eMeasures News You Can Use – MU, MACRA RFI, Interoperability Roadmap and More

eMeasures News You Can Use – MU, MACRA RFI, Interoperability Roadmap and More

Introduction

Encore’s eMeasure Research and Review Board (eMRB) provides direction and common perspective on how eMeasures are applied in a value-based reimbursement environment.  To help keep others informed and share our knowledge of recent activities relevant to eMeasures, eMRB provides this high level monthly recap.

In the update below, covering activities for the month of September, we discuss the legislative activities in Washington, D.C., including status of the Meaningful Use Final Rules, a review of the MACRA RFI, and some links to ICD-10 sources.  We provide commentary on ONC’s Draft Interoperability Roadmap and cover our question of the month on value-based programs.  We also include a link to the August updates in case you missed them.

Reading time: 10 minutes

Watch List Update

We anticipate the MU final rules in early October…

At time of this writing, the Meaningful Use final rules are pending release by the Office of Management and Budget (OMB).  When published, eMRB will provide a detailed analysis of the final rules. In the meantime…

We anticipate the Modifications to Meaningful Use 2015-2017 final rule will provide direction on what to report for Stage 2 in 2015; and what the implications will be for moving to Meaningful Use Stage 3 and the 2015 Edition of the Health IT certification criteria.

What are industry concerns?  Industry groups and members of the Senate and House of Representatives expressed an urgency to the Health and Human Services Secretary, Silvia Burwell, to publish the Stage 2 revisions and put a hold on Meaningful Use Stage 3.  Here’s a link to the letter signed by the 116 members of Congress, and the CHIME press release calling for a delay in the Meaningful Use Stage 3 rulemaking.

On the physician side of things, CMS has sent out an RFI requesting information on the details for implementing its MACRA legislation

The MACRA legislation –Medicare Access and CHIP (Children’s Health Insurance Program) Reauthorization Act of 2015– was signed into law in April 2015.  It repealed the Sustainable Growth Rate (SGR) formula for determining Medicare payments for physician services, brings in a new and consolidated performance based program called MIPS (Merit-based Incentive Payment System), and provides incentives for participation in APMs (Alternative Payment Models).  The RFI is looking for public and stakeholder input to inform implementation of the MACRA provisions.

So what are some impacts to providers?  MACRA impacts physicians, group practices and accountable care organizations (ACOs).  It sunsets the current payment adjustments associated with the Physician Quality Reporting System, Value-based Payment Modifier, and the Medicare EHR Incentive Program for eligible professionals (EPs) beginning with payments for items and services furnished on or after January 1, 2019.  The RFI is an opportunity to weigh in on the details.  The CMS questions are focused on data accuracy as experience has shown data quality is related to the reporting mechanism such as a qualified clinical data registry (QCDR) or certified EHR technology.  CMS is asking for comments on what should be required in terms of testing, standards, and thresholds for data integrity; and whether or not the reporting should be via attestation or electronically transmitted.

Reference the October 6, 2015 HIT Joint Committee presentation for further details about the RFI and the MACRA legislation, including a great timeline graphic on slide 5.

Would you like to read more? Here’s a link to the RFI:  RFI Regarding Implementation of the MIPS, Promotion of APMs, and Incentive Payments for Participation in Eligible Alternative Payment Models; the Oct. 6, 2015 HIT Joint Committee presentation – MACRA Overview and RFI; the Health Affairs Blog, September 28, 2015; MACRA: New Opportunities For Medicare Providers Through Innovative Payment Systems; and MACRA, Medicare Access and CHIP Reauthorization Act of 2015

ICD-10 coding is now official

If you need access to any sources, you can start by visiting this CMS Blog, which will lead you to the Road to 10.  Or you may like this Infographic covering the Top 8 zaniest ICD-10 codes, such as ICD-10 code V97.33XD noted in the list.

Questions on Value-Based Programs

This month we cover the case threshold exemption policy as it relates to eCQMs for the IQR program.

