Meaningful Use, MACRA, MIPS, Promoting Interoperability. So many terms, so many regulations. What do these all mean for physicians and practice owners?
In January of 2016, CMS put forth Stage 3 (2015 Edition) of Meaningful Use. This was before the introduction of the Merit-based Incentive Payment System (MIPS) under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), introduced later that year. Andy Slavitt, former Acting Administrator for CMS explained the change:
The Meaningful Use program as it has existed will now be effectively over and replaced with something better.
Meaningful Use Stage 3
In an effort to improve healthcare through better access to information, CMS included eight advanced use objectives for Stage 3:
- Protect electronic protected health information (ePHI)
- Clinical decision support (CDS)
- Computerized provider order entry (CPOE)
- Patient electronic access
- Coordination of care through patient engagement
- Health information exchange
- Public health reporting
Although many of these stem from Stage 2 with minimal modifications, they require extensive resources for EHR vendors, both big and small.
The vice president of policy and government affairs for Allscripts, Leigh Burchell, announced that Stage 3 requirements drained innovation for the industry.
We certainly understand the thinking behind a lot of the suggestions, but believe the scope of what ultimately was presented was really too significant, particularly within the scope of time they allowed for the work to be done, […] If we have to devote resources for all these requirements, we have to use resources that could be innovating elsewhere.
Many EHR vendors are questioning whether attesting to Meaningful Use Stage 3 is even worth the resources, wanting to concentrate them on innovating their platform further and developing essential functionalities that physicians and practices need.
Putting aside EHR vendors, physicians and practices have recently been delving into the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). CMS’ MACRA, signed into law on April 16, 2015, ended the Sustainable Growth Rate (SGR) formula. Under MACRA, there are two Quality Payment Programs:
- Advanced Alternative Payment models (APMs) or
- The Merit-based Incentive Payment System (MIPS)
The Quality Payment Program we see the most is perhaps MIPS, with 2017 having been the transition year, not all four categories were weighed and clinicians only had to attest for any three-month period during the year. In 2018, on the other hand, MIPS is in full swing, requiring attestations for the entire year and the meeting of performance categories to receive points towards their final score.
In its first year, to avoid a negative payment adjustment, clinicians had to score 3 points out of 100, with 2018 requiring 15 points out of 100.
Beginning January 1 and ending December 31 of each year, MIPS program participants must report their data by March 31 of the following year to receive possible payment adjustments. Tying payments to cost efficient and quality care, MIPS was designed to promote better care processes and health outcomes as well as reduce costs of care.
Promoting Interoperability, the New Stage 3
A breakdown of the MIPS performance categories shows that:
- Quality replaces PQRS
- Cost replaces the Value-Based Model (VBM)
- Improvement Activities have many categories that assess how you enhance patient engagement in care, improve your care processes, and increase access to care
- Advancing Care Information replaces the Medicare EHR Incentive Program (Meaningful Use)
So, how does Meaningful Use fit into MIPS?
The year 2018 has brought about new changes, with Advancing Care Information now being referred to as Promoting Interoperability.
This category, in a way, encompasses Stage 3 of Meaningful Use in a new payment model within a new program.
With the goal to ease the flow of health information between providers and patients, the program aims to highlight interoperability. This is done by making clinicians choose measures that advance the productive use of healthcare information they create through the ability to share this data with their peers or the patient themselves. This information can include test results, therapeutic plans, visit summaries and more.
The MIPS Performance Category of PI caries many of the objectives Stage 3 had. The 4 base score 2018 Promoting Interoperability transition measures are:
- Health information exchange
- Provider-to-patient exchange
- Public health and clinical data exchange
In short, PI has become the new stage 3, with eased regulatory burdens for a smoother transition. While Meaningful Use Stage 3 is now being referred to as Promoting Interoperability, its score in MIPS has not changed.
One thing is for certain, changes will continue to roll out as pushback from various stakeholders continue to arise. In the meantime, 15 points out of 100 will grant no payment adjustment in 2018, with 16 or higher yielding a positive payment adjustment. For all consecutive years, the threshold for payment adjustments will be calculated on a mean or median of all MIPS final scores for a prior year.
For a complete presentation on CMS’ Final Rule for year 2 of the Quality Payment Program, see their slide presentation.