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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.”

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.

Will New Doctors Hate EMRs the Way Older Doctors Do?

Posted on March 22, 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.

Oh! Just the idiocy of it all!

That’s a quote from an email I got from an older doctor in response to a discussion about EHR software and in particular programs like meaningful use and now MACRA. This is a doctor who I’ve exchanged many emails with over multiple years. Needless to say, he’s not happy with what’s happening with EHR software and sees it as an awful thing for medicine. I think this is the view of most older doctors.

While most older doctors feel this way, I wonder if the next generations of doctors will feel the same. I’ll never forget my med school friend who said he hated rounding at a doctor’s office that didn’t have an EHR because he types faster than he writes. Or the middle-aged doctor that’s been a friend of my family since I was a kid that’s been on EHR so long that he once told me “I’ve never really known anything but an EHR, so I can’t imagine practicing medicine without it.”

I understand the doctors who complain about EHRs and more importantly complain about the regulations which are reflected in the features EHR software companies push out. EHR was a massive change for many of them and that can be brutal. Plus, there are plenty of issues with many EHR software and EHR implementations out there. Some that can be resolved and some that can’t. Not to mention that many regulation requirements aren’t clinically useful. We should be glad doctors are upset over this.

However, will the next generation of doctors care?

Besides the fact that new doctors are digital natives who grew up with technology, there’s also the fact that new doctors won’t know what life in a medical office was like before EHR. EHR documentation will just be part of the status quo for them and when you don’t know about the alternative, then you don’t hate it as much. It’s just a required part of the profession and it’s always been that way.

The reality for most new doctors is that there are so many things that are screwed up with our healthcare system, that the EHR is just one more to add to the pile of things that don’t make much sense. They’ll just consider it a feature of the profession and likely not complain much.

The one thing that could change all of this is for a new EHR or related solution to come out and blow all the current EHR vendors off the map. It would have to be something so dramatically better for organizations that healthcare organizations can’t resist it. Think of the way the iPhone made us rethink cell phones. It needs to be a solution which is that much better. Does such a solution exist? Can such a solution be built? Or do the current healthcare regulations prevent such a solution? Will it take changes in regulation and reimbursement to enable a new EHR that doctors love and not a change by an EHR software vendor?

New Eligibility Exclusions in the MACRA Final Rule – MACRA Monday

Posted on October 17, 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 on Friday, we posted the various resources available for the MACRA Final Rule. As you can imagine, one weekend isn’t nearly enough time to process what’s in the final rule. It’s going to take weeks to really get through it all. In fact, we might take a few weeks off from MACRA Monday to process it all.

That said, we wanted to do a quick post this MACRA Monday to talk about the new eligibility requirements and thresholds in the MACRA final rule. For reference, here’s our previous post that looked at MIPS eligibility in the MACRA proposed rule.

In the final rule, it looks like there are still 3 categories of exceptions: new doctors, low medicare volume and participation in an advanced APM. The big change in the MACRA final rule is what is considered low medicare volume. In the proposed rule it said, “$10,000 and providers care to 100 or fewer Medicare patients in a year.” Note the “and” in that requirement. In the MACRA final rule it excludes doctors with less than or equal to $30,000 in Medicare Part B allowed charges or less than or equal to 100 Medicare patients.” Note the “or” and the move from $10k in Medicare volume to $30k in Medicare volume.

With these three exceptions, Andy Slavitt sent the following tweet:

I quickly commented, “Now you’re going to get the small practices complaining that they were excluded from the incentives. #MACRA #CantWin” CMS’s MACRA executive summary says that they considered allowing those that were below these levels to opt into MIPS if they desired, but they “determined that it was inconsistent with the statutory MIPS exclusion based on the low-volume threshold.” I think the complaining for not being allowed to participate will be pretty minimal. 4% of such a small volume of Medicare won’t be that impactful for most.

There’s the start of our analysis of the MACRA final rule. A good first step to knowing if you qualify to participate in MACRA. Let us know if there are changes in the final rule that you’ve noted or that are bothering you. We’d love to hear them in the comments.

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

MACRA Final Rule Is Out – MACRA Monday (on Friday)

Posted on October 14, 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.

We usually wait until Monday to do our weekly MACRA Monday blog posts. However, today the MACRA final rule dropped and so we thought we’d do MACRA Monday on a Friday. Since the rule just came out this morning, we haven’t had a chance to do much analysis. No doubt we’ll do a lot more analysis, summarizing, etc in the future. For this post, I just wanted to share with you the various places you can go to find the final rule and summaries of the final rule that will be helpful.

The first resource you need is the MACRA final rule itself. Yes, it’s 2398 pages, but remember that CMS is required to respond to the feedback that was given in the proposed MACRA rule. The rule itself is much shorter, but the explanation of the rule is quite long. As Andy Slavitt noted, it’s long in the interest of transparency.

The reality is that most of you will only want to check out the MACRA Final Rule Executive Summary. It’s only 24 pages and should give most people what they need to know about the MACRA final rule. You can leave the 2398 page final rule to the health IT policy wonks.

Along with the executive summary, CMS has put out a new website with resources, education, and tools for the Quality Payment Program (Or as we call it, MACRA). The Education and Tools page has some great resources for those wanting to learn more about MACRA.

