EHR Association Responds to CMS’ MACRA/MIPS Proposals

Recognizing the complexity of the MACRA legislation, the Association expressed appreciation that CMS considered a variety of comments from a diverse set of stakeholders in developing the proposed rule.  In their detailed comments, they emphasize that some of the complexities in the proposed rule will lead to many significant changes and implications for eligible clinicians.  EHRA urged CMS to take every possible step to dramatically simplify requirements in the final rule and to develop provider-focused communications to reduce complexity.

Briefing Congress on the Importance of Interoperability

On June 7, 2016, the EHR Association sponsored a briefing for Congressional staff engaged in crafting proposed legislation that addresses interoperability.  EHRA member company, Allscripts, invited their client Stephen Nuckolls, CEO of Coastal Carolina Health Care (New Bern, North Carolina, U.S.A.), to participate as a panelist, along with four other healthcare provider organization executives. Their blog post shares some of his comments at the briefing, which covered successes and areas for improvement with health information technology.

MACRA and Alternative Payment Models – What You Need to Know

When it comes to alternative payment models (APMs), organizations often ask “is it better to be a Medicare Shared Savings Program (MSSP) Track 1 Accountable Care Organization (ACO) or a Patient-Centered Medical Home (PCMH)?”

Typically, the answer depends on a few factors:  organizational goals, level of readiness to adopt new delivery models, and the mix of public and private payer incentive programs.

Going forward, however, the newest factor that organizations must consider is how they want to be scored under the incentive programs created by the Medicare Access and CHIP Reauthorization Act (MACRA).  As the Centers for Medicare and Medicaid Services (CMS) prepares to release the proposed rule for MACRA, the agency has made it clear that not all organizations participating in APMs will be considered “eligible” for purposes of the law’s APM incentive program.  The statute requires that eligible APMs, those which qualify for the APM bonus payment, have the following characteristics:

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New Certification Criteria for APMs–Is This the Right Approach?

CMS and ONC are considering tying the new Alternative Payment Models (APM) being designed per the MACRA legislation to prescriptive criteria for “use” of certified EHR technology, and considering development of new certification criteria specifically created for APMs.  In doing so, do they risk going beyond congressional intent for the APM program and stifling innovation by imposing requirements on health IT beyond what is sought in the market, perhaps pursuing a strategy that may not be the best way to accomplish their end-goals – the rapid shift to value-based reimbursement and more integrated care?

Read “Health IT, Value-Based Payment, and Innovation: Let’s Get it Right” by Mark Segal, PhD (EHRA Chair Emeritus and Vice President of Government and Industry Affairs for GE Healthcare IT) on the GE blog page.

EHRA Responds to ONC’s Interoperability Roadmap

After many conference calls, and lots of “on the job training” using Google Docs to manage the edits of many contributors, we were pleased to submit our response to ONC’s Interoperability Roadmap. . . just in time to start working on the interoperability aspects of the proposed rule for Stage 3 of the EHR Incentive Program . . .and to get ready for HIMSS15!

Overall, we’re positive about the framework the draft Roadmap is starting to put in place, its identified principles, and the pragmatic review of well-established and emerging interoperability standards and technologies. We did express some concern that ONC seems to view the many active, and increasingly successful, interoperability initiatives as a problem to be solved rather than work to inform go-forward strategies with valuable experiences to be built upon. In doing so, we provided some positive suggestions on how to approach interoperability governance in ways that rely on and leverage private sector efforts in the context of an effective public/private partnership.

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Meaningful Use Stage 3 Is Here and We’re Ready to Respond

We recently saw the release of the 732 pages of the CMS Stage 3 Meaningful Use Proposed Rule and ONC’s Proposed Rule on 2015 Edition Certification. The EHRA Meaningful Use and Certification Workgroups have been gearing up to review and comment on these rules for a while so we have already started looking at the eight proposed objectives and 68 proposed certification criteria.

The scope of what is proposed for certification in this NPRM goes beyond what is proposed to be part of the Meaningful Use program, so other EHRA workgroups are also focused on reviewing the material pertinent to their areas of expertise.  We’re committed to detailed review and developing EHRA’s responses for submission by the May 29th deadline.

Our work depends on the deep expertise of EHRA members and their users!  We strongly encourage your involvement. You’ll have the opportunity to learn from the insights of industry experts in our educational calls, discussions, and consensus based positioning. Participating in EHRA’s work will give you an advantage when working on your own company’s feedback.  Also, you’ll be well positioned to engage your users in what the new proposals might mean for their practices and to encourage them to participate in the public comment process.

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