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How Will CMS Handle Issues Surrounding MACRA Changes?

Posted on May 14, 2018 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.

As most readers will know, when CMS released details on MIPS and the Alternative Payment Model incentives it embarked on a new direction for quality programs generally. As most readers will know, MIPS consolidated PQRS, the Physician Value-based Modifier and the Medicare EHR Incentive Program for EPs (Meaningful Use). But CMS is still updating the Medicaid incentive program.

If I were a physician, I’d be even more interested in the CMS initiative dubbed Promoting Interoperability. In some of the biggest news to come out of the agency in ages, CMS is restructuring the EHR Incentive Programs to become the Promoting Interoperability Programs. Promoting Interoperability replaces the Advancing Care Information category of MIPS.

Whoa. That would be a big enough deal on its own, but the issues the rule raises are an even bigger one.

CMS’s has been working towards this goal for a few years. Per HIMSS, here are some changes suggested in the proposed rule that might have the biggest impact on the health IT world:

  • The rule would cut down measures from 16 to six
  • It would use a new performance-based scoring methodology which would include measures of performance on e-prescribing, health information exchange, provider to patient exchange and public health and clinical data exchange
  • The agency will define and work to prevent “information blocking”

On a related note, CMS has posted a request for information asking for stakeholder feedback on program participation conditions. This is pretty unusual for the agency.

Like many CMS proposals, this one leaves some important questions open. (Apparently, CMS itself wonders how this thing will work, as the request for information suggests.)

For example, the new performance-based scoring method will award providers anywhere from 0 to 100 points. Measuring health IT performance is always a tricky thing to do, and there’s little doubt that if this becomes a final rule, both providers and CMS will have to go through some struggles before they perfect this approach. In the meantime, providers face some big challenges. How will they adapt to them? Its too soon to say.

Addressing so-called “information blocking” should be an even bigger challenge. Everyone from members of Congress to providers to vendors acts as though there’s one way to describe this practice, but there’s still a lot of wiggle room. Honestly, I’ll be amazed if CMS manages to pin it down the first time around.

Still, the time is more than overdue for CMS to take on interoperability directly. Without real data interoperability, many promising digital health schemes will collapse under their own weight. If CMS can figure out how to make it happen, it will be pretty neat.

Encouraged By Political Changes, Groups Question ONC Functions

Posted on March 21, 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.

Riding on an anti-regulation drive backed by the White House, groups unhappy with some actions by ONC are fighting to rein it in. President Trump has said that he would like to see two regulations killed for every new reg, and the groups seemingly see this as an opening.

One group challenging ONC activities is HealthIT Now, a coalition of providers, payers, employers and patient groups.

In a letter to HHS Secretary Tom Price, Health IT Now argues that ONC exceeded its authority last year, when it backed an oversight rule designed to boost the certification process by evaluating vendor interoperability capabilities.

The 2016 rule also holds health IT vendors accountable for technology flaws that could compromise patient safety, an approach which, HITN argues, steals a move from federal agencies such as the FDA. The group also contends that ONC has not been clear about its criteria for critiquing HIT solutions for safety problems.

Meanwhile, a group of medical societies and specialties is asking federal health officials to hold off on 2015 EHR certification requirements, which providers are expected to start using January 2018, for at least one year. The group notes that since ONC released its final 2015 Edition requirements, few vendors – in fact, just 54 of 3,700 products currently certified – have fully upgraded their systems.

Given this situation, rushing to deploy the latest certification requirements could create big problems, including a major disruption to medical practices’ business, the coalition argues.

If they’re forced to choose from the small number of systems which have upgraded their platforms, “physicians may be driven to switch vendors and utilize a system that is not suitable for their specialty or patient population,” the group said in a letter to CMS acting administrator Patrick Conway, MD, and acting ONC national coordinator Jon White, MD.

In addition to addressing certification concerns, there’s much the federal government can do to support health IT improvement, according to attendees at HIMSS17.

According to HITN, attendees would like policymakers to address interoperability, in part by reviewing Meaningful Use and the ONC Voluntary Certification programs; to focus on improving patient identification systems, and avoid imposing barriers to private market solutions; to clarify the role of the ONC in the marketplace; and to encourage the use of real-world evidence in healthcare and health IT deployment.

As I see it, these ideas veer between close-in detail and broad policy prescriptions, neither of which seem likely to have a big effect on their own.

On the one hand, while it might help to clarify ONC’s role, authority and process, the truth is that the health IT market isn’t living or dying on what it does. This is particularly the case given its revolving door leaders with too little time to do more than nudge the industry.

Meanwhile, it seems equally unlikely that the federal government will come up with generally-applicable policy prescriptions which can solve nasty problems like achieving health data interoperability and sorting out patient matching issues.

I’m not saying that government has no role in supporting the emergence of health IT solutions. In fact, I’m fairly confident that we won’t get anywhere without its assistance. However, until we have a more effective role for its involvement, government efforts aren’t likely to bear much fruit.

Additional FAQs for Guidance on Meeting Public Health Objective for 2015 EHR Reporting Period

Posted on November 17, 2015 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.

On October 6, CMS released the final rule for the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. To support provider participation in 2015, CMS has released two additional FAQs in response to inquiries about the public health reporting objective in 2015.

FAQ 13409
Question: For 2015, how should a provider report on the public health reporting objective if they had planned to be in Stage 1 meaningful use which required sending a test message and continued submission if successful, but did not require registration of intent?

Answer: We did not intend to require providers to engage in new activities during 2015, which may not be feasible after the publication of the final rule in order to successfully demonstrate meaningful use in 2015. Since providers in Stage 1 in 2015 were not previously required to submit a registration of intent to submit data to meet Objective 10 measures, providers may meet the measures by having sent a test message or by being in production. Providers who have sent a test message can be considered to have met Option 2 of Active Engagement – Test and Validation; providers who are in production can be considered to have met Option 3 of Active Engagement – Production.

FAQ 13413
Question: Does integration of the PDMP (Prescription Drug Monitoring Program) into an EHR count as a specialized registry?

Answer: If the PDMP within a jurisdiction has declared itself a specialized registry ready to accept data, then the integration with a PDMP can count towards a specialized registry. The EHR must be CEHRT, but there are no standards for the exchange of data.