- The College of Healthcare Information Management Executives (CHIME) has issued public comments calling for better alignment of meaningful use measures in the EHR Incentive Programs and the Quality Payment Program as part of MACRA implementation.
In the comments, CHIME leadership recommends that all “meaningful use-like” measures should be aligned to reduce reporting burden and other issues for eligible clinicians.
“CHIME members have expressed concerns that managing the complexity associated with having to meet three sets of Meaningful Use requirements – one for MIPS, another for Medicare hospitals, and yet another for Medicaid providers – will become untenable,” states the comment letter to the Centers for Medicare & Medicaid Services.
This refers to all measures under Medicare meaningful use, Medicaid meaningful use, and the similar measures included under the Advancing Care Information category of the Merit-based Incentive Payment System (MIPS).
The Branzell and Probst suggested CMS align the three programs by doing the following:
1) Establishing a 90-day reporting period for all reporting requirements in perpetuity;
2) Postponing any Stage 3-like measures and use of EHRs certified to Version 2015 until no earlier than 2019;
3) Removing pass / fail policies – particularly as they remain intact for hospitals - and replacing them with one that allows providers to meet at least 75% of the requirements and still pass; and
4) Giving facility-based clinicians the option to use their institution’s performance rates as a proxy for the MIPS’ clinician’s quality scores
With regard to Stage 3 Meaningful Use measures and similar measures included in the Advancing Care Information category, CHIME expressed concerns about technology and vendor readiness.
“We are deeply concerned with CMS’ decision to push forward with timelines that call for Stage 3 and Stage 3-like measures beginning in 2018,” the organization notes. “Both vendors and providers need time to prepare for the requirements. For vendors that means development time and for providers that means testing and deployment.”
According to CHIME, many providers who had been planning to attest to Stage 3 Meaningful Use-like measures are not able to do so specifically because of vendor readiness issues.
“In fact, some of our members have already alerted us to the fact that they will not receive their upgraded products until well into 2018,” CHIME explains. “If you couple this with the concerns we have outlined around interoperability, it becomes clear that the road ahead, while paved with good intentions, is fraught with signals and warning signs.”
Additionally, the leaders of CHIME advocate for better flexibility within the Advancing Care Information reporting category under MIPS. The group advises CMS to reduce the number of measures eligible clinicians must report, accommodating those meeting modified Stage 2 Meaningful Use, increasing the maximum number of points for 131 to 155, implementing a 90-day reporting period for 2017 and 2018, offering bonus points for clinicians using CEHRT to meet practice improvement measures, and offering bonus points to clinicians reporting to multiple public health and clinical registries.
Earlier this week, AMGA and MGMA both posted public comments on the MACRA implementation rule, focusing on the 2017 transition period for the program.
AMGA said CMS needs to ensure the transition period only lasts through 2017. This will better serve those eligible clinicians who were ready for full implementation this year and allow them to receive their maximum reimbursement.
“The agency's decision to define 2017 as a ‘transition year’ is a step backward as it penalizes providers that have taken steps to improve care and population health and reduce spending growth in order to effectively subsidize providers that have not yet to date chosen to do so,” said AMGA President Donald W. Fisher, PhD. “AMGA hopes CMS will fully implement the MIPS program in performance year 2018.”
MGMA said CMS must ensure the shift from 2017 to 2018 goes smoothly, should they choose to end the flexible transition period. Specifically, the organization suggested an iterative approach, increasing the requirements for eligible clinicians to help ease them into full reporting.
“Not only would this promote continued buy-in from physicians and group practices, but a longer transition period will provide CMS with more opportunity to address a myriad of methodological issues in MIPS, including the establishment of a new patient attribution process,” said Anders Gilberg, MGA, Senior Vice President of Government Affairs at MGMA.
All of these comments come as MACRA implementation is fast approaching. Eligible clinicians start reporting to the Quality Payment Program and MIPS starting Jan. 1, 2017.