Meaningful Use: Extreme Makeover Edition

What MACRA means to CMS’s EHR incentive program

Among its many objectives, the Medicare Access & CHIP Reauthorization Act (MACRA) aims to simplify the process health care providers have had to endure when reporting data and other information to the federal government. The Physician Quality Reporting System (PQRS), Value-Based Modifier, and Meaningful Use (MU) are among the programs MACRA will consolidate.

But the Centers for Medicare & Medicaid Services (CMS) continues to push ahead with MU as a standalone program separate from MACRA. In fact, MU’s third stage is slated to begin next year. So what gives?

Let’s take a moment to sort it all out.

Some unlucky timing is partly to blame for the confusion. The Medicare & Medicaid EHR Incentive Program (MU) was created under the American Recovery and Reinvestment Act of 2009 (ARRA). The first two MU phases went into effect in 2011 and 2014, respectively. In 2015, CMS released its plans for MU’s third phase, but Congress passed MACRA shortly after, and much of MU was supplanted by the new law.

MACRA has taken a big bite out of MU, but hasn’t swallowed it whole.

To understand how the new arrangement will work, it’s helpful to split MU into two buckets – one that addresses eligible providers (EPs) in individual and small group practices, and another that addresses hospitals. The individual and small group EPs will see their MU programs give way to MACRA beginning in 2017, while hospitals will soldier on under the regular MU program.

Here’s a further breakdown. MACRA’s Quality Payment Program (QPP) includes two main tracks: the Merit-Based Incentive Payment System (MIPS) and the Alternative Payment Models (APMs). Most individual and small group EPs will submit their performance data to MIPS. CMS will adjust each EP’s reimbursement higher or lower depending on how well each scores on MIPs measures. Some individual and small group EPs may join an APM, such as a patient-centered medical home (PCMH) or an accountable care organization (ACOs), but most will be MIPS “customers.” For them, the information currently reported as part of MU, such as EHR and health information exchange (HIE) data, will move to the Advancing Care Information (ACI) category within MIPS. The ACI category accounts for 25% of an EP’s annual MIPS score.  Hospitals, however, are not part of MIPS, and will continue down the MU path.

Which brings us to MU stage 3. MACRA’s 2017 start effectively means that individual and small group EPs won’t have to attest to stage 3; however, hospitals will. They can voluntarily begin attestation in 2017, and all must start by 2018. Stage 3 focuses on advanced EHR use, interoperability, and more HIE. Specifically, stage 3 calls for:

  • Provider to provider exchange through the transmission of an electronic summary of care document;
  • Provider to patient exchange through the provision of electronic access to view, download, or transmit health information; and
  • Provider to public health agency exchange through the public health reporting objectives.

MACRA may have muddied the MU waters, but hasn’t drained them, or at least not the spirit of MU. The EHR incentive program remains, just under a different name.

As always, stay tuned.

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