In setting the final rule for the Medicare Access and CHIP Reauthorization Act, the Centers for Medicare and Medicaid Services made a determined effort to simplify requirements that will revamp physician reimbursement to reflect quality and efficiency of care.
For instance, physicians not ready in 2017 to report on quality measures for a full year need only to report at least one quality measure to avoid a payment penalty, which was one example of cutting out unnecessary bureaucratic hoops.
“The aim is to have a mixed approach of more incentives and opportunities for physicians to use their EHR technology and be compensated for using it, and reduce make-work process requirements like sending ‘10 percent of this’ or ‘check the box on 13 percent of this,’ “ says Micky Tripathi, president and CEO at the Massachusetts eHealth Collaborative.
Rather than have prescribed measures, CMS has realized that physicians should be using the EHR to exchange data with other clinicians when it makes sense to exchange data, and not being forced to use interoperability just for the sake of using it. For instance, Stage 3 of the EHR meaningful use program required physicians to use Direct Protocol secure messaging with five percent of patients; now, the number is one patient. As physicians become more familiar with interoperability they will use it more often when appropriate, the agency believes.
The reality, Tripathi says, is that any doctor participating in a value-based care program is going to have to adopt interoperability so records can be exchanged with other clinicians, as well as patients, as value-based care compels patient engagement.
“If you aren’t doing patient engagements and sending alerts to patients, you are not going to succeed with value-based care anyway,” he adds. Tripathi actually got a note from his physician recently because he hasn’t had a check-up in a year. And this is the patient-facing work that physicians will need to do regularly.
Further, provider-to-provider interoperability will be just as important. “You can’t do well with a risk cohort without working more closely with other providers, particularly primary care physicians and specialists,” Tripathi counsels. “You need basic interoperability and, over time, automate more.”
Fortunately, two emerging national health information exchange networks—Carequality and Commonwell—are now available to ease the sharing of data, he adds. “Once you have the network in place people start using it because it’s available.”
In the MACRA rule, CMS also finalized requirements that providers attest they have acted in good faith to implement and use EHRs in a manner that supports interoperability and the appropriate exchange of electronic health information. CMS spends considerable time in the rule addressing the issue of “information blocking,” in which providers purposefully withhold information that could and should be disseminated to other providers or patients.
Such incidents do occur, but they often are a recognition of information barriers that don’t necessarily equate with “blocking,” Tripathi believes. For instance, there may be an independent physician association in a community that exchanges data using Continuity of Care Documents pulled from its EHR. But there may be another EHR vendor in town that has a different way of structuring its CCDs, so data exchange is hindered until the vendors reach a resolution.
In another example, the Commonwell HIE and a local HIE may have different consent forms, which could compel a provider to pick one vendor over the other to get their data exchanged. It could be said that this is information blocking, Tripathi notes, but he doesn’t see it as overtly intentional.
Overall, Tripathi sees true information blocking as overblown and “incredibly rare,” and it’s not in his Top 10 list of interoperability concerns. But he acknowledges that when blocking becomes part of the discussion, it makes everyone a little more diligent in ensuring they are not doing something that could be blocking, even if unintentional.
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