Payment Program as they like to call it now):

We heard from physicians and other clinicians on how technology can help with patient care and how excessive reporting can distract from patient care; how new programs like medical homes can be encouraged; and the unique issues facing small and rural non-hospital-based physicians. We will address these areas and the many other comments we received when we release the final rule by November 1, 2016.

It’s comforting to many to know that they hear doctors pleas for help with all the reporting. We’ll see if the changes in the MACRA final rule will be enough.

As part of the announcement, Andy Slavitt said that the MACRA and MIPS program will still begin on January 1, 2017 with payment adjustments (ie. incentives or penalties) being paid in 2019 like we’d noted before. However, CMS now plans to provide multiple options to eligible physicians and other clinicians to avoid the negative payment adjustments in 2019.

There will now be 4 options available:

Option 1 – Test the Quality Payment Program.
For this option, you just have to submit “some data” to the Quality Payment Program and you’ll avoid the negative payment adjustment. Basically, CMS just wants to make sure you’re connected and ready to participate in future years. While you won’t get a negative payment adjustment, you always won’t get a positive adjustment either. It will be interesting to see what the final rule defines as “some data.” I expect it will be pretty minimal.

Option 2 – Participate for part of the calendar year.
This option allows you to submit information for a reduced number of days in 2017. In other words, your performance period could start after January 1, 2017 and you could just do MIPS reporting for part of the year. This would qualify you for a small positive payment adjustment. I’ll be interested to see the details in the MACRA final rule which outlines how much smaller the payment adjustment will be and how it will be calculated.

Option 3 – Participate for the full calendar year.
This option is basically what’s in the MACRA proposed rule. You can take part for the full 2017 calendar year and potentially qualify for a modest positive payment adjustment. CMS suggests that many will be ready for this. We’ll see if that’s the case given the compressed timeline from when the final rule is published and the release cycles of EHR software companies.

Option 4 – Participate in an Advanced Alternative Payment Model in 2017.
It seems that participation in an Advanced APM is the same as the proposed rule. Of course, if you’re participating in an Advanced APM, then you avoid the penalties and don’t have to worry about MIPS. Nothing new there.

It’s no surprise that fewer penalties and looser requirements has been applauded by many in the healthcare community. It’s pretty rare that people complain about a loosening of government regulation and wish they would require more. Personally, I think the changes are a good thing. CMS will still be able to get data from organizations that participate for the full year. Hopefully, they’ll use that to guide any modifications for future years. However, they also aren’t penalizing those organizations who won’t be fully ready in 2017 because of the short timelines.

Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA Quality Payment Program.

Advanced APM Requirements and Incentives – MACRA Monday

Posted on August 8, 2016 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.

Last week we looked at the MIPS and APM programs within MACRA and who will be participating in which program. Today we’ll briefly cover some of the specific requirements to participate in the APM program and the incentives you’ll receive if you are qualified and participate as an APM.

As mentioned before, most people won’t participate in an APM, but will participate in MIPS. This is particularly true because even if you’re part of an ACO or other value based care program you may or may not qualify as what they call an Advanced APM. Last week we listed the various APM definitions for who could be an APM, but we didn’t include this other criteria that is required for an APM to be considered an Advanced APM.

  • Use Certified EHR
  • Base Payment on Quality
  • Bears Financial Risk or Medical Home Model

If you want to dig into the advanced APM criteria, you can do so in the APM webinars that CMS did. They dive into the nitty gritty details of each, but we’ll pass on covering them here since they’ve done a great job and it only applies to a small group of our readers.

If you do not qualify as an advanced APM, then you’ll need to participate in MIPS, but you’ll do so with some favorable MIPS scoring.

APM Incentives
For those organizations that qualify as an Advanced APM, starting in 2019 you’ll receive up to a 5% bonus. This bonus will continue through 2024. In 2026, the bonus will be replaced with a higher fee schedule update.

Worth noting is that the MACRA APM program creates extra incentives for those who are already participating in one of the value based reimbursement programs. The MACRA APM program does nothing to change the current APM functions or rewards values. The 5% bonus will be on top of what was already planned for APMs.

Plan of Action
If you think that you might be part of an organization or program that will qualify as an APM, you’ll need to figure out if you qualify as an advanced APM. You should be able to consult your ACO or other APM organization to find out if you’re considered an advanced APM or not. The key question you’ll want to ask is, Am I considered an Advanced APM or not? Only Advanced APMs are excluded from MIPS.

That’s the short overview of the APM program. Next week we’ll start talking about the MIPS program.

