In Part 1 of this post, I provided an overview of the new Medicare Quality Payment Program (QPP) proposed in response to the 2015 Medicare Access and CHIP Reauthorization Act (MACRA), which sets out a path to value-based Medicare physician payment. The CMS proposed rule implementing MACRA was released April 27; comments are due June 27. In Part 2, I summarize healthcare IT (HIT) implications of the QPP and provide my initial observation on the proposed rule.
It does not appear that MIPS and changes to Advancing Care Information (formerly called Meaningful Use) will initially require major changes in certified EHR/HIT functionality but GE and other HIT vendors are reviewing the proposal in detail, focusing especially on any changes on measure specifications, potential enhancements needed for reporting and progress dashboards, and on APM requirements. ONC and CMS have stated that vendors should continue to build to the 2015 certified edition as finalized last October but, as expected, will allow use of 2014 edition certified EHR technology in 2017.
Overall, this proposed rule reinforces the growing importance of GE Healthcare offerings supporting the accelerating shift to integrated, value-based care, including broader use of highly-usable HIT, revenue cycle capabilities, analytics and population health management, interoperability and care coordination, and EHR-driven quality and performance measurement and reporting.
In addition, with increasing payments through APMs and a greater focus on outcomes, we anticipate (and hope for) a delivery system eco-system less subject to detailed federal regulation and more focused on various types of rapidly evolving risk-taking, population-focused organizations. This evolution will generate increased demand for cloud-based, app-focused HIT delivery.
The new GE Health Cloud and the announcement at Centricity LIVE of Project Northstar are designed to support our customers in this transformation. Especially relevant to MIPS, Project Northstar is GE Healthcare’s next generation IT solution for ambulatory care delivery, designed to help ambulatory practices thrive in value-based care. It will be cloud-based and combine population health, care delivery, and financial management into a fully integrated, interoperable and intelligent software solution.
So, what are my observations and suggestions a month in from the release of the Proposed Rule?
- This is a Proposed Rule and subject to changes, large and small in the Final Rule. Provisions that you like could go away and new problems could be introduced. So comment on what should change and what should remain as proposed.
- Take advantage of CMS, vendor, and professional society education programs and materials.
- CMS did excellent work in the context of the detailed legislative specifications in MACRA, and listened and responded constructively to many of the concerns raised about Meaningful Use and quality measurement. They tried very hard to get it right and made important advances in simplicity, flexibility, and focus.
- Still, the overall proposal is very complex and retains and in some cases introduces new variants of the very complexity and prescriptiveness that it sought to eliminate. CMS is moving ever more deeply into the care delivery process.
- Meaningful Use is still here, though renamed and enhanced in important ways. Although the “all-or-nothing” approach has largely disappeared, there will be even greater pressures to excel on ACI (formerly called MU) measures to do well for this category and, by design, about half of MIPS ECS will see payment cuts.
- Time is very short for the 2017 start of MIPS and APMs for CMS, for providers, and for vendors. We will all need to make important decisions based on “bets” about the Final Rule and constrained time and resources – it seems prudent to assume that the proposals for 2017 will largely survive intact.
- Providers should carefully consider opportunities to participate in accredited Patient Centered Medical Homes given opportunities in both the APM and MIPS tracks and, in general, think about whether they want to focus on MIPS or Advanced APMs for the initial years of the new program.
- In addition, if you have not been doing PQRS, consider starting for 2016 and also focus on 2016 MU performance levels to support the pressures for higher ACI performance levels in 2017.
- Audits will still be with us and will likely cover a broader set of activities, including CPIAs and interoperability attestations, so plan and document accordingly.
- Finally, this and related programs will evolve over time and so too can provider plans for when and how to engage – decisions made for 2017 will not set you on an irrevocable path forward – learn and adjust using the same iterative approach that GE Healthcare and other healthcare industry leaders have been taking to software development.