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The MACRA (QPP) API – MACRA Monday

Posted on August 7, 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.

When the MACRA program was announced, CMS also announced a new API for MACRA as well. In that announcement, CMS really just mentioned that the MACRA API would give developers access to the complete list of Advancing Care Information (ACI), Improvement Activities (IA), and quality measures for QPP 2017 (now called the QPP Measures Data Repository). While it was nice of them to offer this API, it really didn’t seem that useful.

Since then, CMS has launched what they call the QPP Submissions APIs which allow developers to submit MACRA data to CMS. This is much more useful and something that I believe will be adopted by many EHR vendors, data registries, etc.

Here’s a quick look at what these MACRA APIs can do:

  • Submissions API
    • Submit data as a single file or a set of smaller files throughout the reporting period, using QRDA-III or a new, streamlined QPP data format
    • Submit, update or delete ACI, IA and quality measures data during the reporting period
    • Receive feedback on the content and accuracy of a submission
    • Receive the preliminary score for a submission, based on the finalized policy
  • CMS Web Interface API
    • If you are registered for the CMS Web Interface, download your group’s beneficiary sample, modify it and submit it to the CMS Web Interface
    • Receive feedback on the content and accuracy of a submission
    • Receive a real-time composite score for a submission

For those that prefer a picture explanation of how the API works, you’ll enjoy this diagram of the current process and how the API works:

It’s great to see CMS really embracing APIs as part of MACRA. Now if we could just get the rest of healthcare and EHR vendors to implement high quality APIs.

OIG Video on EHR Oversight and eCW Settlement

Posted on August 4, 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 video is a little dry, but about what you’d expect from an organization like OIG. However, it’s interesting that OIG found the $155 million settlement with eCW to be worthy of a video promoting the fact that OIG would pursue legal action against EHR vendors who don’t certify their EHR appropriately.

Check out the OIG video embedded below:

What do you think of this video? Is this needed? Is OIG sending a warning shot for other EHR vendors? Is this a type of healthcare fraud that we’re going to see a lot more of in the industry?

No doubt the eCW settlement has sent some shockwaves through the EHR industry and made a lot of EHR vendors wake up to the fact that they better not cut corners. The sad part is that I don’t think this increased effort to comply with EHR certification is really going to trickle down into benefits for doctors and patients. I do wonder if many lawyers watching this video will see this as an opportunity.

What do you think the impact has been and will be from the eCW settlement and this video?

MACRA Twitter Roundup – MACRA Monday

Posted on July 31, 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 and related topics.

There’s always a lot of activity on Twitter that’s relevant and interesting and this is particularly true for MACRA. So, I thought it would be fun for this MACRA Monday to do a roundup of some of the recent tweets providing resources, information and perspective on MACRA.


This is an important list to know about if you’re participating in MACRA. Make sure you’re using an approved registry (QCDR for those following along at home). I wish it wasn’t a pdf, but it is CMS.


This is a great side by side comparison for those preparing for what’s coming in MACRA 2018. I also found it interesting to see that it outlines MACRA’s main goals as:

  • Improve Health Outcomes
  • Spend Wisely
  • Minimize Burden of Participation
  • Be Fair and Transparent

I think if those are the goals, they might have the wrong program.


This is many doctors views of MACRA. Although, Kris Held, MD is very vocal about it. Her Twitter profile even says she has a mission to get government out of medicine. I don’t think enough doctors are going to follow her lead and opt out, but we’ll see very soon.


This tweet just made me laugh. I guess there’s a Miss Macra. I’m not sure what the Miss Macra Festival is, but I find it hilarious when terms overlap like this. Not really the point of MACRA Monday, but I thought you might enjoy the laugh that I got from the odd overlap.

HHS Office of Inspector General Plans To Review $1.6 Billion In Incentive Payments – MACRA Monday

Posted on July 24, 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 and related topics.

The HHS Office of Inspector General has announced plans to review the appropriateness of a walloping $14.6 billion of incentive payments made to providers over a five-year period.  The upcoming report, which follows on a GAO study naming improperly issued incentive checks as the biggest threat to the Medicare EHR incentive program, addresses payments made between by CMS between January 2011 and December 2016.

The OIG’s current audit plans follow on research it previously conducted which estimated that the incentive program had wrongfully paid out $729 million incentive payments between just May 2011 and June 2014.

