The Centers for Medicare and Medicaid Services proposed replacing the Electronic Health Records Incentive Programs, commonly called Meaningful Use, for eligible professionals who participate in Medicare. The proposed replacement, Advancing Care Information, would become one of four performance measures within the broader Merit-Based Incentive Payment System, or MIPS.
The proposal follows passage of the Medicare Access and CHIP Reauthorization Act. The statutory changes are intended to tie payments more closely to the quality and overall value of patient care. For eligible Medicare professionals, the framework would change how electronic health record activity is reported within the federal Medicare payment system.
The proposal would not replace Meaningful Use across the entire healthcare system. Hospitals would remain under the current structure. Eligible professionals who operate under Medicaid would also continue under the traditional program. Similar clinical activity could therefore be subject to different reporting requirements, depending on the professional’s program and the payer involved.
A flexible category within MIPS
Advancing Care Information would be one part of MIPS rather than a separate reimbursement system. The category would cover the use of certified electronic health record technology, the exchange of structured health information, and patient access to health data.
The framework would support interoperability between different technology platforms. Clinicians would have more choice in selecting reporting metrics that fit their daily work. This would replace the fixed measurement criteria and quarterly reporting schedules associated with the previous approach.
Reporting measures do not fit every practice in the same way. A metric that works well with one clinician’s workflow may be difficult to use in another practice. Under the proposal, eligible professionals could select measures that better match their work while still meeting the broader requirements of the category.
The proposal would also make group reporting options and targeted exemptions available. These options would address situations in which a practitioner’s workflow does not fit extensive technology integration. Professionals would not all have to follow the same reporting path.
Fewer measures and broader data access
The proposal would reduce the number of required reporting measures from 18 to 11. Regulators would also remove mandatory reporting for historical benchmarks related to clinical decision support and computerized provider order entry.
Fewer measures would simplify the reporting process, but the framework would still require certified electronic health record technology. Practitioners would need to use technology that meets current federal interoperability standards.
The proposal would connect reporting requirements with patient access to health information. Providers would have to give patients a timely way to view and download their medical data through secure application programming interfaces. These interfaces would allow information to move between health systems and applications.
The framework would also address deliberate efforts to block health information exchange. Providers or vendors that intentionally interfered with the exchange of health information could face penalties. The requirements would therefore concern more than a practice’s use of certified technology. They would also address whether information can move between different technology platforms.
The same payer distinctions can shape modern medication costs, because commercial plans, Medicare, and state Medicaid programs may reach different decisions about the same prescription.
The proposal’s limits
The proposed changes would apply to eligible professionals who operate under the Medicare framework. They would not alter the Meaningful Use structure for hospitals or for eligible professionals who operate under Medicaid.
Different parts of the healthcare system would therefore follow different reporting paths. An eligible Medicare professional could move into Advancing Care Information, while a hospital would remain under the older program. An eligible professional operating under Medicaid would also continue under the traditional Meaningful Use structure.
The proposal would not create one reporting standard for every provider. The same type of clinical activity could remain subject to different requirements based on whether it occurs within Medicare or Medicaid and whether the reporting entity is an eligible professional or a hospital.
Professionals who work within more than one program would need to identify the applicable reporting framework for each activity. Participation in Medicare could involve the new category, while hospital or Medicaid activity would remain subject to the existing Meaningful Use structure.
Proposed timing and practical effect
If regulators finalized the proposal without major changes, the initial reporting period for the new physician standards would begin on January 1, 2017. This date would apply to the proposed standards for eligible Medicare professionals. It would not mark a replacement of Meaningful Use in every provider setting. The proposal was part of the broader body of HHS documents in the Federal Register.
For eligible Medicare professionals, the practical change would include fewer reporting measures and more choice in selecting metrics. The framework would still require certified electronic health record technology, interoperability, timely patient access through secure application programming interfaces, and compliance with provisions against blocking health information exchange.
For hospitals and eligible professionals under Medicaid, the proposal would leave the existing Meaningful Use structure in place. Advancing Care Information would apply to eligible Medicare professionals, while hospitals and eligible professionals operating under Medicaid would continue under the traditional program.