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MIPS Penalties Include Medicare Part B Drugs – MACRA Monday

Posted on November 13, 2017 I Written By

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.

I’m sure most regular readers can tell that we’re pretty worn out and tired of MACRA, MIPS, and related government regulation. No doubt you’ll see us posting fewer MACRA Mondays going forward, but we’ll still try to cover major MACRA events as they occur. We just won’t be publishing MACRA Monday every Monday like we’ve been doing.

Jim Tate recently posted about the Real MIPS Timeline which included:

  • Phase 1 – Denial
  • Phase 2 – Shock/Anger
  • Phase 3 – Acceptance

You should read his full writeup, but he’s right. There’s a lot of denial that’s going to lead to shock and anger until the majority of healthcare have to finally accept that MIPS and MACA aren’t going anywhere.

Jim Tate also wrote another important piece related to the MIPS penalties and Medicare Part B drugs. You can read the full details of the change, but for those too lazy to click over, here’s the summary:

  • Many organizations argued that Medicare Part B Drug Costs Shouldn’t be Included in the MIPS Penalties (I mean…payment adjustments)
  • The MACRA Final rule still includes Medicare Part B drug costs (for the majority of people) in the MIPS reimbursement and eligibility calculations

If you’re a practice with a high volume of part B drugs, you better start figuring out your MIPS strategy now! Otherwise, that payment adjustment is going to hit pretty hard.

Thanks Jim for the great insights into MACRA and MIPS. If you need help with MIPS, be sure to check out Jim’s company MIPS Consulting.

MACRA Twitter Roundup – MACRA Monday

Posted on October 30, 2017 I Written By

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.

We took last week off from our MACRA Monday series of blog posts. It seems like we’re in a kind of lull period for the program. Either you’ve started collecting the data you’ve needed or you haven’t. Plus, we’re kind of waiting for the next MACRA Final rule to drop for more details.

With that in mind, I did want to see what some of the latest things that were being shared on Twitter when it comes to MACRA. I found a lot of strong opinions about the program, some good resources, and some forward-looking thoughts on what could be coming in the next MACRA final rule.


It’s hard to argue with John. Not just because he’s a smart guy, but because he’s right that it’s hard to imagine a path forward that’s fee for service and doesn’t include a shift to value based care in some form or fashion. At least given the current market dynamics.


This caution from Workflow Chuck should have us all nervous about the shift. I see a lot of healthcare organizations going after the target as opposed to the goal of value based care.


MACRA is going to impact your biz. I liked the way Kelly broke it out into 4 areas. No doubt some of these things could be argued both ways.


This is still how most doctors I know feel about MACRA and even meaningful use before it. They feel like they’ve been thrown under the bus.

Here are two forward looking resources that look at what we might get from the MACRA Final Rule:

What else are you hearing about MACRA? Would love to hear your thoughts, insights, questions, perspectives, rants, etc in the comments.

Optimizing Your EHR for MIPS and Other Quality Payment Programs – MACRA Monday

Posted on October 9, 2017 I Written By

The following is a guest blog post by Meena Ande currently acts as Director of Implementation for Advantum Health. 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.

As quality reporting requirements ramp up under value-based payment programs like MIPS, healthcare organizations are busy retrofitting their EHRs to make way for new measures. In some settings, not much has changed by way of tech utilization since initial EHR investments were made. Many outpatient settings still lack the internal expertise needed to optimize their implementations.

The truth is many EHRs have the functionality providers need for quality reporting, but many providers don’t know that due to limited exposure to the system. Couple that stunted tech knowledge with the well documented lack of familiarity with MACRA and the recent rise of the service model in healthcare is no surprise. Many practice administrators are relying on their EHR vendor or engaging outside experts to help lead the charge on system reconfiguration to meet Quality Payment Program demands.

There are several EMR capabilities providers can take advantage of to support QPP reporting efforts. Here are a few tips to keep in mind as you customize your EHR for MIPS and other value-based models.

Don’t boil the ocean when selecting CQMs.

Most EHRs give the option of tracking more than what is required for quality reporting. Initially, track applicable measures that exceed reporting requirements. After three to four weeks you’ll know which are your strong areas. Pick the best of the litter and proceed.

