From Measuring "Clicks" to Measuring Performance


"For the times they are a-changin'" says Bob Dylan, and his advice, "then you better start swimmin' or you'll sink like a stone," could easily apply to providers floating in CMS's ebb and flow of reimbursement/incentive/penalty structures. Just when providers have become accustomed to the technology and workflows necessary for navigating the Meaningful Use EHR incentive program and other required CMS provider reporting, CMS announces change. In mid-January Andy Slavitt, CMS administrator, announced what sounded like the demise of the Meaningful Use Incentive Program only to clarify his statement the following week in the January 19th CMS blog with his co-administrator, Karen DeSalvo.

The CMS Administrators pointed out that Meaningful Use would continue into the unforeseeable future as a component of the composite provider performance score enacted in the new Medicare Merit-based Incentive Payment System (MIPS) under the Medicare Access and Children's Health Insurance Program Reauthorization Act of 2015 (MACRA), stating "While MACRA also continues to require that physicians be measured on their meaningful use of certified EHR technology for purposes of determining their Medicare payments, it provides a significant opportunity to transition the Medicare EHR Incentive Program for physicians towards the reality of where we want to go next."

Adele Allison, Director of Provider Innovation Strategies at Birmingham's DST Health Solutions, a subject matter expert and national speaker on federal legislation and policymaking related to HIT, healthcare reform, and provider reimbursement models, agrees that Meaningful Use is here to stay: "Today, the majority of providers are used to reimbursement under a fee schedule. However, MACRA rapidly moves Medicare down the payment reform causeway and heralds the onset of acceptable new forms of reimbursement designed to draw a hardline on cost containment. This new payment era will result in differential payment based on quality and efficiency data; and, adoption and use of health IT - Meaningful Use - will be one of those measures. As of 2019, MACRA makes Meaningful Use permanent under MIPS as a component of a weighted performance measure for Medicare reimbursement. Other payers will follow this lead. Simply stated, meaningful use is now tied to provider long-term economic success."

MIPS represents a shift from performance measurements based on the frequency of technology use to outcomes-based measurements demonstrated through use of technology in producing better patient outcomes, cost savings and a healthier patient population. Under MIPS, beginning in 2019, CMS will sunset the applicable payment adjustments under the CMS programs and replace adjustments with the MIPS 100 point weighted performance scale: clinical quality performance, 30 percent; resource utilization, 30 percent; meaningful use, 25 percent; and clinical practice improvement, 15 percent. MIPS is intended to be budget neutral, differentiating the poor performers from the best performers. The top 25 percent have the ability to receive a 10 percent performance bonus while the lower 25 percent will see like-minded reductions in reimbursements.

From 2016-2018, providers will continue to measure Meaningful Use, and other CMS quality measurement programs, under the current set of standards. Providers will have the opportunity to contribute to the structure of MIPS and time to prepare for MIPS. This transition phase should also enable HIT vendors and developers to shift their focus to technological innovation that meets the principles under MIPS as opposed to the checklist functionality under Meaningful Use compliance.

Beth Pittman serves Of Counsel at Waller where she specializes in healthcare law.


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