Incentivizing physicians to use electronic health records appears to be taking a new turn, under the provisions of the proposed Medicare Access and CHIP Reauthorization Act of 2015.
The proposed rules carry the intent of simplifying how physician practices can qualify for payments for using information technology, blending the incentives into the larger movement to reframe reimbursement for physicians.
Under the Merit-Based Incentive Payment System, the use of healthcare information technology is one of four components affecting payment. The others are quality (affecting 50 percent of payment), clinical practice improvement activities (15 percent) and cost (10 percent).
According to the Centers for Medicare and Medicaid Services, the new proposal offers benefits in four areas that would make it easier for physicians to benefit from implementing electronic health records systems. In contrast to the meaningful use incentive system, physicians have more flexibility with the new system, and it better aligns with other Medicare reporting programs.
Physicians still would be required to use certified EHR technology, and would focus the use of it in providing care to patients, while encouraging interoperability and information exchange.
Not all complexity is gone, however. Proposed rules lay out a complex approach to scoring, setting a target of 100 points for physicians to receive full credit toward getting maximum reimbursement for information technology. CMS notes that physicians could follow “multiple paths” to achieve target scores.
Scoring involves a base score, performance score and a public health registry “bonus point.”
Base score. This accounts for 50 points of the total Advancing Care Information category score. To receive the base score, physicians and other clinicians must provide the numerator and denominator or answer yes or no for each objective and measure. CMS proposes six objectives for reporting toward the base score. They are:
- Protect patient health information. Perform a security risk analysis.
- Electronic prescribing. Perform electronic prescribing.
- Patient electronic access. Provide patient access and patient-specific education.
- Coordination of care through patient engagement. Enable view/download and transmit; provide secure messaging, and be able to incorporate patient-generated health data.
- Health information exchange. Exchange information with other physicians or clinicians; exchange information with patients; achieve clinical information reconciliation.
- Public health and clinical data registry reporting. Reporting to immunization registries (required) or optional reporting to syndromic surveillance, electronic case reporting, public health registries or clinical data registries.
Performance score. This accounts for as much as 80 points towatd the total; clinicians select the measures that best fit their practice. These include:
- Patient electronic access.
- Coordination of care through patient engagement.
- Health information exchange.
Public Health Registry bonus point. Immunization registry reporting is required under the proposed approach; physicians that report beyond the immunization category can qualify for a bonus point.
Under the proposed rules, physicians can combine the three scores and, if the total exceeds 100, they will receive the full 25 points in the Advancing Care Information category, toward their MIPS score.
The rules suggest that the performance period for the first information portion is calendar year 2017.
As with any proposed rule, CMS is seeking comments on the approach and components it proposes, so organizations and individuals can weigh in with their perspective of the scoring approach and the components that comprise it. As a result, the structure of the scoring system could be substantially different in its final form.
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