On January 1, 2017, the new Medicare Access and Chip Re-authorization Act (MACRA) will go into effect, completely replacing its predecessor, the Sustainable Growth Rate (SGR) program. This new legislation has the full support of the American Medical Association (AMA) because it represents a sweeping change to how Medicare claims will be handled and how physicians will be reimbursed for services.
One of the main question is how can health IT can be used in support of MACRA? And, how can the roles of the CIO and the IT department contribute to the success of complying with the new legislation?
Since MACRA will be in effect through at least 2019, it is important that healthcare professionals understand its application and potential impacts on business.
What exactly is MACRA?
The first thing to understand about MACRA is that its impact is limited to Medicare clinicians. Despite this limited application, it would be well worthwhile for all health IT vendors who deal with EHRs to be familiar with its provisions, especially with regard to the Meaningful Use stipulations.
The Advancing Care provision within MACRA supersedes the old Meaningful Use program. This provision reduces the reporting requirements from 18 distinct points under Meaningful Use to 11 points, with the intention of providing flexibility, improving alignment with other Medicare programs, and reducing redundancy among other reporting requirements. A key point of this provision is that clinics using EHRs must have their technology certified before 2018 by the Office of the National Coordinator for Health Information Technology (ONC).
MACRA significantly advances the cause of value-based reimbursement for Medicare claims in that physicians will now be reimbursed under a two-pronged system: either the Merit-based Incentive Payment System (MIPS), or the Alternative Payment Models (APM) system. (Read: MIPS replacing Meaningful Use for physicians)
MIPS allows physicians to be reimbursed via a consolidation of existing payment programs and by demonstrating compliance in four separate categories: quality, cost, clinical practice improvement activities, and advancing care information, such as the use of technology in supporting EHRs.
Further, MACRA encourages doctors to make the greatest possible use of APMs by bundling payments through programs already in existence, with the lure of such incentives as qualifying for incentive payments, as well as removing the requirement to report all MIPS data. It also allows for future advanced APMs, which may be developed by Medicare or through programs instituted by Medicaid and private providers.
How will MACRA affect health IT and the role of CIOs?
The main points of MACRA that must be supported by IT include:
- Electronic prescriptions
- Protecting patient health information, including the use of security risk analysis
- Provide patients with electronic access and educate patients about program usage
- Coordinate care through patient engagement, including secure messaging, view-download-transmit of summary care information, and patient-generated health data
- Exchange of health information, such as patient care records, and reconciliation of clinical information
- Reporting of immunizations to public health organizations and clinical data registries
In practice, this means that IT must support these initiatives to the fullest so the organization can demonstrate compliance through examples and reported proof. For instance, to show compliance with the secure messaging provision, at least one patient from a clinic must be sent a secure message using certified EHR technology, ideally in response to an original secure message sent by the patient.
Compliance with the View, Download, and Transmit (VDT) provision can be demonstrated by making EHRs accessible to users, and allowing them to view their health information using a program certified by the ONC. Again, using ONC-certified technology, electronic prescriptions can be sent to pharmacies or other providers for patients under the direct care of the clinic.
In actual practice, clinicians would use EHRs to capture a patient’s status over a prolonged period of time and store that information on records formatted according to guidelines established by the ONC. We will need a universal format so that information can be easily retrieved and interpreted by any organization with access. This stored information is searchable (according to ONC requirements for certification) so it can be retrieved for analysis of trends and patterns.
A CIO must support these provisions of MACRA and our goal is to ensure that the entire IT staff understands the importance of compliance, as well as the significance of maintaining the infrastructure and components of technology that contribute to the successful support of these mandatory and well-intentioned reporting initiatives.
I recommend that healthcare CIOs partner with their physician leadership in sponsoring the required training for personnel who will be involved with the EHR workflow process and ensure that vendors comply with the set of guidelines required by the ONC for proper formatting. In addition, the CIO must ensure that all appropriate security measures are installed to safeguard patient privacy and comply with relevant security measures required for EHR technology.
It is important that we understand this regulation and assist the organization in the journey towards value-based care.
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