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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.

MIPS Performance Categories and the MIPS Composite Score – MACRA Monday

Posted on August 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.

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

As mentioned, next up we’re going to cover the 4 MIPS performance categories. Each of these categories are listed in the graphic below and will contribute to what is called your MIPS Composite Score.
MIPS Performance Categories

At first, these four new category names might be confusing, but here’s the translation you need to know for each category that will illustrate how MIPS really just rolls up three existing programs and adds one new program as follows:

  • Quality Performance Category – PQRS Replacement
  • Resource Use (Cost) Category – Value Based Modifier Replacement
  • Clinical Practice Improvement Activities Category – New
  • Advancing Information Category – Meaningful Use (EHR Incentive Program) Replacement

I’m not sure why the government thought we needed new names for each program, but they decided that was the best route. Maybe they wanted to leave the past behind and move forward without the baggage that exists with the previous names. Regardless, 3 of the 4 MIPS performance categories are programs that most of you probably already know about. There are slight changes with each of the 3 programs (PQRS, Value Based Modifier, and Meaningful Use) under MIPS which we’ll cover in a future part of this series. In most cases, each of those 3 programs was simplified under MIPS.

In order to determine your MIPS Composite Score, each provider will receive a score on a 100 point scale. Each of the 4 performance categories contributes to the 100 point scale and have been weighted as follows:
MIPS Performance Categories Weighting - Year 1

Yes, that means that if you are already doing PQRS (Quality) and Meaningful Use (Advancing Care Information), then you’ll be well positioned for 75% of the points for the MIPS composite score. If you’re only doing PQRS, you’re still in a position to get 50% of the MIPS composite score without too many changes from what you’re doing today. Of course, that assumes you continue those efforts under the modified MIPS requirements in 2017. If you’re not doing PQRS, meaningful use, or value based reimbursement, then you’ll have some serious work to do in order to not be penalized under MIPS.

Once CMS calculates your MIPS composite score, they’ll compare that score against the threshold to determine the adjustment received. Speaking hypothetically, let’s say the MIPS threshold was set at 64 and your MIPS Composite Score was 64. Then, you wouldn’t receive an increase or decrease to your reimbursement. Of course, if you scored above a 64, then you’d receive a bonus payment. If you score below a 64, you’d be penalized.

CMS has said they intend to publish the benchmarks and thresholds prior to 2017. Given the short time frame, this is going to be a real challenge and is likely another reason why it’s possible that MACRA could be delayed. However, it’s good to know that they’re planning to publish the MIPS threshold in advance so practices can plan accordingly. The great part of this scoring system is that unlike meaningful use which was all or nothing, this scoring gives providers credit for partial performance.

It’s worth also noting that the MACRA program must be budget neutral. So, if more providers are getting penalized than are getting incentives, the HHS Secretary will use a scaling factor to increase the incentives paid to participating providers that qualify. HHS also has $500 million available separate from the normal incentive payments to reward exceptional performance. I have yet to see details on this, but it will be interesting to watch and see what they use as the criteria for exceptional performance. I wonder how much higher of a composite score you’ll need above the threshold to be considered an exceptional performer.

Next week we’ll start going through each of the performance categories at a high level and discuss the changes made to each program that’s been rolled into MIPS and the new Clinical Practice Improvement Activities category.

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

Who’s Eligible for MIPS? – MACRA Monday

Posted on August 22, 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 MACRA.

In years 1 and 2 of MACRA, those that are eligible to participate are going to be very similar to past programs. However, the secretary does have the option in year 3 to look at expanding the program to include other healthcare providers that don’t meet the initial requirements. You can see this illustrated in the graphic below.
MIPS Eligibility

There are three exceptions to the above graphic. The first exception is if you’re a first year partipant in Medicare Part B. This gives these doctors time to get up to speed before they’re required to participate in MIPS. They will have to participate in year two. There is also a MIPS exception for low volume providers. If you’re a provider that has Medicare billing charges that are less than or equal to $10,000 and providers care to 100 or fewer Medicare patients in a year, then you are not required to participate in MIPS. The third exception is those providers that are already participating as an advanced APM (see what we wrote about Advanced APM eligibility for more details) are not allowed to participate in MIPS. Here’s a summary of these exceptions:
Not Eligible for MIPS

If all of this Advanced APM and MIPS eligibility is confusing to you, here’s a flow chart which will walk you through the process of knowing whether you’re an advanced APM, whether you must participate in MIPS or whether you’re not subject to MIPS:
APM or MIPS - Where Do You Fit Into MACRA

Next up, we dive into the details of MIPS and the 4 MIPS categories.

