The Centers for Medicare & Medicaid Services (CMS) recently announced it would overhaul and rename its EHR incentive programs, putting a greater emphasis on the interoperability of systems.
The change is welcomed, according to experts, as they say it is time to move past incentivizing physicians to use digital recordkeeping and promote better record sharing across healthcare.
Promoting Interoperability
The new Promoting Interoperability (PI) program states that by 2019, hospitals need to have a patient's electronic health records available the same day the patient is discharged. This will enable them to demonstrate meaningful use and qualify for higher Medicare reimbursement.
It’s also worth noting that, for physicians, the Advancing Care portion of the Merit-based Incentive Payment System (MIPS) will be renamed as the “promoting interoperability” performance category.
“This change in direction is in direct response to the fragmentation of the delivery of care that is caused from having disparate [EHR] platforms in our healthcare delivery venues,” says David Quirke, senior vice president of information services and chief information officer for UPMC Pinnacle. “We, as healthcare delivery entities, were incentivized to implement EHR in order to improve the delivery of care and improve efficiencies and safety. The problem with this is that we were not incentivized to do it in an open or standard platform.”
He adds that incentivizing interoperability will lead to increased collaboration, sharing of information, and reduction of “inappropriate” utilization and redundancy.
“The question will be if both the healthcare networks and the payers will be incentivized in a way that will promote the collaboration and efficiency to drive better care and lower costs,” Quirke said via email.
Likewise, John Halamka, chief information officer of the Beth Israel Deaconess Medical Center and chief information officer and dean for Technology at Harvard Medical School, says he believes the change is exactly what’s needed.
“The Meaningful Use program has run its course and achieved its goals,” he said via email. “Now we need to focus on a small number of remaining challenges, especially innovations in sharing data among patients, providers, and payers. It’s very positive.”
Four New Objectives
There are four new objectives built around PI:
• Public Health/Clinical Data Exchange — Public health information to help track and predict disease and behavior trends in a given area.
• Provider/Patient Exchange — PI encourages patients to actively participate in their own healthcare, allowing them to collect and track their own healthcare information.
• Information Exchange — PI combines the existing referral program with clinical information reconciliation programs.
• Electronic Prescriptions — There are two new measures in the PI program—Query of Prescription Drug Monitoring Program and the Verify Opioid Treatment Agreement— in the EHR incentive program. Both are designed to help reduce “doctor shopping” and opioid drug abuse.
The overall goal is to improve patient access to health information and to improve overall care by incentivizing communication among healthcare professionals.
Peter Basch, senior director for IT quality and safety, research, and national health IT policy at MedStar Health says he’s “cautiously optimistic” about the new focus.
“I do know and appreciate that both CMS and ONC are serious about and committed to decreasing regulatory burden on clinicians,” he said via email. If you interpret the HITECH and 21st Century Cures Acts as including a legislative imperative to further interoperability and believe that most everything else is outside that legislative mandate, he says, then relabeling Meaningful Use as Promoting Interoperability makes sense.
“Words do matter,” Basch says, “particularly if those words make sense to the reader, and if those words accurately describe what’s inside the program. I have not read the [proposed rule] in detail, but a cursory read suggests that that is indeed what CMS is doing.”
Scoring Changes
Currently, the EHR incentive programs are based on a pass/fail threshold score. This will phase out in favor of a performance-based score that will change based on the hospital's overall PI score. Hospitals that score less than 50 out of 100 will not qualify for bonus payments.
The program does reduce the required number of scoring measures from 16 down to six. A hospital that introduces two measures dedicated to interoperability would score 40 points.
A single measure that allows patients to access their own electronic health records is worth an additional 40 points, meaning that three measures can give a hospital 80 points out of the maximum 100 — more than enough to qualify for PI incentives.
The scoring, like the current MIPS program, does require an annual security risk audit for each participating hospital. The PI score is automatically zero if there's no audit, regardless of any measures implemented during the previous year.
It might seem like a big change, but the program is primarily reiterating the same rules established during Stage 2 of the EHR incentives program in 2015.
This change currently only affects hospitals that participate in the EHR incentives programs, but CMS is also asking for feedback from participating hospitals as to whether or not the change should be expanded to include private practices and other eligible healthcare professionals.
While there hasn’t been an official announcement, it seems to indicate that similar changes may be in the pipeline for private physicians in 2019 and beyond.