Be sure to check out all of our MACRA Monday blog posts where we dive into the details of the MACRA program.

What is MACRA? – MACRA Monday

Posted on July 25, 2016 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.

As we mentioned at the end of last week, we’re excited to start a new series of blog posts called MACRA Monday. Over the next months (and possibly year(s)), each Monday we’ll step through the MACRA legislation and share the details of MACRA with you the reader. Many of you might have read our Meaningful Use Monday series which we wrote for a couple years leading up to meaningful use. This will be similar. You can find all the latest MACRA Monday posts here.

Before we begin, it’s worth mentioning that CMS has posted all the latest updates and details related to MACRA here. That’s largely where we’ll get our information for this series, but hopefully we can provide it to you in a more digestible format. Plus, we’ll add in our own opinions, views, and comments that will hopefully add even more value. At the end of the day, like it or not MACRA and value based care is heading your way. Knowing the details about it will better help you make decisions for the future of your practice.

In all of the CMS presentations on MACRA, they always start off with a slide that includes the same image. So, I thought it would be appropriate to start off MACRA Mondays with this image as well.
CMS Move to Value
No matter what happens to MACRA and other government programs, this slide illustrates the goals that CMS wants to achieve in healthcare. They want to shift the reimbursement from the current fee for service model into alternative payment models that pay for quality and value. CMS has said that they’ve already achieved their 30% goal for 2016. I think they’re being generous with their numbers, but that’s a topic for another day. Regardless of the details, CMS has clear goals to shift the healthcare system to a value based care model. MACRA is one major element of that effort.

What is MACRA?
The recent study by Deloitte found that a large portion of doctors are unaware of MACRA. Some had heard of MACRA, but didn’t know any more details. That’s a pretty scary thing considering MACRA will impact most ambulatory practices that participate in Medicare.

At the core of the MACRA legislation was two main goals: replace the Sustainable Growth Rate (SGR) and create a single framework – quality payment program. In the case of SGR, MACRA was the long-term solution to the annual “Doc Fix” or “SGR Fix” which literally shut down our government as congress debated how to address it. Along with replacing SGR, MACRA also streamlined multiple quality reporting programs into APMs (Advanced Alternative Payment Models) and MIPS (Merit-based Incentive Payment System).

We’ll talk in more detail in future MACRA Mondays about which programs ended up where and what they look like under MACRA. For now, we’ll just say that the new APM and MIPS programs consolidated programs such as PQRS, the Value Based Modifier, Meaningful Use (Officially called the Medicare EHR Incentive Program), ACOs, and PCMH to name a few.

Before I end this intro to MACRA, it’s worth noting that the MACRA rule is still only a proposed rule. So, everything we talk about now is talking about what’s part of the proposed rule. Certainly, any and all of this could change. The MACRA comment period ended June 27, 2016 and CMS received 3,710 formal comments (some of them extremely lengthy). However, given past changes to proposed rules (or lack thereof), I’d be surprised if anything changed too dramatically. We’ll talk more about possible changes in a future post.

We’ll be back next week with another MACRA Monday talking about who will be impacted by MACRA and whether your practice should be worried about participating in the APM or MIPS program.

CMS Opens Door to Possible MACRA Delay

Posted on July 15, 2016 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.

In related news to yesterday’s meaningful use REBOOT relief legislation, Andy Slavitt, Acting Administrator of CMS, testified about MACRA before the Senate Finance committee. In his hearing, Senator Orrin Hatch (R-Utah), chairman of the committee commented “Physicians will only have about two months before the program goes live. This seems to be a legitimate concern. Considering the MACRA law does give CMS flexibility as to the start of the physician reporting period, what options is CMS considering to make sure this program gets started on the right foot?”

In response to this Slavitt responded that CMS was open to options such as postponing implementation and establishing shorter reporting periods (both of which were widely requested during the MACRA comment period).

Both Slavitt and Senator Hatch talked about the importance of the MACRA legislation not killing the small practice physician. A delay and shorter reporting periods would be a great start. However, so many small practices have been burned by meaningful use that it might be too late for MACRA. It seems that MACRA is dead on arrival for many physicians based on historical experience with meaningful use and certified EHR. I’m not sure CMS could do anything with MACRA to really stem the tide.

This is reflected in a survey that Deloitte recently did to assess physician’s awareness of MACRA. The survey found that 21% of self-employed physicians and those in independently owned medical practices report they are somewhat familiar with MACRA versus 9% of employed physicians surveyed. 32% of physicians only recognize the name.