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

MIPS Overview – MACRA Monday

Posted on August 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.

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

The Merit-based Incentive Payment System or MIPS as we now know it is going to be a big part of most practices future. As we mentioned previously, most practices will be participating in the MIPS program as opposed to the APM program under MACRA. Here’s a quick overview of the MIPS program. Over the next months, we’ll be diving deeper and deeper into the details of MIPS.

MIPS replaces 3 programs that will likely be familiar to most readers: PQRS, the Medicare EHR Incentive Program (Better known as meaningful use), and the Value-Based Payment Modifier (VBM). The last one might not be as familiar to people, but PQRS and Meaningful Use are likely very familiar. In future posts, we’ll dive into the changes to these programs that come as they’re rolled into MIPS.

It’s worth noting that these programs will continue to run in their current from through 2018. Plus, the Medicaid EHR Incentive Program and the Medicare EHR Incentive Program for Hospitals will continue. Along with rolling the 3 current programs into MIPS, MACRA also adds a new program to MIPS called the Clinical Practice Improvement Activities (CPIA).

The first performance period for MIPS is 2017 with MIPS adjustments happening in 2019. At least that’s the way it’s listed in the proposed rule. Many are suggesting that there’s no way that MIPS will be for all of 2017. They argue that it has to be either delayed or moved to a 90 day reporting period (which is basically a 9 month delay). We’ll see what they finally decide when the MACRA final rule finally comes out.

The potential MIPS adjustments to your Medicare Part B payment are 4% in 2019 and grow to 9% in 2022. Remember that these adjustments can be both positive and negative based on how well you participate in the MIPS program. We’ll dive into the MIPS Composite Score that determines your MIPS payment adjustment in a future post. Here’s a charge which illustrates the MIPS timeline and incentives:
MIPS Incentives and Penalties
That’s all for our MIPS overview. Next up we’ll dive into who is eligible for MIPS and who is not eligible for MIPS.

You can see how if you’re already participating in PQRS, Meaningful Use, and the Value-Based Modifier, then you are well positioned to do well in MIPS. This will become even more clear when we discuss the weighted scoring that each of these pieces of MIPS receives. Of course, if you haven’t been participating in these programs, then MIPS will definitely be a pretty big hill to climb.

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

MIPS or APMs … That Is The Question – MACRA Monday

Posted on August 1, 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 outlined in the first entry of MACRA Monday, MACRA is broken down into two programs: APMs (Advanced Alternative Payment Models) and MIPS (Merit-based Incentive Payment System). The question your practice should be asking yourself is whether your practice will be participating in the MIPS or APM program. Practices will participate in one or the other, but not both.

Steve Sisko recently tweeted that CMS estimates only 4% of doctors will participate in MACRA as an APM. Regardless of the exact percentage, it’s clear that the majority of providers will need to worry about MIPS and won’t spend much time looking into the details of the APM program. As such, we’ll spend most of our MACRA Monday time diving into the details of MIPS and not APMs. However, in this post we will highlight what would make you qualify as an APM in case that applies to you.

Here’s CMS’ technical definition of who’s included in an APM:

  • CMS Innovation Center model
  • MSSP (Medicare Shared Savings Program)
  • Demonstration under the Health Care Quality Demonstration Program
  • Demonstration Required By Federal Law

In the CMS webinars, they offered this easier to understand list of who’s considered an advanced APM in 2017:

  • Shared Savings Program (Tracks 2 and 3)
  • Next Generation ACO Model
  • Comprehensive ESRD Care (CEC) (large dialysis organization agreement)
  • Comprehensive Primary Care Plus (CPC+)
  • Oncology Care Model (OCM) (two-sided risk track available in 2018)

Those are the details of who should be watching the APM program because they could be a participant. If you’re not participating in any of these programs, then you’ll not be taking part in the APM program. Next week we’ll dive into more details of other requirements to be what is considered an “Advanced APM”. Plus, we’ll dive into the benefits of participating as an advanced APM.

