Small, rural practices participating in MIPS at EHR disadvantage
The health IT challenges experienced by small and rural physician practices in Medicare’s past payment incentive programs will continue to dog them under the new Merit-based Incentive Payment System.
That’s the assessment of the Government Accountability Office based on interviews they conducted with 23 healthcare stakeholders, including small and rural practices, physician associations and officials from the Centers for Medicare and Medicaid Services.
“Stakeholders told us that having an EHR system may be needed to successfully participate in MIPS, and as a result, many of the technological challenges of maintaining and operating an EHR system may continue under MIPS, especially for small practices,” states a GAO audit released this week.
Under the Advancing Care Information (ACI) performance category, MIPS includes measures that support clinical effectiveness, information security and patient safety, patient engagement, as well as health information exchange. However, faced with EHR challenges, small and rural practices will have an uphill struggle to meet those requirements, according to auditors.
“EHR systems can play a role in everything from coordinating care among providers to population health management (i.e., taking actions to improve the health outcomes of a certain population),” the GAO notes. “Stakeholders reported that the challenges for practices in selecting an EHR system that is best suited to meet their reporting needs, maintaining an EHR system and obtaining support from vendors may be magnified for small and rural practices.”
To participate in MIPS, practices of all sizes need to make an upfront financial investment in technology, such as purchasing an EHR system and staffing, stakeholders told GAO. While practices of all sizes can struggle with the task of selecting a functional EHR system, auditors say small and rural practices tend to have fewer resources or less ability to leverage or share costs among a number of providers.
In addition, they find that these practices have difficulties purchasing EHRs that match their needs and with the day-to-day operation and maintenance of the systems.
“Some stakeholders told us that small and rural practices may have limited financial resources and thus purchase less expensive EHR systems that may not meet their functionality needs,” states the report. “Stakeholders told us that purchasing an EHR system is a major financial investment and that selecting an EHR system that does not meet a practice’s needs can create challenges for completing certain activities required for legacy programs and MIPS, such as measuring quality, sending summaries of care and accessing data in real time.”
Further, GAO reports that the differences among EHR systems can create challenges for small and rural practices when an EHR is unable to submit data to CMS or exchange information with another provider’s system.
“A few stakeholders also told us that small and rural practices may not be able to perform needed EHR maintenance tasks,” according to auditors. “For example, some stakeholders said that EHR servers and security systems require staff attention, which may be challenging in smaller practices with fewer support staff.”
As a result of having fewer staff, GAO observes that small and rural practices rely more heavily on EHR vendors for support than other practices. Nonetheless, stakeholders told auditors that the vendors may be less willing or unable to fully provide the support the practices need, given that large practices generate more revenue for them and are a bigger priority. Making matters worse, because small and rural practices tend to have fewer financial resources, paying for EHR vendor support may affect them disproportionately, the report finds.
To help address some of the challenges facing small and rural practices participating in MIPS, CMS has indicated that it may alter certain program requirements. In response to the GAO’s report, agency officials told auditors that instead of requiring providers to meet a number ACI category requirements, CMS will review whether providers make progress on a few key uses of EHR technology, such as engaging with patients via EHR systems and exchanging health information with other providers.
When it comes to increasing oversight of vendors and standardization of EHR products, CMS officials told GAO that to address this issue, the agency allows providers to use an older version of EHR certified technology in MIPS year 2 and to apply for hardship exceptions.
“These efforts may help providers that have difficulty selecting or incorporating an EHR system into their practice,” the report concludes. “CMS officials also said that additional vendor oversight activities may be performed by HHS’s Office of the National Coordinator for Health Information Technology, which has primary responsibility for certifying technology used by EHR vendors.”