If you plan to participate in MIPS, then you’re likely going to use the Explore Measures page. Considering MACRA’s increase in the number of measures, this page will help you navigate through the various measures and decide which measures you’re going to do as part of MACRA.

If you want a higher level look at what CMS did to put together the MACRA final rule, take a second to read through Andy Slavitt’s letter to Clinicians. We might disagree with the details of MACRA, but after reading letters like this it’s hard to argue that Andy Slavitt and his team aren’t listening to providers and healthcare’s feedback on these rules.

That’s all for today. Happy reading this weekend! Over the next months and years we’ll be diving into the details of the program. If you’re reviewing the final rule like us, share any insights or findings you find interesting in the comments. It takes a large community to understand new rules like this.

AMA Introduces MACRA Tools – MACRA Monday

Posted on October 10, 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.

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

The American Medical Association has released a package of online tools designed to help physicians cope with major changes to Medicare rolling out next year under MACRA. While it’s likely that practices will still have plenty of challenges to address on their own, these tools seem like they may offer a leg up on the subject, particularly for smaller practices with less resources to throw at MACRA issues.

One of the tools being introduced is the AMA Payment Model Evaluator (Sadly an account is required, but there’s an option to create a new account), designed to help doctors determine how their practices will be impacted by MACRA. The Evaluator, which was developed in partnership with physicians and AMA partners, asks physicians and medical practice administrators to fill out an online questionnaire on their practice. The Evaluator then offers an assessment of their specific situation, along with educational material and other resources. This includes recommendations on which MACRA payment model is best for them, which can help your practice know the best direction for your specific needs.

The AMA has also added new MACRA-specific tools to its AMA Steps Forward collection of practice improvement strategies. The STEPS modules help physicians determine how to report on quality metrics central to MACRA as well as the Physician Quality Reporting System. The STEPS modules each focus on a specific issue and offer solutions, steps for implementation, case studies, CME opportunities and downloadable additional tools.

In addition, the physician group has launched a podcast series, Inside Medicare’s New Payment System, featuring acting CMS administrator Andy Slavitt, AMA staff experts and other healthcare leaders. The series, which will include five episodes, should help get physicians up to speed on MACRA-related changes. I for one am eager to hear what Slavitt has to say about MACRA, as he is about the best source on the subject you could have.

At first glance, it doesn’t seem that the AMA plans to spend a lot of time on the Advancing Care Information subset of MIPS, better known as the replacement for the Meaningful Use program. I guess that’s not a huge surprise, given that physicians are still grappling with broad implications of MACRA which go well beyond HIT issues. However, given how important Meaningful Use has been to physicians over the past few years, one might expect it to get a little bit of special attention. Maybe they’re waiting for the MACRA final rule to come out.

With CMS casting a wider net and looking for more from medical practices than just adequate levels of EMR adoption, the AMA is probably following CMS’ path in talking about more than just the meaningful use (Advancing Care Information) portion of MACRA.

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

Overview of the Advancing Care Information Category in MIPS – MACRA Monday

Posted on October 3, 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.

In our last edition of MACRA Monday we covered 3 of the 4 categories that are part of MIPS: Quality Performance, Resource Use (Cost), and the new Clinical Practice Improvement Activities Category. This week we’ll be covering the details of the 4th category known as Advancing Care Information.

The Advancing Care Information category is probably one you’ve heard about since it’s the replacement for the well known meaningful use program. One change that will be available in the Advancing Care Information category that wasn’t available in meaningful use is that you may participate as an individual or as a group. It’s also worth noting that the Advancing Care Information category makes up 25% of the total MIPS composite score.

One thing that can be a little confusing about MIPS is that the Advancing Care Information category has a score within a score. Advancing Care Information makes up 25% of the MACRA score, but in order to calculate how much of the 25% you’ll receive you have to figure out how many points you receive in the Advancing Care Information category. This chart illustrates how the points will be calculated:
advancing-care-information-scoring-for-macra
As you can see from this chart, your base score, performance score, and any bonus points will be used to calculate whether you receive the full 25% for your MIPS composite score or not.

The base score requires that you report your participation in the following items:

  • Protecting PHI
  • ePrescribing
  • Patient Access
  • Patient Engagement
  • HIE
  • Public Health and Clinical Data Registry Reporting

The good thing about the base score is that you’ll receive full credit for each item if you submit the reports for each item. There’s no threshhold required.

The performance score focuses on the following areas:

  • Patient Electronic Access
  • Coordination of Care through Patient Engagement
  • HIE

Unlike the base score, the performance score will need to achieve certain performance in order to receive points. You’ll also notice that these three areas indicate CMS’ efforts to focus on patient access and health data exchange.

A few other high level things to note for the Advancing Care Information category. First, they’ve removed the “All or Nothing” approach that existed in the EHR (Meaningful Use) program. Second, they’ve removed redundant measures to try and streamline the program. Third, they’ve eliminated CPOE and CDS objectives. Finally, they’ve reduced the number of required public health registries.

As you can see from the list above, this will not be that different than meaningful use. So, if you’ve been participating in meaningful use, then advancing care information won’t be a huge obstacle. If you haven’t been participating in meaningful use, well then you have some work to do.

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

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.