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CMS Acting Administrator Provides EHR Incentive Programs update

Recently, Andy Slavitt, Acting Administrator, Centers for Medicare and Medicaid Services (CMS) and Dr. Karen DeSalvo, the Acting Assistant Secretary for Health in the U.S. Department of Health and Human Services (HHS) published an important update.  In their post titled EHR Incentive Programs: Where We Go Next there were two important takeaways for health care professionals:

  1. MACRA is under development and is where we are going next.
  2. MACRA is on the horizon, but do not abandon Meaningful Use â€" just yet.

According to Mr. Slavitt and Dr. DeSalvo “The EHR Incentive Programs were designed in the initial years to encourage the adoption of new technology and measure the benefits for patients.”  They go on to say “while it helped us make progress, it has also created real concerns about placing too much of a burden on physicians and pulling their time away from caring for patients.”

Transitioning From Measuring Clicks to Focusing on Care 

According to the update, Congress advanced this goal through the passage of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which considers quality, cost, and clinical practice improvement activities in calculating how Medicare physician payments are determined.  Further, MACRA will continue to require physicians to be measured on their meaningful use of certified EHR technology for purposes of determining their Medicare payments.

Where are we going next?

While MACRA details will be shared and comments will be invited for proposed regulations, according to Mr. Slavitt and Dr. DeSalvo:

“All of this work will be guided by several critical principles:

  1. Rewarding providers for the outcomes technology helps them achieve with their patients.
  2. Allowing providers the flexibility to customize health IT to their individual practice needs. Technology must be user-centered and support physicians.
  3. Leveling the technology playing field to promote innovation, including for start-ups and new entrants, by unlocking electronic health information through open APIs â€" technology tools that underpin many consumer applications.  This way, new apps, analytic tools and plug-ins can be easily connected to so that data can be securely accessed and directed where and when it is needed in order to support patient care.
  4. Prioritizing interoperability by implementing federally recognized, national interoperability standards and focusing on real-world uses of technology, like ensuring continuity of care during referrals or finding ways for patients to engage in their own care. We will not tolerate business models that prevent or inhibit the data from flowing around the needs of the patient.”

Finally, and perhaps most importantly, According to the update, for Doctors and Hospitals it is important to keep in mind the following:

  1. “The current law requires that we continue to measure the meaningful use of ONC Certified Health Information Technology under the existing set of standards. While MACRA provides an opportunity to adjust payment incentives associated with EHR incentives in concert with the principles we outlined here, it does not eliminate it, nor will it instantly eliminate all the tensions of the current system. But we will continue to listen and learn and make improvements based on what happens on the front line.
  2. The MACRA legislation only addresses Medicare physician and clinician payment adjustments. The EHR incentive programs for Medicaid and Medicare hospitals have a different set of statutory requirements. We will continue to explore ways to align with principles we outlined above as much as possible for hospitals and the Medicaid program.
  3. The approach to meaningful use under MACRA won’t happen overnight. Our goal in communicating our principles now is to give everyone time to plan for what’s next and to continue to give us input. We encourage you to look for the MACRA regulations this year; in the meantime, our existing regulations â€" including meaningful use Stage 3 â€" are still in effect.
  4. In December, Congress gave us new authority to streamline the process for granting hardship exception’s under meaningful use. This will allow groups of health care providers to apply for a hardship exception instead of each doctor applying individually. This should make the process much simpler for physicians and their practice managers in the future. We will be releasing guidance on this new process soon.”

We will continue to monitor Meaningful Use and MACRA very closely.  For now, we encourage you to continue your compliance efforts while we await further announcements this spring.  If you have any questions please do not hesitate to contact one of our professional consultants.

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