Basically, physicians barely even know about MACRA. Although, I’m quite sure if we asked them if they liked the MACRA government legislation they’d all say an emphatic No! (Kind of reminds me of Jimmy Kimmel’s Life Witness News) It’s too bad, because if doctors have already been participating in PQRS and Meaningful Use, MACRA won’t be that bad. Of course, the same can’t be said for those that haven’t participated in either program.

During the hearing mentioned above, Senator Hatch highlighted Andy Slavitt’s comment that “the focus must be focused on patients and not measurement.” Plus, he suggested that more needed to be done in this regard. Andy Slavitt responded that they need to reduce the documentation requirements so doctors can spend more time with patients.

Take those comments for what their worth. They’re hearing the right messages and I think they’re heading the right direction. Let’s hope we see that in the MACRA final rule.

Physician Data Paradox

Posted on June 29, 2016 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.

“[Doctors] are overloaded on data entry and yet rampantly under-informed.”
-Andy Slavitt at Health Datapalooza

This quote from Andy Slavitt at Health Datapalooza has really stuck with me. He calls it the physician data paradox. It’s an ugly paradox and is at the heart of so many doctors discontent with EHR software. Andy Slavitt is spot on with his analysis. Doctors spend hours entering all of this data and get very little return value from that data or the volume of health data that is being captured.

My friend Dr. Michael Koriwchak has made an interesting request. In a recent blab interview he was on he said that CMS should only require the collection of data they’re actually going to use.

My guess is that the majority of meaningful use data would not need to be collected if Dr. Koriwchak’s rule was in place. CMS hasn’t really even collected the data from doctors, so they’re certainly not using it. Some of the principles of meaningful use would still exist like interoperability and ePrescribing, but we wouldn’t be turning our doctors into data entry clerks of data that’s not being used.

Think about the reality of meaningful use data collection: CMS doesn’t use the data. Clinicians don’t use the data.

We’ve basically asked doctors and other medical staff to spend millions of hours collecting a bunch of data that’s not being used. Does that make sense to anyone? You could make the argument that the data collection is creating a platform for the future. There’s some value in this thinking, but that’s pretty speculative spending. Why not do this type of speculative data collection with small groups who get paid for their efforts and then as they discover new healthcare opportunities? We can expand the data collection requirement to all of healthcare once doctors can do something meaningful with the data they’re being required to collect.

In fact, what if we paid docs for telling CMS or their EHR vendor how EHR data could be used to benefit patients? I’d see this similar to how IT companies pay people who submit bug reports. Not using health data the right way is kind of like reporting a bug in the health system. Currently, there’s no financial incentive for users to share their best practices and discoveries. Sure, some of them do it at user conferences or other conferences, but imagine how much more interested they’d be in finding and sharing health data discoveries if they were paid for it.

If we finally want to start putting all this health data to work, we’re going to have to solve the physician data paradox. Leveraging the power of the crowd could be a great way to improve the 2nd part of the paradox.

Is CMS Listening to Doctors’ Thoughts on MACRA?

Posted on June 10, 2016 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.

I have to admit that I have a lot of respect for Andy Slavitt. He’s doing a really hard job as Acting Administrator of CMS and he’s been very vocal and open about his view of what they’re doing and their efforts to listen to those of us in healthcare. I’ve really appreciated his willingness to engage the community on challenging topics. Did you ever see this from previous CMS administrators?

This tweet illustrates Andy’s efforts to really listen to doctors when it comes to MACRA:

This illustrates why I previously wrote that Andy Slavitt was very much in touch with the pulse of what doctors are feeling and experiencing. Although, with that comment I also said that I hoped that the policies and programs they implemented would match that understanding.

I realize that this concept is much easier said than done. Andy Slavitt and his team at CMS are sometimes not able to make changes to things like MACRA even if they know it’s the right thing to do. They aren’t the ones responsible for making the legislation. Their jobs are to implement the legislation. It’s a tough balance which always leaves people wanting.

The only thing awkward about Andy Slavitt’s tweet above is that he says CMS has “trained nearly 60,000.” It’s quite interesting that he views these MACRA sessions as trainings. I thought they were more listening sessions than training sessions, but I guess I was wrong. Certainly you have to train a doctor on the MACRA legislation if you want to get the right feedback from them. So, I guess training and listening aren’t mutually exclusive, but it’s not surprising that many doctors don’t want to be “trained” on MACRA. For some doctors, anything less than a full repeal of MACRA will be less than satisfying and that’s not going to happen.