To conduct that review, the OIG sampled incentive payment records for 100 eligible providers, then used the level of erroneous payments found among them to extrapolate the total amount paid out wrongly by CMS during those three years.

This time around, the watchdog organization plans to audit all payments made during the entire past life of the incentive program, an exercise which could generate some even more dramatic numbers. If the prior research is any indication, the OIG could conclude that roughly 10 % to 12% of the entire $14.6 billion in incentive payments it issued shouldn’t have been made in the first place.

Of course, looked at one way this effort could be seen as closing the incentive door after the horses have left. Meaningful Use, by all accounts, is giving way to incentives under MACRA, which will apply distinctive criteria to its incentive payment formulas. Also, while I’m no numbers whiz, seems to me that you can’t really model the entire meaningful use program effectively using just 100 sample cases.

That being said, it does seem likely that the audit will find more situations in which physicians hadn’t submitted he right self-attestation data or couldn’t prove what they asserted, and if the federal auditor has any role to play, this research is probably a good idea

Sure, nobody wants to be audited, particularly when your healthcare organization has jumped through many hoops to comply with meaningful use rules. Even if you can afford to pay back your incentive money, why would you want to do so? And particularly if you’ve already played by the rules, you certainly wouldn’t want to prove it again. But since the audit is going to happen anyway, perhaps it’s best to get any possible pain it may generate out of the way.

To date, I haven’t read anything suggesting that CMS has immediate plans to claw back incentive payments from providers. My assumption, though, is that they will eventually do so. Governments need money to get their job done, and audits theoretically offer the added benefit of tightening up important initiatives like this one.

As someone who has worked exclusively in the civilian world, I have often made fun of the plodding pace at which federal and state government agencies operate. In this case, though, a slow, deliberate process — such as a gradually-widening payment review — is likely get the job done most effectively. Let’s establish carefully which incentive payments may have been issued inappropriately and clear the decks for MACRA.

GAO: HHS Should Tighten Up Its Patient Data Access Efforts

Posted on March 23, 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.

The Government Accountability Office has issued a new report arguing, essentially, that while its heart is in the right place, HHS isn’t doing enough to track the effectiveness of patient health data access efforts. The report names ONC as arguably the weakest link here, and calls on the HHS-based organization to track its outreach programs more efficiently.

As readers know, CMS has spent a vast sum of money (over $35 billion at this point) to support health IT adoption and health data access. And while these efforts have spilled over to some patients, it’s still an uphill battle getting the others to access their electronic health information, the GAO report says.

Moreover, even patients that are accessing data face some significant challenges, including the inability to aggregate their longitudinal health information from multiple sources into a single, accessible record, the agency notes. (In other words, patients crave interoperability and data integration too!)

Unfortunately, progress on this front continues to be slow. For example, after evaluating data from the 2015 Medicare EHR Program, GAO researchers found that few patients were taking a look at data made available by their participating provider. In fact, while 88 percent of the program’s hospitals gave patients access to data, only 15 percent of patients actually accessed the information which was available.  When professionals provided patients with data access, the number of patients accessing such data climbed to 30 percent, but that’s not as big a delta as it might seem, given that 87 percent of such providers offered patient data access.

Patient reluctance to dive in to their EHI may be in part due to the large number of differing portals offered by individual providers. With virtually every doctor and hospital offering their own portal version, all but the most sophisticated patients get overwhelemed. In addition to staying on top of the information stored in each portal, patients typically need to manage separate logins and passwords for each one, which can be awkward and time-consuming.

Also, the extent of data hospitals and providers offer varies widely, which may lead to patient confusion. The Medicare EHR Program requires that participants make certain information available – such as lab test results and current medications – but less than half of participating hospitals (46 percent) and just 54 percent of healthcare professionals routinely offered access to clinician notes.

The process for sharing out patient data is quite variable as well. For example, two hospitals interviewed by the GAO had a committee decide which data patients could access. Meanwhile, one EHR vendor who spoke with the agency said it makes almost all information available to patients routinely via its patient portal. Other providers take the middle road. In other words, patients have little chance to adopt a health data consumption routine.

Technical access problems and portal proliferation pose significant enough obstacles, but that’s not the worst part of the story. According to the GAO, the real problem here is that ONC – the point “man” on measuring the effectiveness of patient data access efforts – hasn’t been as clear as it could be.

