In last week’s Acumen blog Diana tackled highlights of the MACRA Final Rule released on October 14. She noted that the 2,398-page document is overwhelming and we are going to need to “eat the elephant one bite at a time.” Well, I’d prefer not to literally eat the elephant since I love elephants and tend toward vegetarianism, but MACRA is mammoth enough that we will need to use multiple blog posts to break it down into some small, usable parts. So, as promised by Diana Strubler, MACRA is still on the menu.
MIPS exclusions
One point to review today regards exclusions. The Final Rule changes the threshold for participation to include providers with greater than $30,000 of Medicare Part B charges or with greater than 100 Medicare patient encounters. CMS expects one-half of clinicians will be exempt from MIPS participation in 2017 due to low volume of Medicare business. An additional 70,000 to 120,000 clinicians will be excluded from MIPS due to participation in advanced Alternative Payment Models (APMs). If you don’t meet the exclusion criteria and just choose to ignore MIPS in performance year 2017, then you will face a 4% Medicare Part B payment penalty in 2019.
Exclusion is good news and bad news. It lets you off the hook for a year, but you miss an opportunity to prepare for the future. Performance year 2017 has flexibility and low thresholds, so even if you qualify for exemption from MIPS it may be worth your while to use this year to get ready for participation. This MIPS transition year offers 90-day reporting and reasonable requirements, including reporting only 5 Advancing Care Information measures and no cost reporting in the MIPS composite score.
Advancing Care Information
The October 17 blog post highlights the Quality Payment Program (QPP) performance category of Advancing Care Information (ACI). ACI is the new incarnation of the old EHR incentive program or Meaningful Use (MU). This performance category is central to supporting and incenting the digital transformation of healthcare. Last Friday as the MACRA Final Rule was released the National Coordinator for Health IT, Dr. Vindell Washington, spoke publicly about the intentional use of MIPS to support health IT interoperability. Dr. Washington remarked that the entire QPP is designed to move healthcare toward seamless and secure information flow. As an improvement over MU, MIPS provides choices and flexibility for providers to report using health IT (HIT) in daily patient care. In addition ACI measures support patient access to their own data with the ability to view, download, and transmit.
Through the QPP and ACI, the Office of the National Coordinator for Health IT (ONCHIT) plans to promote 3 key drivers for HIT transformation:
- Healthcare reimbursement (i.e. Medicare payment) will reward HIT information flow
- Healthcare technology must be interoperable within the care ecosystem
- Data blocking by vendors and health systems will not be allowed; providers and patients must have easy access to data
Measures in the ACI performance category support the ONCHIT agenda. The 15 ACI measures available for reporting in 2017 include:
- 5 public-health or registry reporting measures
- Clinical Data Registry Reporting
- Electronic Case Reporting
- Immunization Registry Reporting
- Public Health Registry Reporting
- Syndromic Surveillance Reporting
- 5 patient-care coordination EHR measures
- Clinical Information Reconciliation
- E-Prescribing
- Patient-Specific Education
- Send a Summary of Care Record
- Summary of Care Measure
- 4 electronic patient interaction measures
- Patient-Generated Health Data
- Provide Patient Access
- Secure Messaging
- View Download Transmit
- EHR security risk assessment measure
- Security Risk Analysis
Data access for patients
Measures focused on patients and patient representatives ensure not only patient access to data, but the ability to interact with a personal health record and to control data-sharing. Patient-Generated Health Data includes the opportunity for at least 1 patient to enter data into the certified EHR during the performance period. Patient access to data includes not only the ability to view, download, and transmit personal health data, but to be able to use additional healthcare applications to access data through an Application Programming Interface (API), a capability that is part of 2015 EHR certification. The Secure Messaging Measure requires only 1 secure message to or in response to a patient. The View Download Transmit measure requires at least 1 patient to not only access their health data online, but to view, download, and transmit the data to a 3rd party and/or move data to/from an application by use of an API.
Patient access to personal health data with the ability to share it is key to a healthcare future that supports patient engagement. All of the ACI measures support health IT interoperability, a must-have in the future of excellent healthcare quality and safety. As Dr. Washington notes, Health IT is “foundational” to quality clinical care.
MIPS and small practices
This is just the start of MACRA and MIPS. CMS expects the number of clinicians in advanced APMs to increase to 250,000 by performance year 2018. Meanwhile CMS hopes to support solo and small practices in IT adoption and QPP reporting. Based on the changes in the Final Rule that decrease the reporting burden, CMS expects 80% of small-practice providers will receive neutral or positive payment adjustments for 2017 performance. With a budget of $20 million per year for 5 years, CMS is offering MIPS training and education to small practices of less than 15 providers. This support is provided through local organizations that can assist with measure selection, solving IT issues, and supporting clinical quality improvement activities. MACRA legislation requires CMS to develop structure and criteria enabling solo and small groups to band together into virtual large groups to offload the reporting burden and performance impact. Virtual groups should be possible by performance year 2018.
Are you feeling relaxed, seamless, and flowing about MIPS? You’re likely to hear more MACRA tidbits in the next few weeks and we hope that will help. Do you have MIPS or advanced APM questions? Send us your comments!
Dugan Maddux, MD, FACP, is the Vice President for CKD Initiatives for FMC-NA. Before her foray into the business side of medicine, Dr. Maddux spent 18 years practicing nephrology in Danville, Virginia. During this time, she and her husband, Dr. Frank Maddux, developed a nephrology-focused Electronic Health Record. She and Frank also developed Voice Expeditions, which features the Nephrology Oral History project, a collection of interviews of the early dialysis pioneers.
Top image from www.canstockphoto.com
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