Jeff Smith, VP of Public Policy at AMIA, and Jake Ellis, manager of regulatory compliance practice at Cerner, recently presented a primer on the Medicare Access & CHIP Reauthorization Act (MACRA) to attendees of Cerner's CPC and Ambulatory Summit. Smith discuss the new policy from an industry perspective while Ellis shares how MACRA will effect Cerner clients.
The Centers for Medicare and Medicaid Services (CMS) issued proposed rules designed to fundamentally change the way Medicare reimburses physicians for care. The rules would alter decades of fee-for-service payments through the creation of a multi-program, Merit-based Incentive Payment System (MIPS) and a host of alternative payment models (APMs). Of particular interest is a component of MIPS called the Advancing Care Information (ACI) performance category that is designed to replace meaningful use (MU).
While there are several differences between the old MU program and the proposed ACI, eligible professionals – now referred to as eligible clinicians (ECs) – who have experience with MU will notice numerous similarities as well. Gone is the "all-or-nothing" requirement that the user has to meet all MU thresholds to be considered a successful meaningful user. The ACI also dropped some required categories, including Clinical Decision Support and Computerized Provider Order Entry, because the majority of ECs were hitting high marks in those categories.
Additionally, the ACI creates flexibility, through a novel scoring system, for ECs who would rather focus their efforts on engaging patients through APIs than trying to figure out how to collect patient-generated health data. According to the CMS, “the overall ACI score would be made up of a base score and a performance score for a maximum score of 100 points.” The base score makes up half of these 100 points. To earn all 50 points, a MIPS EC must demonstrate that “at least one unique patient” was involved with each measure, such as sending at least one secure message during the reporting period. MIPS ECs must also answer yes to:
For the performance portion of the overall ACI score, ECs must submit performance data (numerator and denominator percentages) for eight measures across the Patient Electronic Access, Health Information Exchange and Coordination of Care Through Patient Engagement objective areas. The total points awarded will be determined by meeting the base score requirements (of at least one) and the performance percentages.
The basic comparison is this: MU Stage 3 had 15 measures that providers were measured against, such as the percentage of patients who were able to access their health information using an online patient portal. There are now eight measures that providers are measured against. Click here for a crosswalk between old MU Stage 3 requirements and proposed ACI requirements.
Clearly, MU has not been removed from federal requirements. It has not even been recast in a terribly different mold. It has been rebranded. Plain and simple.
This does not mean we should all despair. There are new opportunities to leverage MIPS as a framework, not simply as a set of requirements. This program will include an estimated 1.3 million ECs. With such a large number of ECs, CMS is hoping MIPS can help transform care delivery in ways that address costs and quality, while experimenting with care improvement activities and participating in a modern, connected care system. Roughly $833 million, plus a $500 million pot of incentives, will be in play for MIPS ECs, and those who perform well in this new paradigm will be looking at a possible 12 percent increase in Medicare B payments in 2019.
The collective capacity of providers to handle tremendous change will be seriously tested over the next several months. But those ECs who are able to see the forest through the trees will be rewarded, and they will be vital participants in the decades-old question of how to move past our broken fee-for-service health care system.
The recent release of the proposed MIPS will have a significant impact on health care providers delivering care in the ambulatory setting. MIPS replaces the Sustainable Growth Rate formula and provides financial incentives for providers to provide better, not more, care. It also combines multiple existing programs (Physician Quality Reporting System, Value Modifier and Meaningful Use) into one.
It’s important to note that MU will still be required for eligible hospitals, critical access hospitals and any providers participating in the MU program for Medicaid
Providers who choose to participate in the MIPS program need to plan to upgrade to the 2015 edition of Certified Electronic Health Record Technology (CEHRT) by the end of 2017. This will ensure they have all of the technical capabilities required to participate in MIPS. The proposed rule provides flexibility to providers in 2017 allowing them to attest to a modified set of measures as part of the ACI pillar. This allows organizations the ability to complete their upgrade to 2015 CEHRT during the 2017 calendar year.
The ACI portion of MIPS places significant importance on meaningful engagement of patients in their health and care, as well as interoperability of health systems. Half of the ACI score is determined by a provider’s ability to meet these measures. It will be important for providers to have strategies in place for engaging their patients in their care, both inside and outside the four walls of their practice, through the use of patient portals and secure messaging.
In order to achieve interoperability, the use of health information exchanges and Direct secure messaging will be critical to an organization’s success.
In order to be successful within MIPS, providers should begin their planning now. They must educate themselves on the changes that will be required of them, and put together plans and strategies to achieve the new requirements.
By Jeff Smith, Vice President of Public Policy, AMIA ;Jake Ellis, Manager, Regulatory Compliance Practice