Question:

• Is a hospital required to electronically submit the 4 required eCQMs in 2016 if the populations for the measures don’t meet the case exemption thresholds?

eMRB’s response (backed by an inquiry to QualityNet):

• The answer is, Yes.  If a hospital is a participant in the Hospital IQR program, the electronic submission of 4 eCQMs is a reporting requirement for FY 2016 whether or not a case threshold exemption is invoked or a zero denominator is declared for one or more eCQMs.

And how does an organization declare a zero denominator when electronically submitting the CQMs?  Turns out, it is a manual process.

• For zero denominator declarations, any eCQM that does not have any patients that fall into the measure will be a zero denominator and will have to be indicated in the Denominator Declaration screen of the QualityNet Secure Portal.

Education

In September, we did a briefing of ONC’s Interoperability Roadmap

What is the Nationwide Interoperability Roadmap? The draft roadmap was released in January 2015; the comment period closed in April and an updated roadmap will be released later this year.  It describes the actions and roles of health IT stakeholders to achieve the vision of ONC’s 10-Year Interoperability Concept Paper.  It lays out the plan for what needs to happen, by when, and by whom, to see that electronic health information is available when and where it matters most.

What are the critical elements? It requires standards, motivating the use of those standards through appropriate incentives, and creating a trusted environment for the collecting, sharing and using of electronic health information.

What are the implications for healthcare organizations?

• Ensuring they can send, receive and find the core set of health data (as defined in the Roadmap) across all providers regardless of vendor platform.
• Planning and competencies to address population health management with a focus on data sharing.
• Building a population health infrastructure with the goal of enabling improvement in the health of its population, in addition to addressing the technical challenges of interoperability.
• Ongoing patient engagement challenges.  Patients are a significant component of the roadmap, but if we build it, will they come?  Current statistics of portal usage (and what it took to get to the MU thresholds) indicates not.

Sources: Connecting Health and Care for the Nation A Shared Nationwide Interoperability Roadmap DRAFT Version 1.0; ONC Interoperability Roadmap website; HIT Joint Advisory Committee Presentation, October 6, 2015, Connecting Health and Care for the Nation:  A Shared Nationwide Interoperability Roadmap –  Final Version 1.0

Announcements and Events

If you missed it, below is a link to and description of the eMeasures News You Can Use covering August activities.  It was posted to Encore’s website on September 15, 2015.

eMeasures News You Can Use – IPPS, MU, IOM and More

• In the update, we discuss the August legislative activities in Washington, D.C., including the Fiscal Year (FY) 2016 Inpatient Prospective Payment System (IPPS) Final Rule.  We provided a review of the National Academy of Medicine’s (formerly IOM) Core Metrics Book, highlighted Encore’s latest white paper (Maximizing Legacy Data Migration to a New EHR) and its associated Webinar, and covered a question on value-based programs.

Acronyms

Accountable Care Organizations (ACO); Calendar Year (CY), January – December; Centers for Medicare and Medicaid Services (CMS); Electronic Clinical Quality Measures (eCQMs); Fiscal Year (FY), October – September; Inpatient Prospective Payment System (IPPS); Inpatient Quality Reporting program (IQR); Institute of Medicine (IOM); Medicare Access and CHIP (Children’s Health Insurance Program) Reauthorization Act of 2015 (MACRA); Medicare Shared Savings Program(MSSP); Meaningful Use (MU); Office of Management and Budget (OMB); Physician Quality Reporting System (PQRS); U.S. Department of Health & Human Services (HHS).

To read previous versions of the eMeasures News You Can Use, you can locate them on Encore’s Website under the Press Room.

Points of view and interpretation were relevant at time of authorship; however, they are subject to change over time.

eMRB

Encore’s eMeasure Research and Review Board is made up of Encore’s industry thought leaders and eMeasure experts who are responsible for understanding the current state and future direction of quality and value-based programs for Encore’s business.

eMeasure Research and Review Board
Encore, A Quintiles Company
[email protected]
www.EncoreHealthResources.com