The Centers for Medicare and Medicaid Services is quickly moving to alternative payment models, but for those to succeed, it also must streamline meaningful use and quality reporting programs, contends the College of Healthcare Information Management Executives.
In a November 17 letter to CMS, CHIME recommends getting rid of the current pass/fail approach for Meaningful Use, instead moving to a 75 percent score to qualify for incentive payments. Also, CHIME says CMS needs to eliminate duplicative and burdensome reporting requirements as the agency looks to implement the MU portion of the new Merit-based Incentive Payment System (MIPS).
“CHIME strongly supports creating a pathway for MU whereby physicians are moved to a more flexible regulatory model and away from a ‘pass/fail’ construct. The same pathway must also be created for hospitals,” states the letter. “Additionally, the complexities associated with quality reporting should be reduced to bring the value intended under new models of care.”
CHIME’s letter is in response to a CMS request for information from industry stakeholders regarding implementation of MIPS and alternative payment models. “While we appreciate CMS is considering how MIPS could address the pass/fail methodology beginning in 2019 for physicians, we believe CMS should address the ‘all-or-nothing’ construct immediately for physicians and hospitals alike,” the group argues.
CHIME urges CMS to create parity for hospitals and to remove the pass/fail construct for all providers thereby bringing eligible professionals and hospitals under a single set of MU requirements. “We strongly support the agency’s consideration of removing the pass/fail construct for EPs, however, leaving it in place for hospitals will introduce a level of complexity that will be very difficult for providers and CMS to manage,” CHIME states. “This is especially important as payment models evolve to support greater coordination between hospitals and physician offices. Having a different set of standards for different providers could jeopardize attempts to connect organizations under ACO or bundled payment models.”
The organization does not support the existing “all-or-nothing” scoring methodology that requires 100 percent achievement of all MU requirements. Instead, CHIME believes that the threshold for provider success in meeting the program’s measures should be those who meet 75 percent or more of the requirements.
In addition, CHIME encourages CMS to reduce the reporting burden for providers by eliminating redundant measures and data collection requirements, as well as providing access to real-time and actionable data which the group believes will be critical for success under MIPS.
“Since the future of value-based reimbursement is contingent upon the ability to measure performance and outcomes, we believe a unified strategy for capturing and communicating quality in healthcare is needed,” states the letter. “Currently, providers are required to report clinical quality measures (CQMs) to several public and private entities. Many CHIME members submit more than 20 reports across federal, state and private sector programs for various CQMs each month. Hours of work and expertise are required to comply with these reporting demands and such burdens are exacerbated by a lack of technical harmonization. In other words, even when the same CQMs are used among different programs, they tend to require different technical specifications.”
Making matters worse, CHIME points out that its members have found that while electronic health record systems are able to automatically produce CQM reports, data is sometimes inaccurate and largely incomparable across different providers.
“This is due in part to what EHRs are certified to do and what CMS submission requires,” the letter asserts. “CHIME does not believe that generation of accurate and complete CQMs is possible with current EHR technology.”
At the same time, data created, maintained, and transmitted using EHRs will be used to ensure correct value-based payments, according to CHIME. Consequently, the group concludes CMS must ensure that data collected from providers and provided for new payment models is timely, accurate, complete, and integrated and shared across models as appropriate.
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