Providers can be overwhelmed by too many measures, particularly in multi-specialty practice settings. While it can be difficult to find overlap in measures between specialties, taking advantage of shared metrics whenever possible can reduce reporting burdens. Sit down as early as possible and develop an EHR configuration that works for your practice’s various clinicians.

Case in Point:

A gastroenterologist and a cardiologist may work in the same multi-specialty organization and on the same EHR, but the clinical quality measures they care about differ. There is no reason to give the gastroenterologist access to the cardiology problem list in the EHR. Specialty views improve ease-of-use and support more complete documentation.

Most EHRs offer role-based and specialty-based customization. Administrators can enable or disable EHR features related to some quality measures at the practice level and sometimes at the individual provider level. Clinical quality measures are based on details about the patient, but what is captured at each point of care should be tailored to the specific provider role.

Consider the roles impacted by different CQMs.

Keep the role of the person who may be responsible for different quality measures and Advancing Care Information workflows in mind when selecting and carving out space for CQMs in your EHR. Select measures that spread reporting work across multiple roles to relieve clinicians of unnecessary burdens.         

Case in Point:

The insurance eligibility verification required under Meaningful Use is managed by the front office. Front-office staff members should be made aware of the processes they need to complete before a patient checks in, and where to document that task in the EHR.

Control what is included in MIPS denominators.

Like Meaningful Use, patient encounter volume is important under MIPS. The size of the patient pool under any given quality measure directly impacts your adherence percentage. While most primary care encounters do meet patient visit requirements under MACRA, that is not always the case in specialty settings. Clinicians can exercise some control in determining what is included in patient denominators when reporting under MIPS.

Case in point:

Some primary care visits can be omitted. Let’s say a two-physician practice sees 50 patients a day. Only 15 of those patients might be seen by a physician. The rest of the patients may be there for a simple procedure like a blood pressure screening, stress test, or echocardiogram, where quality reporting elements are not verified. Such visits should be excluded.

Evaluate your reporting paths.

MIPS offers both EHR-based and registry-based reporting paths. Most specialties can submit CQM data via their EHR while others will have to rely on paid registry reporting. Additional reporting options might include submitting through associations that member clinicians are affiliated with, or through registries created by large hospital affiliates to help related providers.

Another hurdle for clinicians is deciding whether to submit data as a group or independently. Groups interested in participating in MIPS via the CMS web interface or administering the CAHPS for MIPS survey had until June 30, 2017, to register. Beyond that, clinicians have until the March 31, 2018, MIPS submission deadline to decide whether to report independently or as a group.

Case in point:

Big groups with different levels of EHR proficiency among providers may be better suited reporting at an individual level. Individual reporting takes more time for attestation, but the advantage is that higher-performing clinicians can avoid a penalty if the group doesn’t collectively meet reporting criteria.

Each month, sample 10 percent of EHR CQM data, including instances where criteria have been met and where it has not. Catch outliers with trouble following through on processes and extend targeted training to the team members bringing numbers down.

Conclusion

Optimizing the EHR and other tech resources providers have in place can be a huge MIPS enablement factor. Up-front customization work helps providers meet reporting requirements and save time over the long run. EHR optimization also enables future value-based care initiatives and lays the groundwork for population health management programs. Gains made in EHR use benefit the life of the practice through increased efficiency and, at the end of the day, better patient care.

About Meena Ande
Meena Ande currently acts as Director of Implementation for Advantum Health where she manages Implementation of services along with EHR optimization, with emphasis on workflow management for value-based reporting.

MACRA Preparation, Are You Ready? – MACRA Monday

Posted on October 2, 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.

I’ll admit that the timing of this week’s MACRA Monday is a bit rough for me given the tragedy that’s occurred in my town, Las Vegas. Instead of dwelling on the tragedy and the person who could do such an awful thing, it’s been amazing even in these early hours to see how many people in Las Vegas and around the world want to and are supporting the victims of this tragedy.

We heard that there was a need for blood and thought we could help. Turns out that hundreds of others had the same idea and the blood banks have their schedules full through Wednesday. We’ll go after that to replenish the blood banks that no doubt will take a while to replenish their supply.

Thanks to everyone on Facebook, Twitter, and other social media that have reached out to myself and the rest of us that live in Las Vegas. We’re in a bit of shock and it doesn’t feel real.

