The Medicare Access and CHIP Reauthorization Act (MACRA) gives the Centers for Medicare and Medicaid Services (CMS) authority to alter the payment system for Eligible Clinicians (ECs) who accept Medicare payments under the Physician Fee Schedule (PFS). The agency introduced its proposed methodology via CMS’ Notice of Proposed Rulemaking (NPRM) on the new Quality Payment Program, comprised of two tracks for EC payment under the Merit-Based Incentive Payment System (MIPS) or through Alternative Payment Models (APM). The MIPS program consolidates existing PFS-related quality- and value-based payment programs to emphasize quality over quantity of care, as well as the effective use of resources and certified EHR technology (CEHRT). Cerner submitted detailed comments on the NPRM, highlighting areas of the proposed rule where we believe clarification and improvements could be made to ensure both MIPS and APMs meet legislative intent and continue to move our health care system in the right direction.
Below is a summary of the key points made in Cerner’s comments, which were submitted to CMS on June 24, 2016:
- CMS should not significantly alter the three programs in the early performance periods of 2017 and 2018 that are being rolled into the MIPS program – Value-Based Modifier, Physician Quality Reporting System and Meaningful Use. These are all established programs, and we recommended that CMS use these as the starting points for the Resource Use, Quality and Advancing Care Information categories under MIPS. Altering the requirements on a shortened timeline would create uncertainty and confusion, and the resulting reported outcomes would not be indicative of actual performance. We also recommended that they pull over the existing FAQs from these programs as the basis of guidance for the related domains under MIPS.
- CMS should provide clarity on the electronic Clinical Quality Measures (eCQMs) when it comes to certification and submission requirements across the methods available that make use of electronic measure specifications. Not all of the measures will be eCQMs, but there are certification requirements that may require reporting mechanisms to become certified, so we asked CMS to provide clarity on what these requirements may entail and to which method they apply.
- CMS should not continually change the reporting periods and reporting requirements for 2017 for the Advancing Care Information (ACI) category. Over the past year, CMS has announced three different performance periods and a distinct basis for measurement considering original Stage 2, modified Stage 2 and now ACI, making it very confusing for ECs tracking their performance. We recommended CMS adopt a 90-day reporting period for 2017 and allow the use of 2014 and 2015 Edition CEHRT for the ACI category measures. We also asked CMS to review its options in 2017 for measure scoring and allow Computerized Physician Order Entry (CPOE) to be included in the Performance Score category.
- Regarding ECs eligibility for Alternative Payment Model (APMs), we asked for specificity on how an EC will gain Qualified Participant (QP) status. We recommended CMS find ways to let the ECs within an APM know during the reporting year if they are on track to meet QP status, as this will determine whether they must also report to MIPS. A benefit of being a QP in an APM is it grants exemption from MIPS reporting, but if ECs do not know whether they qualify, this incentive is significantly undermined, which runs counter to MACRA’s goal of increasing APM participation.