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Certified Health IT Infrastructure Requirements of MACRA Rule

The latest MACRA final rule outlines CEHRT requirements for the Quality Payment Program with the ultimate goal of improving patient care through technology.

By Elizabeth O'Dowd

- The Department of Health & Human Services (HHS) announced the publishing of a final rule to implement provisions of to the Medicare Access and CHIP Reauthorization Act (MACRA), introducing a new program called the Quality Payment Program.

MACRA technology requirements

The Quality Payment Program progresses Medicare’s value-based care initiative and rewards the delivery of high-quality patient care through the Merit-based Incentive Payment System (MIPS) or Advanced Alternative Payment Models (Advanced APMs) for eligible Medicare clinicians or groups.

According to a Centers for Medicare & Medicaid Services (CMS) executive summary, “this final rule establishes incentives for participation in certain Alternative Payment Models (APMs) and includes the criteria for use by the Physician-Focused Payment Model Technical Advisory Committee (PTAC) in making comments and recommendations on physician focused payment models (PFPMs).”

The latest update to the Quality Payment Program (and MACRA implementation) seeks to improve clinician payments and develop new policies to drive participation in value-based care. These improvements rely heavily on EHR and health IT infrastructure technology and rewards participants in MIPS and Advanced APMs for embracing advanced technology.

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  • A fact sheet released by the Office of the National Coordinator for Health Information Technology (ONC) states that the advancing care information performance category under MIPS will “modernize, streamline, and replace the Medicare EHR Incentive Program for eligible professionals.”

    The fact sheet indicates that the Quality Payment Program requires the use of certified EHR technology (CEHRT) and health IT systems to exchange information among clinicians to reach the ultimate goal of improving the quality of patient care.  

    ONC published health IT certification criteria that serves as the standard for the Quality Payment Program. The criteria was published in 2015 with required implementation in 2018. Whether an organization chooses MIPS or Advances APMs, certified EHR technology is needed to support the secure exchange of information and multiple methods of data submission among healthcare providers.

    To prepare for future technology advancements, HHS has encouraged MIPS eligible clinicians to prepare for the migration to the 2015 Edition CEHRT by 2018. Migrating to the most current version of certified EHR technology is especially important for compatibility and data sharing between healthcare organizations to ensure that EHRs are exchanged correctly with all information present and in the right place.

    The final rule allows MIPS eligible clinicians to submit advancing care information performance category data through qualified registry, EHR, QCDR, documentation and CMS Web Interface submission methods. Because clinicians are submitting and reporting the data, the need for a simple and streamlined approach to data reporting becomes necessary.

    The HHS fact sheet outlines several final rule IT infrastructure goals in the MIPS Advancing Care category:

    • Bridging the information gap across care settings: Create an organization network allowing clinicians to share and obtain information from multiple settings using secure electronic messaging and health information exchange, and incorporating patient generated health data and data from a non-clinical setting.
    • Streamlining reporting and providing flexibility: Build a usable, simple and flexible way for clinicians to succeed by allowing them to select the measures that reflect how technology best suits their day-to-day practice and simplifying reporting.

    The fact sheet also establishes an incentive for organizations to embrace widespread electronic reporting methods in the MIPS Quality category by encouraging:

    • Seamless information exchange through health IT: MIPS eligible clinicians can earn bonus points for using certified EHRs and other health IT to capture, calculate, and submit clinical quality measures using structured data standards and automated data exports.  
    • Flexible options for electronic reporting: Eligible clinicians will have multiple options to electronically submit data to CMS, including leveraging certified EHR technology or qualified clinical data registries, as well as expanding the availability of third parties to automatically calculate and report measures on a provider’s behalf.

    Advanced APMs also offer rewards for clinicians using certified health IT. Organizations need least 50 percent of their clinicians using certified EHR technology to document and communicate clinical care information with patients and other healthcare professionals to qualify for Advanced APM benefits. Organizations that meet Advanced APM qualifications can potentially earn a 5 percent incentive payment.  

    HHS is pushing technology the adoption of more advanced health IT with the Quality Payment Program by providing organizations with incentives to upgrade from legacy EHR technology. Embracing new technology advances the transition to value-based care which continues to improve the quality of patient care. 

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