To keep with our tradition of MACRA Monday, I thought I could at least share this infographic from Integra Connect on how prepared specialty practices are for MACRA:

No doubt there are a lot of healthcare organizations that aren’t ready for MACRA and they are confused on how they should be ready. Hopefully, those who have read our weekly MACRA Monday posts feel better prepared than most. MACRA is upon us whether you’re ready or not. However, MACRA certainly seems much less important on this day of mourning in Las Vegas.

On this tragic day, it’s worth noting all the incredible stories I’ve heard about Las Vegas healthcare professionals that were prepared and ready for a tragedy like this. I read stories of UMC, a major Las Vegas hospital that was so full of victims that they asked to stop bringing people to UMC that didn’t have life-threatening injuries. I read of EMS people who were at home and went into the danger to help transport victims. No doubt there will be hundreds of other stories of heroism by healthcare professionals. Many that likely won’t be heard or seen, but saved people’s lives. We thank them for their preparation, care, and work that no doubt has saved hundreds of people’s lives.

A big thank you from Vegas to each of you for all of your support.

New EHR Certification Rules Including Self-Declaration – MACRA Monday

Posted on September 25, 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.

Elise Sweeney Anthony and Steven Posnack recently announced on the ONC Health IT Blog two major changes to the EHR certification program. In some ways, it shows a maturity of the EHR certification program, but in other ways, it’s ONC kind of taking a more hands off approach to EHR certification.

Here are the two big changes they made:

  1. Approving more than 50% of test procedures to be self-declaration; and
  2. Exercising discretion for randomized surveillance of certified health IT products.

The first one is really fascinating since they’re making 30 out of the 55 certification criteria as “self-declaration only.” That basically means that EHR vendors will just have to claim they meet the requirements. The ONC-ACBs won’t be certifying those 30 test procedures. In many ways, it reminds me of the meaningful use self-attestation. Does that mean that ONC-ACBs will cut their costs in half? Don’t be holding your breath on that one.

Let’s just hope that most EHR vendors don’t self-certify the way eCW approached EHR certification. Although, the eCW EHR certification issues are the perfect example of why a company self certifying their EHR software or the ONC-ACB certifying the EHR software is just about the same. I haven’t seen which test procedures will be self-declared, but my guess is that it was the ones that the ONC-ACBs weren’t really doing much to test and certify anyway. Ideally, this will free up the ONC-ACBs to dive deeper into the 25 test procedures they’ll still complete so they can avoid another eCW like incident.

Some might wonder why we don’t just take the self-declared EHR certification tests altogether if there’s no one that’s going to be checking them. What those people miss is that the self-declaration still keeps the EHR vendors on the hook for properly implementing the EHR certification criteria. If it’s discovered that they claimed to be compliant but aren’t, then the government can go after the EHR vendor for false claims.

The second change has me a little more puzzled. I’m not sure why they would want to release ONC-ACBs from the requirement to randomly audit EHR certifications. Maybe they didn’t discover any issues during their random audits and so they didn’t see a need to continue them. Or maybe the ONC-ACBs said they were going to pull out as certifying bodies if the government didn’t lighten the EHR Certification load. This is all conjecture, but they could be some of the reasons why ONC decided to make this change. They did offer the following insight into their reasoning:

This exercise of enforcement discretion will permit ONC-ACBs to prioritize complaint driven, or reactive, surveillance and allow them to devote their resources to certifying health IT to the 2015 Edition.

I wonder how many complaints the ONC-ACBs have gotten about the EHR software they’ve certified. Have they just been so overwhelmed with complaints that they need more time to deal with those complaints and so audits aren’t needed? I’d be surprised if this was the case. At this point I imagine most people with EHR certification issues will be calling the whistle blower attorneys, but I could be wrong.

All in all, I don’t think these EHR certification changes are a huge deal. It’s largely a maturing of the EHR certification program and does little to help the EHR certification burden on software vendors. Maybe the ONC-ACBs will charge a little less for their certification, but that’s always been a negligible cost compared to the development costs to become a certified EHR. I’m sure the ONC-ACBs are happy with these changes though.

What do you think of these changes? Any other impacts I haven’t described above that we should consider?

Mental Health EMRs And MIPS – MACRA Monday

Posted on September 18, 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.

