Medicare Compliance & Reimbursement

Advancing Care Information eliminates the ineffective ‘one-size-fits-all’ approach.

Remember all that buzz earlier this year about the Centers for Medicare & Medicaid Services (CMS) getting rid of the Meaningful Use program? Well, it’s official: Get ready to start reporting under a new program by the beginning of next year.

New Program Doesn’t Apply to All

After dropping a bombshell in January 2016 that it will do away with the Electronic Health Records (EHRs) Incentive Program — better known as Meaningful Use — CMS announced on April 27 a new proposed rule that will make this transition a reality.

Since the January announcement, CMS says it has conducted a review of the Meaningful Use program for Medicare physicians, consulting more than 6,000 stakeholders nationwide, including clinicians, patients, and others. Based on that feedback, CMS has decided to incorporate the old Meaningful Use program into the Merit-based Payment System (MIPS).

CMS will replace Meaningful Use under the Medicare Access and CHIP Reauthorization Act (MACRA), which many in the healthcare industry celebrated for repealing the sustainable growth rate (SGR) last year.

The new program within MIPS will be called “Advancing Care Information.” CMS aims for the new program to become more patient-centric, practice-driven, and focused on connectivity. Moving forward, CMS has three major goals: improved interoperability; increased flexibility; and user-friendly technology.

Important: The new law would affect only Medicare payments to physician offices, not hospitals or Medicaid programs. If finalized, the rule would replace the current Meaningful Use program with reporting under the new Advancing Care Information program beginning on Jan. 1, 2017.

Stakeholders are Cautiously Optimistic

The reporting requirements for the current incentive programs like Meaningful Use and Physician Quality Reporting System (PQRS) are “onerous and inflexible,” says Richard Loomis, MD, Vice President and Chief Medical Officer for Practice Fusion. The burden on providers is great, costing about $40,000 per year in administrative reporting costs alone to participate in these programs.

The proposed rule, however, takes encouraging steps toward simplifying reporting and improving flexibility, Loomis notes. Despite the proposed rule’s complexity and added reporting requirements in transitioning from fee- to value-based reimbursement, the changes to the Meaningful Use program will help simplify the attestation process.

“Our goal with Advancing Care Information is to support the vision of a simpler, more connected, less burdensome technology,” stated an April 27 blog posting by CMS Acting Administrator Andy Slavitt and Dr. Karen DeSalvo of the HHS Office of the National Coordinator for Health IT (ONC). “Compared to the existing Medicare Meaningful Use program for physicians, the new approach increases flexibility, reduces burden, and improves patient outcomes.”

Some of the key operational differences between the Meaningful Use program and the new Advancing Care Information program include the following improvements:

• More choices: The new program allows physicians and other clinicians to choose to select the measures that reflect how technology best suits their daily practice.
• Simplified process: The rule simplifies the process for achievement and provides multiple paths for success.
• Simplified reporting: The new program simplifies reporting by no longer requiring all-or-nothing EHR measurement or quality reporting.
• Improved interoperability: The rule emphasizes interoperability, information exchange, and security measures. The new program would require patients to access their information through Application Programming Interfaces (APIs).
• Reduced reporting burden: The rule reduces the number of measures from 18 to 11 measures.
• Provider exemption: The rule would exempt certain physicians from reporting when EHR technology is less applicable to their practice. The rule would also allow physicians to report as a group.

Which Changes You’ll Feel the Most

More specifically, the proposed rule would change the existing program to streamline reporting requirements in three key ways:

1. Nixing two attestation items. The rule proposes to remove Computerized Physician Order Entry and Clinical Decision Support alerts, because these two measures in Stage 2 Meaningful Use are consistently above 90 percent and therefore already widely adopted, Loomis notes.

2. Simplifying reporting for two measures. For the Health Information Exchange and Public Health and Clinical Data Registry reporting measures, the rule proposes to eliminate the requirement to track the numerator and denominator. Instead, you would provide a simple yes/no attestation.

3. Eliminating the first-time attestation period. Instead of having a 90-day reporting period for first-time attestations, CMS proposes to require a full calendar year reporting period for all stages and all providers, according to Loomis. This would eliminate a somewhat confusing aspect of attestation.

“These improvements should increase providers’ ability to use technology in ways that are more relevant to their needs and the needs of their patients,” Slavitt and DeSalvo wrote. “Previously established requirements for APIs in the newly certified technology will open up the physician desktop to allow apps, analytic tools, and medical devices to plug and play.”

CMS is encouraging developers to design EHRs around the everyday needs of clinicians, instead of taking a “one-size-fits-all” approach. CMS and ONC are continuing to use the federal government’s authority to eliminate barriers to interoperability among EHR systems.

Caveat: Despite simplifying the reporting process, the proposed rule expands the program’s scope, which appears daunting for most practices, Loomis states. For instance, the proposed rule has several hundred pages just describing the scoring and compensation for the new program.

Resources: CMS will accept public comments on the proposed rule through June 27. The proposed rule is a whopping 962 pages, and you can access it at https://s3.amazonaws.com/public-inspection.federalregister.gov/2016-10032.pdf. A summary of the proposed rule is available at www.hhs.gov/about/news/2016/04/27/administration-takes-first-step-implement-legislation-modernizing-how-medicare-pays-physicians.html.