- MGMA and AMIA hold differing opinions over CMS policies included in Year 3 of the Quality Payment Program (QPP) that require eligible clinicians to use 2015 edition certified EHR technology (CEHRT) to fulfill reporting requirements for the Merit-Based Incentive Payment System (MIPS) in 2019.
The associations recently submitted comment letters in response to the CMS proposed rule for Year 3 of QPP.
In its letter, MGMA stated its disapproval for CMS proposed policies mandating use of 2015 edition CEHRT by 2019.
“MGMA member practices are concerned with the unrealistic timeframe and the difficult-to-meet requirements proposed for the 2019 reporting year of the Promoting Interoperability component of MIPS, as well as with the potential related requirements under other areas of the QPP,” stated MGMA.
MGMA recommended CMS allow MIPS and alternative payment model (APM) participants to use either 2014 or 2015 CEHRT in 2019 and 2020.
“Moving from 2014 Edition CEHRT to 2015 Edition CEHRT will be an onerous, costly, and challenging process for those physician practices who have not yet upgraded,” maintained the association.
Meanwhile, AMIA expressed support for policies requiring use of 2015 edition CEHRT beginning in 2019.
“We view this as foundational for improved interoperability, patient data access, and better usability. Thus, we strongly support the agency’s proposal to extend this requirement to eligible clinicians (ECs) in this NPRM.”
AMIA also stated its support for CMS efforts to align the Promoting Interoperability MIPS performance category with Promoting Interoperability program requirements recently finalized for hospitals in the 2019 IPPS proposed rule.
The Promoting Interoperability performance category — formerly called advancing care information (ACI) — is one of four performance categories part of MIPS under QPP.
While AMIA supports the Promoting Interoperability performance category, the association took issue with QPP scoring.
“While QPP recognizes quality and cost, the QPP composite score does not most reward those ECs who deliver the highest value to beneficiaries,” wrote AMIA. “Rather, the composite score incentivizes ECs to reduce cost to receive higher composite scores without regard to the impact on quality.”
AMIA recommended CMS change MIPS scoring methodology to ensure eligible clinicians who deliver the highest quality care for the lowest cost receive the highest composite scores.
Meanwhile, MGMA recommended CMS simplify MIPS reporting by allowing eligible clinicians who submit quality measures using end-to-end electronic reporting or CEHRT in the Improvement Activities category to also earn full credit for their Promoting Interoperability score.
“ECs use CEHRT and other tools that leverage interoperable standards for data capture, usage, and exchange to facilitate and enhance patient and family engagement, care coordination among diverse care team members, and to leverage advanced quality measurement and safety initiatives,” wrote MGMA.
“CMS should recognize that if an EC or group is leveraging CEHRT to report quality measures or Improvement Activities, they are also demonstrating the use of technology to capture, document, and communicate patient care information and should therefore receive both quality and Promoting Interoperability credit,” MGMA continued.
To streamline reporting requirements, MGMA suggested CMS award credit across MIPS performance categories rewarding high-impact behavior.
“MGMA recommends the agency reconfigure the MIPS scoring methodology and award Promoting Interoperability credit for reporting quality measures via end-to-end electronic reporting,” the association wrote.
MGMA also pressed CMS to decrease MIPS reporting requirements, permanently shorten MIPS reporting periods to any 90 consecutive days, and provide clear feedback about MIPS performance at least every calendar quarter.
The public comment period for stakeholders to submit feedback for the proposed rule closed September 10.