Recently, I began researching the mental health EMR market on behalf of a client. I had expected to find it dwindling as a) the big EMR players have always insisted that an all-purpose EMR could be adapted to serve mental health providers effectively and b) more importantly because mental health professionals weren’t eligible for Meaningful Use payments, which presumably made them lousy sales targets for vendors.

However, my research concluded that there’s roughly a dozen mental health EMRs out there and kicking and that at least two large medical EMR vendors had bought into the mental health technology niche. (Allscripts bought a stake in NetSmart Technologies last year, and Cerner acquired Anasazi outright in 2012). With their investments, the two vendors effectively admitted that supporting mental health providers wasn’t as easy as they’d suggested.

Now, with MIPS imposing new demands on clinicians, mental health providers are likely to expect even more from mental health IT vendors, said Bob Ring, a consultant with Mica Information Systems.

Right now, few mental health EMRs defining themselves as “therapy specific” are CEHRT technology, which could become an issue if MDs on staff in a mental health setting want to meet MIPS requirements, Ring notes.

Under MIPS, psychiatrists must provide a wide range of mental health-specific data, some of which calls for specialty-related technology. For example, one category under the Clinical Practice Improvement Activity Performance Category calls for enhancements to an EMR to capture added data on behavioral health populations and use that data for additional decision-making.

But uncertified EMRs are likely to stay that way, Ring says. “Because these therapy-specific [EMRs] are generally priced very low, and it is expensive to go through the ONC certification process, it’s questionable whether many of them ever will be,” he concludes.

Not only that, things could get even trickier for both mental health clinicians and mental health EMR vendors in the future, if CMS follows through on its threat to hold therapists to the same standards as MDs beginning in 2019.

This could create chaos, however, according to my colleague John Lynn, who contends that putting mental health therapy EMRs under MIPS would be “a disaster.” Instead, mental health should not piggyback MU or MIPS, but instead, focus on incentives for mental health focused EHR incentives.

“The relationship between a mental health provider and a client is totally different than the relationship between a medical provider and their patient,” said John, whose first EMR implementation came when he rolled out a medical EMR in a health and counseling center. “Their methods of documentation are different. Their methods of billing are different. Their approach to care is different. We made it work, but it took a lot of duct tape and jerry rigging to fit it in.”

Why Delaying the Transition to 2015 Edition Technology Would Be a Problem for Patients and Families – MACRA Monday

Posted on September 11, 2017 I Written By

The following is a guest blog post by Erin Mackay, Associate Director, Health Information Technology Policy and Programs, National Partnership for Women & Families.  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.

The National Partnership for Women & Families recently weighed in on the Centers for Medicare & Medicaid Services’ (CMS) proposed rule for 2018 updates to the Quality Payment Program (QPP). In our comments, we express concerns that many of the proposed requirements would have a chilling effect on the country’s badly needed transition to a health care system that rewards quality and value over volume. Of particular concern to us is the proposed delay in clinicians’ transition to the 2015 Edition electronic health record (EHR) certification requirements.

Putting off requirements to use more advanced health IT would be a one-two punch to health transformation. First, new models of care that demand high-quality, efficient practices and coordinated care rely on robust health IT. Likewise, these new models only succeed when patients have the information – about their medications, health status, diagnoses and treatment received – they need to participate in their care and make informed decisions with their health care teams.

Here are three ways the proposed rule would delay critical functionalities that are foundational to a patient and family-centered health care system:

1) Delaying Availability of APIs for Consumer Access
It would undermine the commitment to patient engagement to delay the availability of application programming interfaces (APIs) as a way for patients and their caregivers to access, download and share health data. When available, APIs will let consumers choose from a range of apps that pull in health data from various health care providers and hospitals, helping form a comprehensive picture of their health and health care and facilitating information sharing. Gone will be the days when patients and family caregivers struggled to remember passwords for multiple patient portals, or were able to view only one aspect of their medical history at a time.

2) Slowing More Robust Collection of Demographic Data
To enhance health equity, we must first be able to identify disparities by gathering standardized, granular demographic data. Right now, certified EHRs are not designed to distinguish among Chinese, Indian or Vietnamese patients, for instance, instead collapsing these identities into a single “Asian” category. Similarly, EHRs cannot currently store structured information about patients’ sexual orientation or gender identity. In both these examples, this information has clinical relevance and is vital for improving health outcomes. For example, too often transgender individuals do not receive appropriate “gendered” preventive screenings such as Pap tests, mammograms and prostate exams.

