The path to the new Medicare physician payment system known as the Quality Payment Program (QPP), which began on January 1, is strewn with pitfalls for doctors. Among those are some of the provisions related to health IT, which in various forms is interwoven throughout the program.
Further reading: Why have EHRs failed to deliver their promised efficiency benefits?
Still, the final rule for the Medicare Access and CHIP Reauthorization Act (MACRA), which established the payment reform, softens the transition considerably in comparison to the MACRA proposal released by the Centers for Medicare & Medicaid Services (CMS) last spring, observers say.
Advancing Care Information (ACI), the successor to Meaningful Use, now requires eligible clinicians to meet five measures, down from 11 in the proposed rule. These metrics support goals that include clinical effectiveness, information security, patient safety, patient engagement and health information exchange. Extra credit is available for electronic reporting to public health and clinical data registries or for using certified electronic health records (EHRs) for certain clinical practice improvement activities (see the QPP website at qpp.cms.gov).
However, there are a couple of caveats. For one, the core ACI measures include the exchange of electronic care summaries. Because of the poor state of interoperability between EHRs, physician practices will continue to find it difficult to trade these summaries, notes David Zetter, CHBC, a practice management consultant in Mechanicsburg, Pennsylvania.
Physicians can use Direct secure messaging, based on a standardized internet protocol, to send and receive clinical summaries without interoperability between their EHRs. But to do that, they must use a health information service provider (HISP), and that entity may not be able to communicate with the HISPs used by other practices. Edward Gold, MD, the leader of a 70-doctor group in Emerson, New Jersey, says his practice cannot exchange Direct messages with most other groups in his area because of non-communicating HISPs.
Consequently, he says, health information exchange measures are “the hardest to meet. The way they’ve got it structured, the goals are somewhat unrealistic.”
Michael Munger, MD, a primary care physician in Overland Park, Kansas, agrees that some practices that lack interoperable EHRs may not be able to meet these requirements. He adds, however, that most practices should be able to exchange summaries electronically with enough partners to satisfy the requirement.
Another key challenge is that, starting in 2018, all physicians in the Quality Payment Program—whether they participate through the Merit-based Payment Incentive System (MIPS) or an Advanced Alternative Payment Model (APM)—use EHRs that have been certified to meet standards originally designed for Stage 3 of the Meaningful Use program. In 2017, physicians can continue to use their current EHRs if those have been certified under the previous standards.
But the transition to the new EHRs is expected to be rocky. “Very few vendors have recertified so far,” notes Robert Tennant, a senior policy adviser to the Medical Group Management Association (MGMA). “And if you’re stuck with an EHR that’s not going to be upgraded, you’ve got to rip and replace it.”