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.

Shaping the Substance of MACRA: EHRA Comments Set Foundations for Success

Few, if any, health care payment and delivery initiatives underway promise to have as much impact on the nation’s shift from volume to value-based reimbursements, holistic clinical delivery, and overall system sustainability as the Medicare Access and CHIP Reauthorization Act (MACRA).

By establishing distinct and relatively complex delivery and payment tracks – the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs) – programmatic vigilance and collaboration is needed by all healthcare stakeholders.

And with current and future healthcare information technology solutions a critical part of the equation – building upon similar public and private payer programs such as patient-centered medical home (PCMH) and accountable care organization (ACO) structures – the Electronic Health Record Association (EHRA) submitted detailed comments November 17 to the Centers for Medicare & Medicaid Services (CMS) in response to the agency’s MACRA request for information (RFI).

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EHRA’s Advice to ONC on Information Blocking

In October, we provided comments to ONC on its April 2015 “Report on Health Information Blocking”, in the spirit of collaborating to establish an environment where the right data can flow to the right party at the right time using a set of agreed-upon standards.  While some press coverage characterized our comments as negative (“…Prove It”), we in fact attempted to provide balanced feedback, recognizing that the first challenge is to come up with a definition of “information blocking” that everyone agrees on.

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When Health IT is Personal

Leigh Burchell, EHRA Chair and VP for Policy and Government Affairs for Allscripts, recently wrote about her own experience with health IT and how that has broadened her perspectives as both vendor and patient.  An excerpt:

“Recently…health IT has been personalized for me in an entirely different way, and I understand it from a new perspective. Thankfully, unlike many people who speak about the challenges they’re still encountering, my experience has largely been positive since becoming a breast cancer patient.”

Read the full post, “When health IT became personal: My journey with breast cancer” on the Allscripts blog.

 

 

 

Privacy and Security, and Building Patient Trust

Earlier this year, ONC published an updated “Guide to Privacy and Security of Electronic Health Information” to help healthcare providers and ambulatory practices understand existing federal law on protected health information (PHI).  It provides guidance on how providers can use certified electronic medical record technology (CEHRT) to provide secure communications with their patients and, via secure and interoperable health IT, share patient data with other care providers.

There is a great deal of practical information provided in this guide that helps explain who is and who is not a business associate (BA), per the HIPAA regulations.   It also provides clear guidance as to when it is permissible to disclose PHI, when patient authorizations are required, and how to provide patient access to their health information.  In addition, there is a useful section on general cybersecurity explaining the threat of cyber-attacks, the use of mobile devices, and email and texting among providers and their patients.

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