- The American Medical Informatics Association (AMIA) has voiced its support of MACRA implementation contingent on the Centers for Medicare & Medicaid Services (CMS) committing to learning from previous quality reporting programs and reducing the 2017 reporting period for eligible clinicians.
In a comment letter to CMS Acting Administrator Andy Slavitt, AMIA has called MACRA implementation an “unprecedented opportunity” for the federal agency to learn from legacy programs — the EHR Incentive Programs, Physician Quality Reporting System, and Value-Based Modifier.
“AMIA believes CMS has an unprecedented opportunity to learn which components of these legacy programs will effectively support our healthcare system in moving toward the triple aim, and we strongly recommend that CMS engage medical informatics expertise more broadly to understand how technology should be leveraged to improve care experience, efficacy, and reduce unnecessary expense,” wrote AMIA President & CEO Doug Fridsma, MD, PhD, and Board Chair Thomas Payne, MD.
Additionally, CMS should take an iterative approach to MACRA rulemaking to makes its provisions for the Quality Payment Program to ensure the successful implementation of the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs).
According to AMIA, the experience of providers in meaningful use warrants a reconsideration of the upcoming 2017 reporting period, a full year’s worth of reporting for eligible clinicians.
“Despite our support for much of this NPRM, the level of complexity inherent in these programs has no equal in Medicare, and we suspect it rivals any federal program in aggregate complexity. This complexity will necessitate tremendous amounts of education and dialogue, despite most EC’s familiarity with certain aspects of MIPS,” claimed Fridsma and Payne.
“AMIA recommends CMS issue an interim final rule with a comment period to further refine proposed policies based on stakeholder feedback,” they continued, “and we recommend CMS consider a 90- or 180-day reporting period in 2017. Experience with MU has indicated that 90-day reporting periods has benefited clinicians without compromising their commitment to using IT to improve care.”
Beyond these significant recommendations, the AMIA includes a host of accompanying recommendations for MACRA implementation:
• Use data reporting requirements to learn, not simply to grade.
• Focus on defining clear, expected outcomes, rather than prescriptive process measures.
• Engage organizations and experts to perform scientifically rigorous, peer-review studies to determine which requirements should be retained in future years.
• Leverage current programs, standards and requirements to enable clinicians to optimize the tools they have to improve care.
• Pay special attention to small practices, which limited resources, so they are empowered to succeed.
• Develop feedback loops that are accurate, timely and meaningful
• Encourage increased data exchange and interoperability whenever possible.
• Consider the capacity of the average MIPS eligible clinician (EC) or APM participant to absorb high levels of complexity and change.
AMIA remains critical of MACRA proposals for preventing information blocking through provider attestation and surveillance by the Office of the National Coordinator for Health Information Technology.
Under the proposed rule for the Quality Payment Program, CMS would require providers to attest that they have complied with the surveillance of certified EHR technology, particularly for eligible clinicians under the advancing care information performance category under MIPS:
We understand this attestation is meant to strengthen surveillance and other oversight of certified health IT, including through expanded in-the-field surveillance and ONC direct review of technology and capabilities. However, we have general concerns with the burden on providers and associated uncertainty that could be imposed by the surveillance attestation. We also question whether such an attestation is necessary, given that in-the-field surveillance is a new activity, and ONC direct review is not yet a legal authority of the Office.
The comment period for the MACRA implementation proposed rule ends this evening, after which time the focus turns to CMS and its response.