Looking at the health IT portion of the MACRA proposed rule shows us that components of Meaningful Use have been carried over to the new reporting program.
The words "Meaningful Use" will no longer be applicable but that doesn't mean the remnants of the program will be gone.
In fact, "Advancing Care Information," the new term for Meaningful Use, as part of implementation of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), has a familiar look to it. Under the Merit-Based Incentive Payment System (MIPS) track of MACRA which scores Medicare reimbursement on four categories (technology implementation and usage; quality; clinical improvement; and cost), the Advancing Care Information will essentially require physicians to attest to measures from Stage 3 of Meaningful Use to weigh their scores for the reporting period in 2017.
In other words, Meaningful Use isn't dead, it's reinvented.
For more of a breakdown on the MACRA proposed rule, click here.
Similarities and changes
It's not a complete carbon copy, as there are changes to Meaningful Use reporting. "They've eliminated the need for [physicians] to report clinical quality measures, because that's already being done through the quality portion of MIPS," says Tom Lee, Founder and CEO of SA Ignite, a Chicago-based software firm that provides assistance to providers on reporting for federal programs.
Also gone is the "All or Nothing" approach of Meaningful Use. Providers will be given half credit for simply attesting and the performance scores will be weighted based on percentages. However, Rob Tennant, the director of health information technology policy for the Medical Group Management Association (MGMA), says upon looking deeper into the 962-page proposed rule for MACRA implementation from CMS, this might not actually be the case.
"When you read the proposed rule, page 210, it says, 'Failure to meet the submission requirements, or measure specifications for any measure in any of the objectives would result in a score of zero for the Advancing Care Information performance category base score.' I don't see that as anything other than all or nothing. Yes, they've decreased the number of requirements, but they've made it clear, at least to me, if you miss out on any [measure], you get a complete zero for this category," he says. CMS did not comment on requests for clarification on the meaning of that line in the proposed rule.
Meanwhile, a lot isn't left up to interpretation in terms of what's carrying over from Meaningful Use to Advancing Care Information. As stated, the Stage 3 of meaningful use measures will carry over to MACRA implementation, under less demanding thresholds. This includes asking eligible professionals (EPs) to get patients to view, download, and transmit their health information; to securely message patients; to exchange health information with other providers; to send EHR data to public health registries, to secure patient data, to integrate patient-generated data, and much more. In Advancing Care Information, EPs will be able to select measures that best fit their practice. There are bonus points available in the performance aspect of Advancing Care Information, meaning if EPs do particularly well on one category, it can make up for lacking in another.
One of the more significant holdovers from Meaningful Use that has been incorporated into Advancing Care Information is the reporting period requirements, says Tennant. "There is a one-year reporting period [under MIPS]. That's problematic," he says. "One-year reporting is overkill. Quarterly reporting is more than fair."
He notes that physicians aren't going to turn off a module of their EHR, such as ePrescribing, from one quarter to another just to satisfy reporting requirements. In the proposed rule, CMS reasons that the full-year reporting period aligns Advancing Care Information with the other MIPS categories and gets them all on a "common timeline."
Seeing as it's a proposed rule, there will be plenty of time for physicians to comment before the end of the comment period (June 30). The comments could lead to significant changes. Moreover, as Tennant notes, because this is an election year, the rule could be put on hold until a new administration is in place. Lee at SA Ignite, however, sees it as "the new black" for Medicare Part B physicians. He notes, "This is bipartisan. It's not getting overturned regardless of what happens in November."
Even with the uncertainty, both Lee and Tennant say this should be taken seriously by physicians. MACRA could have significant financial impact, as the first payment year (for 2014 reporting) could include up to a 4 percent Medicare adjustment. CMS itself projects, using 2014 data, 87 percent of solo practices will face a negative adjustment in year one of MACRA, equaling $300 million. "For some specialties, like podiatry and rheumatology, which are very heavily Medicare, this could be very significant to their bottom line," says Tennant. "Smaller practices, they are running on pretty thin margins as it is. Getting a pay cut of 4 percent, it's very meaningful for these folks."
For practices, Tennant advises taking a "good, hard look at your options," including possibly bypassing MIPS and going with the Advanced Alternative Payment Model track, which would mean joining an eligible Accountable Care Organization, Patient-Centered Medical Home, or similarly devised risk-bearing program. Tennant also says EPs will "need to be actively engaged with their EHR vendors."
Lee at SA Ignite says physicians should educate themselves, use this year as a dress rehearsal by participating in Meaningful Use and other current reporting programs, and stay on top of deadlines. "Try to optimize for your point total. That's what it's all about right now," Lee says. "You have to plan out how you need to prioritize your time. It starts on January 1, so you have eight months."