While you can complain about the way Andy might phrase things in a tweet, I don’t think that’s very productive. Although, I don’t think listening to (or should I say training) 60,000 physicians’ thoughts about MACRA is very useful either if we don’t see that feedback incorporated into the final MACRA rule. This tweet gives me some hope that the feedback has been heard and we’ll see some important changes to MACRA:

When the MACRA final rule comes out, I hope that along with the changes that were made we also get a look into the changes that people requested that CMS was unable to make because of the way the legislation was written. I’m not sure if CMS is allowed to be that transparent, but if we’re going to help push for better legislation it would be great to know which feedback was thwarted by legislation so that doctors can push for better legislation.

Halamka Ponders The Need to Leave Medicine If We Continue Our Current Trajectory

Posted on May 5, 2016 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.

The famous Dr. John Halamka, Hospital CIO, Doctor, Former member of the HIT Policy committee, blogger at Life as a Healthcare CIO, recently read the 962 page MACRA NPRM and he wrote up a detailed look at the IT elements of MACRA. The post is worth a read if you’re interested in MACRA. Especially if you don’t want to spend the 20 hours reading it that he spent.

MACRA aside, he ends his post with this bombshell of a comment:

As a practicing clinician for 30 years, I can honestly say that it’s time to leave the profession if we stay on the current trajectory.

A doctor in the comments shared a similar view to Dr. Halamka:

Wow, I feel exactly the same as you do. As a front line ortho provider in a small group. I think now I get the message. CMS and ONC wants us out of private practice, either retire, or join as a salaried doc or hospital employee. That is the only justification for this 1000 page nightmare.

We’ve written a lot about physician burnout and many doctors distaste of all this government regulation, but having someone like John Halamka comment like this is quite telling. What’s scary for me is that I don’t see much light at the end of the MACRA tunnel from a physician perspective. Do you?

New Payment Model Pushes HIT Vendors To Collaborate

Posted on April 20, 2016 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.

CMS has launched a new program designed to shift more risk to and offer more rewards to primary care practices which explicitly requires HIT vendors to be involved at advanced stages. While the federal government has obvious done a great deal to promote the use of HIT in medical practices, this is the first I’ve seen where HHS has demanded vendors get involved directly, and I find it intriguing. But let me explain.

The new Comprehensive Primary Care Plus payment scheme – which builds upon an existing model – is designed to keep pushing risk onto primary care practices. CMS expects to get up to 5,000 practices on board over the next five years, spanning more than 20,000 clinicians serving 25 million Medicare beneficiaries.

Like Medicare payment reforms focused on hospitals, CPC+ is designed to shift risk to PCPs in stages. Track 1 of the program is designed to help the practices shift into care management mode, offering an average care management fee of $15 per beneficiary per month on top of fee-for-service payments. Track 2, meanwhile, requires practices to bear some risk, offering them a special hybrid payment which mixes fee-for-service and a percentage of expected Evaluation & Management reimbursement up front. Both tracks offer a performance-based incentive, but risk-bearing practices get more.

So why I am I bothering telling you this? I mention this payment model because of an interesting requirement CMS has laid upon Track 2, the risk-bearing track. On this track, practices have to get their HIT vendor(s) to write a letter outlining the vendors’ willingness to support them with advanced health IT capabilities.

This is a new tack for CMS, as far as I know. True, writing a letter on behalf of customers is certainly less challenging for vendors than getting a certification for their technology, so it’s not going to create shockwaves. Still, it does suggest that CMS is thinking in new ways, and that’s always worth noticing.

True, it doesn’t appear that vendors will be required to swear mighty oaths promising that they’ll support any specific features or objectives. As with the recently-announced Interoperability Pledge, it seems like more form than substance.

Nonetheless, my take is that HIT vendors should take this requirement seriously. First of all, it shines a spotlight on the extent to which the vendors are offering real, practical support for clinicians, and while CMS may not be measuring this just yet, they may do so in the future.

What’s more, when vendors put such a letter together in collaboration with practices, it brings both sides to the table. It gives vendors and PCPs at least a marginally stronger incentive to discuss what they need to accomplish. Ideally – as CMS doubtless hopes – it could lay a foundation for better alignment between clinicians and HIT leaders.

Again, I’m not suggesting this is a massive news item, but it’s certainly food for thought. Asking HIT vendors to stick their necks out in this way (at least symbolically) could ultimately be a catalyst for change.

Meaningful Use Holdover Could Be Good News For Healthcare

Posted on January 25, 2016 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.

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.