Archive for September, 2015

CMS Requests Stakeholder Input on Future Regulatory Implementation of SGR Fix

September 28, 2015 1 comment

Earlier today, the Centers for Medicare and Medicaid Services (CMS) released its long-anticipated Request for Information (RFI) on implementation of the Merit-based Incentive Payment System (MIPS) and promotion of Alternative Payment Models (APMs). The RFI will be formally published in the Federal Register on October 1 for a thirty-day public comment period. The bulk of the actual rulemaking activity is expected to commence next year, with 2019 being the start of the APM/MIPS payment implications.

As background, APM participation was promoted by legislation that permanently repealed the Sustainable Growth Rate (SGR) physician payment formula (Medicare Access and CHIP Reauthorization Act of 2015). Physicians with inadequate proportions of compensation from APMs would alternatively participate in MIPS—an umbrella quality incentive program that will restructure and revamp the existing Medicare quality incentive programs (PQRS, EHR/Meaningful Use, and VBM) into a composite score-driven incentive/penalty structure.

The government relations, economics, and quality and safety components of the ACR staff and leadership are reviewing the RFI as a team and compiling formal comments for submission to CMS. To provide input to ACR on the EHR/Meaningful Use/health IT components of the RFI, please email Michael Peters, ACR Director of Regulatory and Legislative Affairs, at

Categories: EHR, meaningful use, Medicare

ONC Releases Final Health IT Strategic Plan for Federal Agencies

September 21, 2015 Leave a comment

The HHS Office of the National Coordinator for Health IT (ONC) released its final “Federal Health IT Strategic Plan” for 2015 through 2020 on September 21. The American College of Radiology (ACR) submitted comments on the draft version in early 2015.

The latest strategic plan is the third iteration since 2008 of broad policy milestones for all health IT-related agencies in the U.S. federal government. The plan does not address private sector goals and activities, but instead focuses exclusively on outcomes government actors should strive for over given periods of time.

ACR Government Relations staff will review the document over the coming days for differences between the final and draft versions. Members with questions or feedback should please contact Michael Peters, ACR’s Director of Regulatory and Legislative Affairs, at

Filing and Sharing Health IT-Related Complaints

September 17, 2015 Leave a comment

The HHS Office of the National Coordinator for Health IT (ONC) recently announced a new webpage for physicians and others to file unresolved health IT product complaints. The service is meant to be a last resort for those who already contacted their vendor and, if applicable, the ONC-Authorized Certification Body (ACB) that certified the product in question.  The following are potential concerns that would be legitimate reasons for contacting the agency:

  • Health information blocking
  • Unable to share or receive health information
  • Product usability
  • ONC-ACB certified capabilities not performing as expected
  • Product safety

Please see the ONC’s blog entry for details about this helpful new service.

On a different but related note, the American Medical Association (AMA) provides a relatively new website,, for sharing stories and information about challenges with the Medicare/Medicaid EHR Incentive Program.  The site also includes educational resources about the program and grassroots advocacy features.

The American College of Radiology continues to provide radiologist-specific resources on its Meaningful Use Resources page.

Categories: EHR, meaningful use, Medicare

OMB Reviewing Final Rules to Update Meaningful Use and HIT Certification Criteria

September 11, 2015 Leave a comment

Last week, the HHS Office of the National Coordinator for HIT (ONC) and Centers for Medicare and Medicaid Services (CMS) submitted final rules to update the EHR Incentive Program participation and technology certification requirements for White House Office of Management and Budget (OMB) regulatory review. OMB regulatory review is one of the final closed steps prior to public release, and the process typically takes 30 to 90 days.

There are two CMS final rules (2015-2017 and Stage 3) and one ONC final rule (2015 Edition HIT certification criteria) under review. We should expect at least the main final rule on meaningful use (MU) modifications for 2015-2017 to be published before October to enable 90-day reporting periods to commence on October 1. The Stage 3 final rule also includes “modifications for 2015-2017” in the title, which could mean pieces of the MU fix are divided between some sort of expedited “modifications” final rule and a lengthier “Stage 3” final rule to be published later. However, it is equally possible that all three CMS and ONC final rules will be published simultaneously given that all three were submitted for OMB review on the same September 3 date.

Stay tuned…

Categories: EHR, meaningful use, Medicare