Home > EHR, meaningful use, Medicare > CMS Planning to (Re)position Meaningful Use for the MIPS Era

CMS Planning to (Re)position Meaningful Use for the MIPS Era

The recent comments of Andy Slavitt (Acting Administrator, Centers for Medicare and Medicaid Services [CMS]) at the J.P. Morgan Annual Health Care Conference created waves around the Internet, in large part because of the oversimplified, click-bait headlines: MU will be over in 2016!!! The agency quickly had to post clarification tweets as well as a full transcript of Slavitt’s presentation on its website – which is not the standard operating procedure for presentations given at conferences, by the way.

With the clarification, Slavitt’s real message was basically this: Meaningful Use (MU), as it has existed, will no longer exist in the Merit-based Incentive Payment System era. In fact, Slavitt pointed out in his presentation that all three incentive programs (MU, PQRS, and VBM) will be “sunset” and “aligned together in a new single program.” Importantly, official agency announcements will be coming over the next several months, presumably including the MIPS/APMs proposed rule itself which was already planned for March-April-ish 2016.

MIPS and its repackaging of the financial components of the three current quality incentive programs is obviously old news. So, what else did Slavitt mean for MU’s future?

This is just a guess, but his statements could indicate a radical simplification of MU requirements heading into the MIPS era. Stage 3 was the previous plan, but maybe the agency plans to revert back to the basics of the statute – before the federal advisory committees to ONC and the agencies helped turn MU regulatory implementation into a complicated tapestry of unnecessary objectives and data capture exercises. After all, “MU,” and however that concept is defined in the future, still needs to be 25% of a physician’s composite score under MIPS.

Slavitt’s full statement includes a glimpse at what the “MU” 25% of the composite score could mean in the MIPS era:

“Let me dive a little deeper on the technology component. Now that we effectively have technology into virtually every place care is provided, we are now in the process of ending Meaningful Use and moving to a new regime culminating with the MACRA implementation.

The Meaningful Use program as it has existed, will now be effectively over and replaced with something better. Since late last year we have been working side by side with physician organizations across many communities — including with great advocacy from the AMA — and have listened to the needs and concerns of many. We will be putting out the details on this next stage over the next few months, but I will give you [the] themes guiding our implementation.

For one, the focus will move away from rewarding providers for the use of technology and towards the outcome they achieve with their patients.

Second, providers will be able to customize their goals so tech companies can build around the individual practice needs, not the needs of the government. Technology must be user-centered and support physicians, not distract them.

Third, one way to aid this is by leveling the technology playing field for start-ups and new entrants. We are requiring open APIs in order to the physician desktop can be opened up and move away from the lock that early EHR decisions placed on physician organizations so that allow apps, analytic tools, and connected technologies to get data in and out of an EHR securely.

And finally, we are deadly serious about interoperability. We will begin initiatives in collaboration with physicians and consumers toward pointing technology to fill critical use cases like closing referral loops and engaging a patient in their care. And technology companies that look for ways to practice “data blocking” in opposition to new regulations will find that it won’t be tolerated.”

Each of the themes Slavitt listed were clearly based on the original HITECH statutory definition of MU, paraphrased as follows:

1) certified EHR technology is used in a meaningful manner (eRx is the only example used by Congress);
2) information exchange (connected and able to exchange health information for quality and care coordination); and,
3) reporting on clinical quality measures (CQMs).

Reverting to the original Congressional intent via a radical simplification of “MU” would be welcomed by physician participants dreading the expected regulatory challenges of MIPS participation. MU will be a supporting character – not the star of the show – during the MIPS era, so it makes sense to streamline the MU definition into something more manageable and, frankly, less extensive.

How the changes will be implemented in regulation will hopefully be answered by the future CMS announcements—will there be a separate standalone rulemaking to replace Stage 3, or will these changes be handled within the MIPS rulemaking itself?  Slavitt’s comments suggest the changes have not yet been drafted internally, which could mean the upcoming APMs/MIPS proposed rule will either be delayed beyond the March-April-ish timeframe, or that a separate proposed rule will be needed to reform the MU piece of the MIPS puzzle.  Stay tuned…

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Categories: EHR, meaningful use, Medicare
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