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AMIA Critiques CMS Proposal for Value-Based Programs

AMIA gives critique on value-based quality measures, health IT integration into value-based payments, and integration timelines in their public comments.

By Sara Heath

The American Medical Informatics Association (AMIA) recently submitted comments to the Centers for Medicare & Medicaid Services (CMS) in reference to the Merit-based Incentive Payment System (MIPS), Alternative Payment Models (APMs), and incentive payments for the Eligible Alternative Payment Models (EAPMs).

value-based payment

These comments come by way of a letter written by AMIA President and CEO Douglas B. Fridsma, MD, PhD, FACP, and AMIA’s Board Chairman Blackford Middleton, MD, MPH, MSc.

Overall, AMIA’s comments span three key areas, including quality measurements for value-based payments, the use of health IT in value-based environments, and the timelines for program implementations.

Value-based payment quality measurements

While AMIA supports the transition from volume- to value-based payment programs, AMIA argues that frequent quality measuring is not the best way to foster outcomes-based care. Instead, quality measures requirements cause physicians to check off certain measures boxes rather than deliver the highest quality of care for the lowest cost.

AMIA suggests policymakers do away with many of the prescriptive quality measures, as to not over-emphasize outcomes measures and instead focus on the patient experience.

“AMIA recommends that federal officials do not reflexively expand the current approach to quality measurement in developing these new policies,” the organization writes. "Rather, CMS should seek opportunities should to retire existing process-based measures while looking for ways to develop more outcomes-based measures.”

Integration of health IT into value-based programs

The use and integration of health IT into value-based programs present two challenges that require solutions.

First, AMIA identifies the need for improved health IT infrastructures for measuring population health requirements. To do this, AMIA recommends doing away with population health measurement certification and guidelines, which will allow for more innovation and better understanding of population health functionalities on EHRs.

Second, meaningful use and EHR certification policies inhibit user-facing innovation.

“We are concerned that a focus on conformance to certification criteria has inadvertently led to a ‘develop-to-the-test’ approach, and has affected the functionality and usability of EHRs in ways not sought or prioritized by clinicians,” AMIA writes.

According to the organization, “federal officials avoid overly prescriptive requirements to determine how providers use informatics tools, but rather focus on the outcomes sought by the use of such tools.”

Implementation timelines

Last, AMIA suggests policymakers remain cognizant of the effort that goes into preparing for a shift from volume to value-based payments. In doing so, CMS should implement these payment reforms in intervals rather than all at once.

Additionally, AMIA requests CMS to develop an implementation roadmap.

“This roadmap should clearly articulate the CMS quality strategy, beginning with a focus on accurate, complete and valid eCQMs. If CMS continues its plan to require electronic submission of CQMs, and payment depends on those quality measures beginning in 2017, all stakeholders must be confident that those eCQMs represent an accurate picture of care delivered,” the organization adds.

Recently, CMS tied the 60-day comment for Stage 3 Meaningful to the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) of which these value-based programs such as MIPS and APMs are a part. In clarifying the types of comments the federal agency is seeking, CMS noted that implications of MACRA for meaningful use requirements was an area of particular interest.

Around the same time, Beth Israel Deaconess Medical Center CIO John Halamka, MD, MS, cited MACRA as a suitable replacement for the EHR Incentive Programs and a means of building off the foundation of EHR adoption that meaningful use helped create.

The comment period for MACRA closes today, November 17, at midnight.

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