As the Quality Payment Program enters its second year, the Centers for Medicare and Medicaid Services issued its 1,653-page final rule on Nov. 2, with an array of implications for the ways physician practices use information technology in 2018.
Among the biggest provisions is to allow doctors to use either 2014 or 2015 Edition certified electronic health record technology in Year 2 of the program – but gives a 10 percent bonus to those practices that make the leap to using only 2015 edition CEHRT.
CMS also included an interim final rule allowing for a hardship exception aimed at small practices and clinicians whose EHR use has been impacted by "extreme and uncontrollable circumstances" such as the recent hurricanes Harvey, Irma and Maria.
For three of the four components of the Merit-Based Incentive Payment System, meanwhile, it will maintain a 90-day reporting window: advancing care information, improvement activities and cost.
But CMS will require a full-year performance period for the quality component of MIPS. This, even as CMS recently announced its intention, with its "Meaningful Measures" initiative, to reassess just how many of those measures providers should have to report on.
That didn't sit well with some groups, such as the Medical Group Management Association, whose SVP for Government Affairs Anders Gilberg tweeted: "Deeply disappointed the final #QPP reg takes quality reporting requirement from 90 to 365 days in 2018 - not #patientsoverpaperwork."
CMS says it's trying to strike a balance between overly rigid regulations for providers and the need to promote innovation for better quality, delivered more efficiently.
"During my visits with clinicians across the country, I’ve heard many concerns about the impact burdensome regulations have on their ability to care for patients," said CMS Administrator Seema Verma.
"These rules move the agency in a new direction and begin to ease that burden by strengthening the patient-doctor relationship, empowering patients to realize the value of their care over volume of tests, and encouraging innovation and competition within the American healthcare system," she said.
But while physicians should enjoy some added flexibility for their practices' use of IT, hospitals struggling with meaningful use would also enjoy some relief, said Tom Nickels, executive vice president, American Hospital Association.
"While we applaud CMS for providing much-needed relief from unrealistic and unfunded mandates for EHR capabilities for clinicians, we are disappointed the agency has yet to provide similar relief for hospitals," he said in a statement. "We also urge CMS to provide additional avenues for clinicians to earn incentives for partnering with hospitals to provide better quality, more efficient care through advanced alternative payment models."
More support for telehealth, delay in appropriate-use criteria
Two areas AHA did find to like in the QPP rule and its accompanying 2018 Physician Fee Schedule were new payment options for telemedicine and a delay until 2020 for the requirement that physicians consult with software that tells them whether the imaging tests they order are appropriate and grounded in evidence.
"AHA is pleased that CMS implemented a further delay in implementation, until Jan. 1, 2020, of appropriate use criteria for advanced diagnostic imaging to allow providers sufficient time to understand and implement the program’s requirements," said Nickels.
"We are also supportive of the agency’s policies to make payment for new telehealth services, although we urge a more expansive approach toward telehealth coverage," he said.
CMS plans to increase access to Medicare telehealth services – especially for patients in rural or underserved areas – by paying for more such consults and making it easier for providers to bill for them.
The QPP Final Rule adds a series of new billing codes that reimburse virtual visits for risk assessments and care planning under CMS' chronic care management program.
The American Medical Group Association was another of many organizations who thought the change was overdue.
"Telehealth is a tool that benefits both providers and patients, and it’s a becoming an increasingly effective way to enhance the patient experience," said Jerry Penso, MD, AMGA's President and CEO. "Consultations, remote patient monitoring, and patient self-management all are aided through telehealth."
The MACRA rule will also enable greater use of remote patient monitoring tools and encourage physicians to do more with patient-generated health data.
"We believe that the use of digital technologies that provide either one-way or two-way data between MIPS eligible clinicians and patients is valuable, including for the purposes of promoting patient self-management, enabling remote monitoring, and detecting early indicators of treatment failure," said CMS officials.
"We believe MIPS eligible clinicians will use health IT including providing patients access to health information and educational resources as well as incorporating PGHD for this activity to include standardized data capture and incorporating patient-generated health data."
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