3) Failing to Capture Information on Social Determinants of Health
In addition to better demographic information, to best support providers in delivering patient- and family-centered care, EHRs should also capture information about non-clinical factors pertinent to individuals’ health. The 2015 Edition includes a new criterion to capture relevant social, psychological and behavioral data. This includes information on financial resource strain, educational attainment, stress, depression, physical activity, alcohol use, social connection and isolation, and intimate partner violence. At the individual level, this information could help clinicians and care teams determine treatment options that address the unique needs of the patients and families they serve. To improve population health, clinicians, hospitals and community organizations need this information to identify communities that need additional support in order to get and stay healthy.

Conclusion
Overall, the proposed rule for QPP 2018 raises a number of concerns for the National Partnership, particularly the proposed delay of 2015 Edition certified health IT products. We strongly encourage CMS to maintain the current requirements and timeline for clinicians transitioning to the 2015 Edition to provide the necessary infrastructure for the kind of patient- and family-centered health system our country urgently needs.

MACRA Monday: MIPS Imposes A Major Burden

Posted on August 28, 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.

A new study by the Medical Group Management Association has concluded that most practices find participating in the MACRA Quality Payment Program to be very challenging. The study, which focuses on regulatory burdens affecting group practices, also identifies several other rule-related challenges practices face.

In its press release, the MGMA notes that almost half of practices surveyed said they spent more than $40,000 per FTE physician each year to comply with various regulations. Nonetheless, they continue to participate in programs that reward them despite the hassles involved.

According to the research, the vast majority of respondents are participating in the Merit-Based Incentive Payment System (MIPS) this year, and 72% said they expected to exceed the minimum reporting requirements.

That being said, their success clearly hasn’t come easily, with 82% of practices rated MIPS as either “very” or “extremely” burdensome. Within MIPS, groups cite clinical relevance (80%) as their top challenge. Seventy-three percent of survey respondents said MIPS doesn’t support their practice’s clinical quality priorities.

In fact, many respondents said that complying with MIPS was like pulling teeth. Over 70% reported that they found the MIPS scoring system to be very or extremely complex, and 69% said they are very or extremely concerned that unclear program guidance will impact their ability to participate in MIPS successfully.

Eighty-four percent of respondents agreed or strongly agreed that if Medicare’s regulatory complexity were reduced, they could shift more resources to providing patient care. Their frustration is palpable, as the following anonymous comment illustrates: “The regulatory and administrative burdens have dramatically increased over the past two years. However, the biggest problem isn’t the increase itself, [it’s] that the increase is for no good purpose.”

Other programs respondents named as very/extremely taxing included national electronic attachment standards (74%), audits and appeals (69%) and lack of EHR interoperability, followed by payer use of virtual credit cards (59%).

It’s interesting to note the disconnect between the number of practices participating in MIPS (and seemingly, crushing it) and the complaints most are making about participation. Clearly, given how painful it can be to comply with the rules, most practices see their involvement as necessary from a financial perspective.

It’s unlikely that this participation it will get much easier in the near future, though. Eventually, as regulators keep taking feedback and streamlining the MIPS program, they may be able to streamline its requirements, but I wouldn’t hold my breath waiting for that to happen.

Leveraging New Age Technology to Overcome MACRA Challenges – MACRA Monday

Posted on August 21, 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.

The following is a guest blog post by Dr. David A. Goldman, CEO and founder, Goldman Eye and Ophthalmology Team Lead, Anterior Segment at Modernizing Medicine.  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.

MACRA and the Quality Payment Program (QPP) were implemented by the Centers for Medicare & Medicaid Services (CMS) to improve healthcare by focusing on the quality of care provided to patients. There are two paths under the QPP: the Merit-based Incentive Payment System (MIPS) track which covers most clinicians, and the Advanced Alternate Payment Models (APMs) track which applies to providers who have taken on some risk related to patient outcomes (Medicare Shared Savings 2,3 and Next Gen ACO participants for example).