The bottom line, for GAO, is that it’s time to figure out what enticements encourage patients to access their data and which don’t. Because the ONC hasn’t developed measures of effectiveness for such patient outreach efforts, parent agency HHS doesn’t have the information needed to tell whether outreach efforts are working, the watchdog agency said.

If ONC does improve its methods for measuring patient health data access, the benefits could extend beyond agency walls. After all, it wouldn’t hurt for doctors and hospitals to boost patient engagement, and getting patients hooked on their own data is step #1 in fostering engagement. So let’s hope the ONC cleans up its act!

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.

CMS Finalizes the New Medicare Quality Payment Program

Posted on 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.

Today, the Department of Health and Human Services (HHS) finalized its policy implementing the Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Model (APM) incentive payment provisions in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), collectively referred to as the Quality Payment Program. The new Quality Payment Program will gradually transform Medicare payments for more than 600,000 clinicians across the country, and is a major step in improving care across the entire health care system.

The final rule with comment period offers a fresh start for Medicare by centering payments around the care that is best for the patients, providing more options to clinicians for innovative care and payment approaches, and reducing administrative burden to give clinicians more time to spend with their patients, instead of on paperwork.

Accompanying today’s announcement is a new Quality Payment Program websitehttp://qpp.cms.gov, which will explain the new program and help clinicians easily identify the measures most meaningful to their practice or specialty.

To see the press release and obtain more information about today’s announcement, including a fact sheet, please visit: http://www.hhs.gov/about/news/2016/10/14/hhs-finalizes-streamlined-medicare-payment-system-rewards-clinicians-quality-patient-care.html

To learn more about the rule, visit: https://qualitypaymentprogram.cms.gov/education

New Payment Model Pushes HIT Vendors To Collaborate

Posted on April 20, 2016 I Written By

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies. Contact her at @ziegerhealth on Twitter or visit her site at Zieger Healthcare.

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

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

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

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

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

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

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

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

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

The Case For Dumping EMR Interoperability Goals

Posted on December 22, 2015 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.

The new year is upon us, and maybe we should consider some new approaches, or even throw out accepted wisdom. Why not consider some major pain points and reconsider how we’re handling them?

In that spirit, my question is this: Should we give up on the idea that EMR vendors will ever allow their data will be interoperable? While this conclusion isn’t exactly a no-brainer, many of us have certainly toyed with the idea. So let’s take ‘er out for a spin.

One major consideration is that EMR vendors have some very compelling reasons for keeping things as they are. Perhaps most notably, interoperability would mean that providers wouldn’t be trapped in deals with a single vendor, as they could just shift the data over to a new platform if the need arose. If I sold EMRs I’d fight tooth and nail to prevent my product from being dumped too easily.

As if that weren’t enough of a disincentive, EMR vendors would need to spend big bucks to achieve interoperability, with no direct reward in sight. Somehow, I doubt that they’re ever going to make such an investment to win some “nice guy” award from the industry.

And even if they could somehow achieve interoperability without breaking a sweat, we’ve got to contend with inertia. Making changes on that scale takes a great deal of effort, and EMR vendors have very little reason to do so.

Maybe the federal government could achieve interoperability through some kind of epic power play, like refusing to issue Medicare reimbursement to providers whose EMRs didn’t meet some ONC interoperability standard.

But even that kind of brute force wouldn’t solve the interoperability problem with one stroke. Such an approach would come with a raft of serious concerns. What interoperability standard would ONC use, and how long would it take to choose? Then, how long would vendors have to meet the standard?  How long would providers have to decommission their existing EMR — and let’s not forget, quite possibly interlocking HIT systems — and where would they get the money for the new/upgraded systems?

Not only that, it would it cost billions of dollars, without a doubt, to make this transition. It could take a decade before the transition was complete. A lot can happen to derail such an initiative over that amount of time, and market forces could render the premises of such an effort obsolete.

On top of that, any effort which encouraged providers to dump their existing EMR platform would greatly diminish, if not erase, the value of the billions of dollars invested in Meaningful Use incentives. A lot of effort has gone into workflow and interface designs that support MU compliance, and starting from scratch on a new platform would NOT be a walk in the park.  So meeting MU goals might be possible over time, but could fall by the wayside for the short term.

All told, it seems that we may be chasing our tails trying to push through interoperability. In theory it sounds good, but when you look at the details it seems unlikely to happen. That being said, the need to share patient data isn’t going to go away, so what alternatives might work? I’ll follow up with some additional thoughts.

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.