Last week, the Department of Health and Human Services (HHS) issued a proposed rule to implement key provisions of the Medicare Access and Summary CHIP Reauthorization Act of 2015 (MACRA). The proposed rule addresses changes through the unified framework called the Quality Payment Program, which includes two paths:
- The Merit-based Incentive Payment System (MIPS), and
- Advanced Alternative Payment Models (APMs)
The MIPS track further defines its program into four performance categories:
- Cost – based on Medicare claims
- Quality – flexible reporting options based on differences in clinician specialties and practices
- Clinical Practice Improvement Activities – rewards clinical practice improvement activities such as those focused on care coordination, beneficiary engagement, and patient safety
- Advancing Care Information – replaces Meaningful Use for physicians
With this proposed rule, the HHS wanted to address three central priorities moving forward:
- Improved interoperability along with the ability of physicians and patients to easily move and receive information
- Increased flexibility as compared to the Meaningful Use program
- User-friendly technology designed around physician workflows
More specifically, the Advancing Care Program within MIPS is touted as being more patient-centric, practice-driven, and having a strong focus on connectivity. Emphasis will be on interoperability, information exchange, with importance placed on security of PHI and a requirement to give patients access to their health information through APIs.
This proposal, if finalized, would replace the current Meaningful Use program and reporting would begin January 1, 2017. The proposal will be available for public comment over the next 60 days. Under this proposed law, Advancing Care Information would affect only Medicare payments to physician offices, not hospitals or Medicaid programs.
Clinicians must still use a certified Electronic Health Record (EHR), as defined in Defining Key Health Information Technology Terms (The National Alliance for Health Information Technology, April 28, 2008): An electronic record of health-related information on an individual that conform... technology and would choose to report a customizable set of measures that reflect their workflows, with a particular emphasis on maintaining interoperability and information exchange. The all-or-nothing EHR measurement and quality reporting would no longer be required as it was with Meaningful Use.
CMS proposes six objectives for this category:
- Protect Patient Health Information
- Patient Electronic Access*
- Coordination of Care Through Patient Engagement*
- Electronic Prescribing
- Health Information Exchange*
- Public Health and Registry Reporting
For the three objectives starred above, clinicians can select the measures that best fit their day-to-day practice activities giving them the flexibility to comply without the extra burden that has come with compliance in the past.
The six objectives are similar in nature to some of the past interoperability requirements from Meaningful Use. Elements of Transfer of Care, View-Download-Transmit, and public health reporting have evolved into the new objectives. Improvements in the objectives “should increase providers’ ability to use technology in ways that are more relevant to their needs and the needs of their patients,” according to a blog from Acting Administrator Slavitt and National Coordinator Karen DeSalvo on Advancing Care Information.
APIs requirements are also key in opening up connectivity flexibility. APIs will enable physician apps, patient apps, analytic tools, and medical devices to plug-and-play with healthcare data, leading to a better user experience for involved in the healthcare experience.