MACRA and MIPS are intended to advance quality based care by implementing outcome-based payment adjustments. Providers will be measured across a number of different performance categories and will be paid on a curve. By 2022, physicians who outperform their peers may receive up to a 9 percent positive payment adjustment on their Medicare reimbursements based on their performance in 2020. Those who report poor performance may receive up to a 9 percent negative payment adjustment on their Medicare reimbursements in 2022.

Specialtyspecific Measures & Bonus Points

As previously mentioned, if you perform better than your peers when it comes to MIPS, you can substantially increase your Medicare reimbursements. Conversely, reporting a score below the performance threshold could prevent you from receiving a positive payment adjustment on your Medicare reimbursements, and not reporting on MIPS could cause you to be penalized.

Some MIPS categories will be the same across all specialties such as Advancing Care Information and Improvement Activities, whereas others can be geared towards a specialty, like Quality. Quality accounts for 60 percent of your total MIPS score in 2017. As an Eligible Clinician (EC), you should select six measures, including one Outcome Measure or if an Outcome Measure is not available, a High Priority Measure. After your first Outcome or High Priority Measure, any additional ones you report will count towards your bonus points (up to six points). In addition, an EC can earn another six points by doing end-to-end reporting. More information on the measure specifications can be found here.

Under the Advancing Care Information (ACI) category, ECs have the option to earn 5 bonus points by being in active engagement with a specialized registry, which are typically specialty-specific. The third category of MIPS is called Improvement Activities (IAs) which has over 90 activities to choose from. ECs, regardless of specialty, can choose activities that apply to their practice size and way of practicing like expanded practice access and closing the referral loop. Depending on the IA selected, ECs can also earn a 10 point bonus under the ACI category.

How can we turn this change into an opportunity?

A major factor in succeeding in MIPS is the use of today’s latest technology. Innovative electronic health record (EHR) systems, which can collect and organize clinical data in a structured format, empower doctors to extract meaningful insights at the patient and population levels. Instead of relying on any one physician’s narrative assessment or unstructured data for a diagnosis or treatment, physicians who have access to an interoperable platform can reference relative findings from their peers while eliminating redundancies, automating communications and improving patient outcomes.

How Do You Track Your Performance

The answer is certainly not using pen and paper. Look for a certified EHR vendor that has technology which provides services and products that can track data in real time and provide analytics to show your progress and outcomes. You want MIPS intelligence directly built-in to your EHR system.

Modernizing Medicine offers a specialty-specific suite of products and services that gives physicians added support. modmed Ophthalmology™ helps ophthalmologists transition to MIPS by providing them with quality data and reporting capabilities with the products and services they provide. Included within the suite is the company’s flagship EHR system, EMA™. EMA provides functionality for automated quality data capture, population health registries, real patient engagement and analytical tools, plus the ability to submit MIPS right to CMS.

I have been utilizing EMA for the past few years and am also a team lead on Modernizing Medicine’s ophthalmology team. As a practicing ophthalmologist, I have gone through the process of spending countless hours documenting patient reporting following a long day in the office. Couple that with ensuring my compliance measures are in check – it adds up. Now, my measures are completed efficiently, accurately and securely, ready to be submitted to CMS at the end of my reporting period. I even led a webinar on the topic of MIPS, if you want to see it in action.

EHR System Checklist for MIPS

From my unique perspective of working for an EHR vendor and utilizing the certified technology in my practice, I’ve shared a few qualities to look for in an EHR to support your reporting needs:

  • 2014 / 2015 ONC Certified
  • Integrated MIPS intelligence
  • Built in Improvement Activities
  • Qualified MIPS Registry
  • Automated data capturing and reporting
  • Built-in, real-time analytics reporting for Quality, Resource Use, Advancing Care Information and Improvement Activities
  • A vendor with an all-in on solution, including the ability to submit MIPS right to CMS
  • Advisory services and consultation during MIPS transition and reporting

While there is much work to be done in terms of keeping up with and understanding today’s fast-paced healthcare landscape, one thing is for certain – the proper use of specialty-specific technology can help alleviate hours of extra work, stress and physician burnout. As noted above, there are certain aspects of MACRA that apply across all specialties, whereas others are specialty-specific and working with a vendor that can guide you along this MIPS journey can be crucial to your financial success.

David A. Goldman, M.D. is the Ophthalmology Team Lead, Anterior Segment at Modernizing Medicine and founder of Goldman Eye in Palm Beach Gardens, Fla.

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.