There has been a lot of talk about the death of MU, the start of MACRA/MIPs, and all the regulation around them. With all the hubbub buzzing around, I thought this would be a good opportunity to break it down and give the conversation some clarity.
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How it All Played Out
CMS* Acting Administrator, Andy Slavitt, MD, made an announcement regarding MU* ending that left many feeling somewhere between “heaven and hell.” In this state of purgatory, many were asking, “what do we do now?” What we have come to know is a misunderstanding of Slavitt’s comments on MU, and that the MU program, as we know it today as a “separate” program, is ending at year-end 2018. MU is on a timeline shifting into MACRA*/MIPs*. Currently, laws require HHS* to measure the meaningful use of ONC* Certified health IT under the existing set of standards; moreover, HHS has set firm goals to move to Value-Based Care, and the announcement of MACRA/MIPs is one more step in that direction.
What’s Going to Happen?
Moving forward to 2019 and beyond, MACRA combines the PQRS*, MU, and VBM* programs into MIPS and incentives for providers to participate in APMs*. MACRA creates two tracks for providers: the “MIPS or APM*” option. Additionally, MACRA requires MU compliance as a 25% part of the MIPs program calculation.
What You Should be Doing
Providers should stay the course in the drive toward MU and eCQMS*, while intensifying efforts on quality and outcomes to meet the expectations of MACRA. MACRA will provide an opportunity to adjust the payment incentives associated with EHR incentives, but does not eliminate the EHR incentive program. As a reminder, MACRA only addresses Medicare Physician/Clinician payment adjustments, not Medicaid. The EHR incentive programs for Medicaid and Medicare Hospitals have a different set of statutory requirements, which are not directly impacted by MACRA. *At this time, MU 3 is in full play for everyone.*
What Else Can We expect?
- It is anticipated for CMS to release a MACRA NPRM* in spring 2016, with rules to be finalized in fall 2016
- 2017 is likely the first reporting year for the 2019 MIPS payment adjustment
- Under MIPs, separate payment adjustments under the PQRS*, VBM, and MU will sunset December 31, 2018.
- MIPS payment adjustments will begin January 2019 with a maximum payment adjustment of 4% in 2019 and incrementally increasing to a maximum of 9% in 2022 and onward
- For 2019 to 2024, there will be an additional payment adjustment given to the highest MIPs performers for exceptional performance
- NOTE: MACRA is for Medicare physician payments, not the hospital or Medicaid
So Why is CMS taking this Direction?
While the EHR incentive program has had its benefits, MU has also been fraught with challenges. Frustrations arise particularly among providers who have experienced interruptions in their clinician workflow when caring for patients, which impede their ability to focus on improving quality and outcomes.
CMS is trying to create a better environment where providers are allowed flexibility to customize health IT to their individual practice needs; in other words, technology needs to be more user-centered, better supporting physicians and clinicians, and subsequently rewarding providers for the outcomes they are able to achieve through technology.
CMS is also trying to level the playing field to promote innovation, including opportunities for new start-ups by unlocking electronic health information through open application programming interfaces (API). This will allow new apps, analytic tools, and plug-ins to connect more easily so that data can be securely accessed and directed where and when the data is needed to support patient care.
Lastly, HHS is focused on supporting federal, national interoperability standards that focus on real-world use cases of technology. HHS is taking a strong stance towards business models that prevent or inhibit data from flowing around the needs of the patient, saying they will not be tolerated. With the thought of information sharing, CMS recently released an NPRM to give access to information to drive quality and patient care improvement. Responses and comments regarding this NPRM are due by March 29 2016.
Undoubtedly, there is more to learn about MACRA so be on the lookout for another NPRM in spring 2016. MACRA & MU will most certainly will be talked about at HIMSS16 in special sessions such as “Standards: Moving Beyond Meaningful Use” on Feb 29. Stayed tuned as the road continues with twist and turns.
*Healthcare Acronyms 101:
- CMS, Center for Medicare & Medicaid Services
- MU, Meaningful Use
- MACRA, Medicare Access & CHIP Reauthorization Act of 2015
- MIPs, Merit-Based Incentive Payment System
- HHS, Health & Human Services
- ONC, Office of the National Coordinator for Health Information Technology
- PQRS, Physician Quality Reporting System
- VBM, Value-Based Payment Modifier
- APM, Alternative Payment Models
- eCQMs, Electronic Clinical Quality Measures
- EHR, Electronic Health Record
- NPRM, Notice of Proposed Rulemaking