CMS Cuts Number of Measures in Meaningful Use Successor

Ken Terry

October 17, 2016

In rolling out the final rule for the Medicare Access and CHIP Reauthorization Act (MACRA) on Friday, the Centers for Medicare & Medicaid Services (CMS) made a few significant changes in the health information technology (IT) component of that regulation.

Most importantly, CMS reduced the number of measures for Advancing Care Information (ACI), the successor to the meaningful use program, from 11 in the MACRA proposal to just five in the final rule. The objectives in the ACI performance category — one of four categories in MACRA's Merit-Based Incentive System (MIPS) track — emphasize clinical effectiveness, information security and patient safety, patient engagement, and health information exchange.

However, despite the talk at a CMS news conference about making it simpler and easier for physicians to meet the ACI criteria, the agency is still focusing on some requirements that are difficult for many practices to meet.

For example, a fact sheet from the Office of the National Coordinator for Health IT (ONC) says that the ACI goals include "querying" for patient information in other providers' electronic health records (EHRs), which is still beyond the capability of many practices. Clinicians are also supposed to be "incorporating patient-generated health data and data from a non-clinical setting," such as long-term care, home health, and behavioral health, into their EHRs. These capabilities are just starting to emerge or are still on the horizon.

CMS' final rule also provides additional flexibility in ACI "by allowing clinicians to select the measures that reflect how technology best suits their day-to-day practice and simplifying reporting," the fact sheet said.

Making It Less Burdensome

At the press conference, CMS Acting Administrator Andy Slavitt elaborated on this concept. "Until technology supports the workflow, [physicians] will view certified EHRs as a burden," he said. "That's one reason why we've reduced requirements for Advancing Care Information from 11 measures to five in the final rule and added more flexibility so physicians can pick the measures that are right for their practice."

In addition, he noted, CMS is aligning the ACI measures so they can serve double duty in the clinical practice improvement activities (CPIA) section of MIPS. "We expect the focus to be on your goals for the patient, not the goals of technology."

According to the fact sheet, "Participants using certified health IT will likely be engaged in many activities that satisfy requirements for the Improvement Activities performance category. This may include emerging health IT capabilities such as technology certified to capture social, psychological, and behavioral data, as well as technology certified to generate and exchange an electronic care plan."

In addition, the fact sheet notes, MIPS participants may earn bonus points in the ACI category if they used certified EHRs for certain improvement activities. These activities may be related to high-priority quality measures, the use of health IT to support improved patient outcomes, "and other key delivery system reform goals."

CMS has also established a bonus scoring opportunity in the quality category for practices that do end-to-end electronic reporting of clinical quality measures. Today, the majority of practices report to the Physician Quality Reporting System (PQRS) by using a claims-based method that requires the manual entry of special codes.

Slavitt framed the goal of getting practices to report quality measures electronically in terms of reducing the reporting burden on practices. "We must make it easier to configure quality measures so that physicians spend less time on reporting them and more time receiving feedback that is useful to them," he said.

The methods of electronic reporting include direct reporting from EHRs (often with the help of EHR vendors) and reporting via registries, including a CMS registry. There are also qualified clinical data registries operated by specialty societies, quality improvement collaboratives, and other third parties.

According to the ONC fact sheet, the government will "expand the availability of third parties to automatically calculate and report measures on a provider's behalf."

Kate Goodrich, MD, director of the CMS Center for Clinical Standards and Quality, explained this statement at the press conference. She said that CMS will allow third party vendors to submit data on clinical improvement activities and ACI measures, as well as quality measures. Some vendors may be able to report on all three, she said, whereas others can just report quality data. CMS is working on specifications that will allow data in all three categories to be submitted by any vendor, she added.

Goodrich also pointed out that "in the past 2 or 3 years, we've seen a significant uptick in the number of individual doctors and group practices that are using an electronic method of reporting."

APM Ramifications

Besides explaining the ramifications that the final rule for MIPS will have on health information technology, the ONC fact sheet also addresses the advanced alternative payment models (APMs) that form the second track of MACRA. These APMs include accountable care organizations (ACOs) that take financial risk for care delivery, as well as a few other models.

At least 50% of the clinicians in an advanced APM must use certified EHR technology for documentation and information exchange, the document notes. Starting in the 2019 performance period, the fact sheet states, eligible clinicians will be able to combine their experience in a CMS advanced APM with experience in an APM funded by other payers, such as Medicaid or commercial health plans, to potentially earn APM incentives. These "other-payer" APMs must also require participants to use certified EHRs.

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