With the passage of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), three existing Medicare quality programs (Physician Quality Reporting System, Value-Based Payment Modifier, and Medicare Electronic Health Record Incentive/Meaningful Use) are rolled into one new Medicare payment model known as the Merit-Based Payment System (MIPS). One of the key components of MIPS for which physicians and other eligible clinicians will be evaluated is called Advancing Care Information (ACI). Thus, physicians may find themselves asking several questions including:
Is meaningful use gone for good?
The simple answer is yes and no. Medicare Meaningful Use (MU) as a stand-alone program, its pass/fail approach, and related negative payment adjustments for non-participation or unsuccessful participation will be gone by 2019. However, MACRA emphasizes the use of health information technology as tool to help advance the sharing of information among care settings and to engage patients in their care through more accessible personal and educational information. Therefore, several components of MU are incorporated into the new ACI component of MIPS. It is anticipated that physicians who are current successful MU participants will have a smooth transition to ACI expectations. In addition to greater flexibility in selecting measures, the measures will be familiar and several experts have predicted that meeting ACI requirements in 2017 will likely be easier than under MU.
Of note, the Medicaid Electronic Health Record (EHR) Incentive Program is NOT affected by MACRA. Therefore, physicians participating in this program will continue to report meaningful use through their respective state Medicaid agencies. Additionally, the incentives under the Medicaid EHR Incentive Program continue through 2021.
Has my investment in certified electronic health record technology (CEHRT) been for naught?
No. When the Medicare and Medicaid EHR Incentive Programs were initially created, the legislation and related regulations called for the standardization of certain functionality. Congress, the Centers for Medicare and Medicaid Services, and the Office of the National Coordinator for Health Information Technology intended that physicians and others purchasing EHRs would have some assurance that their EHR met minimum standards necessary for them to accomplish MU requirements. Regardless of whether a physician participates in Medicare via the Advanced Alternative Payment Model or MIPS pathway, he/she will be expected to utilize CERHT to meet certain requirements. For the 2018 performance period, physicians and other eligible clinicians must use CERHT that meets the 2015 edition certification standards. Ask your EHR whether your system meets those standards and if not, when will the vendor will have upgrades available and what is their plan for dissemination, installation, and training if necessary.
If the MU penalty is going away, do I still need to attest?
Yes. It is imperative that physicians attest to 2016 meaningful use participation by February 18, 2017, to avoid a 3 percent penalty in 2018. If you have not previously participated in MU and 2017 would be your first year, you can avoid a penalty in 2018 by successfully completing 90 consecutive days of MU within the first 9 months of 2017 and attesting by October 17, 2017.
What are the requirements of the ACI component?
All physicians and eligible clinicians for whom the ACI requirements are applicable must meet the following base requirements in 2017 (for those using 2015 edition CERT, there are some additional measure options):
- Electronic Prescribing
- Health Information Exchange
- Provide Patient Access (e.g., patient portal)
- Security Risk Assessment
Additionally, scoring can be enhanced by reporting on optional measures:
- Immunization Registry Reporting
- Medication Reconciliation
- Patient Specific Education
- Secure Messaging
- Specialized Registry Reporting
- Syndromic Surveillance Reporting
- View, Download, or Transmit/VDT (e.g., one patient VDTs their health information to a third party)
For additional information including a link to sign-up for future CMS notifications of updates and MACRA programming, visit https://qpp.cms.gov/.