As I mentioned, we’ll be focusing most of our MACRA Monday series on the MIPS program, but it’s important that all practices spend time understanding the APM program even if you’re not going to be impacted by it in 2017. Why? CMS expects that while most practices will start their MACRA journey in the MIPS program, practices will transition to the APM program over time. How quickly that will happen and the process for switching programs will be interesting to watch. However, that’s why even MIPS participants should be keeping an eye on what’s happening with the APM program. It’s important to see the trends and shifts so your practice is ready.

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.

What’s the Impact of MACRA on Small Practices?

Posted on July 22, 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 recently had a chance to sit down and chat with Tom Giannulli, MD, Chief Medical Officer of Kareo and Michael Sherling, MD, MBA, Chief Medical Officer and Co-founder of Modernizing Medicine, to talk about the impact of the MACRA legislation on small practices. Both of these CMOs at EHR vendors rode the meaningful use wave and now they’re preparing to ride the new MACRA wave as well. So, they were the perfect people to talk about the impact of MACRA on small practices and how a small practice should prepare themselves for the new MACRA legislation. If you’re a small practice that’s wondering about MACRA (or doesn’t even know what it is), then take the time to watch the video below to see what it means for small practices.

After our formal interviews, we always like to hold what we call the “after party.” We never know how it’s going to go. Sometimes people join in and offer their insights and ask questions and sometimes they don’t. In this case, we continued our conversation about the MACRA and small practices, but we also talked about the impact that legislation like MACRA has on an EHR vendors development lifecycle. You can learn more about MACRA in the video below:

This post was a great way to wrap up the week and also for us to announce a new blog post series we’re starting on Monday called MACRA Monday. Long time readers may remember the Meaningful Use Monday series of blog posts we did every Monday for a few years. This will be similar as we dive into the MACRA legislation and help small medical practices understand the details of what’s coming in MACRA. Watch for that on Monday!

Bill Could Cut Meaningful Use Reporting Period Drastically

Posted on April 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.

A bill has been filed in Congress that would slash the Meaningful Use reporting period from one year to 90 days. This seems to be a challenge to CMS, which has reportedly held firm in the face of pressure to cut the reporting period on its own.

Supporters of the bill, which is backed by a broad coalition of industry trade groups, argue that a 365-day reporting period is unduly burdensome for providers, and will become even more awkward as MACRA requirements fall into place. Cutting the reporting period “will continue the significant progress providers are making to harness the use of technology to succeed in new payment and care delivery models,” argued a coalition of such groups in a letter sent to CMS last month.

That being said, it’s not clear how the structure of Meaningful Use incentives will play out under MACRA. So the reporting period change may or may not be as relevant as it might have been before the MACRA rules were set to be announced.

CMS leaders have said that the upcoming Merit-Based Incentive Payment System (MIPS) – which will probably fall in place under MACRA in 2017 — is designed to unify incentive payments. Specifically, it integrates existing MU, PQRS and Value-Based Payment Modifier programs. MIPS payments will be based on a weighted score rating providers on four factors: quality (30%), resource use (30%), Meaningful Use (25%) and clinical practice improvement activities (15%). This suggests that a focus on reporting requirements is probably a matter of closing the barn door after the horse has left the stable.

On the other hand, since Meaningful Use isn’t going away completely, maybe cutting the reporting period required is necessary. If providers are being rated on a set of factors of which MU is just a part, reporting for an entire year could certainly impose an administrative burden. Why set providers up to fail by forcing them to overextend their resources on reporting?

I believe that reducing Meaningful Use requirements is a sensible step to take at this point. While there are probably those who would argue the point, I submit that MU has been pretty successful in motivating providers to rethink their relationship with HIT, and has even help a subset to completely rethink how they deliver care. Now, it’s time to move the ball forward, to a more holistic approach that goes beyond regulating care processes.

Admittedly, it’s possible that cutting the reporting period, or otherwise shifting the emphasis away from regulating HIT use, might cause some providers to slack off in some way. But to my way of thinking, that’s a risk we need to take. After investing many billions of dollars on promoting smart HIT use, we have to assume that we’ve done what we can, and focus on smart quality measures. With any luck, the new measures will work better for everyone involved.