More stakeholders have weighed in on the structure of the Merit Based Incentive Program System (MIPS) and alternative payment models (APMs), with the Healthcare Information and Management Systems Society and its Electronic Health Records Association both expressing concern about over-burdensome requirements.
In a letter to Centers for Medicare & Medicaid Services' Acting Administrator Andy Slavitt, the EHRA recommends that CMS take a more consistent and streamlined approach to measuring performance and quality in MIPS and APMs.
"We are enthusiastic about the opportunity to help providers optimize the use of technology as they transition to APMs. However ... we caution against over- reliance on the use of EHRs and health IT for collecting data that is outside the scope of EHRs, or is not currently defined and implemented today," EHRA states. "For items that may be appropriate to add to an EHR for measuring or reporting, both vendors and providers need sufficient time to develop and implement new functionality or reporting capabilities, which may not be possible in time for the 2017 performance year."
EHRA also recommends that the MIPS calculations be as simple as possible, and does not support the creation of a new certification for the APM track; the technology requirements should be the same for MIPs and APMs to reduce barriers going forward.
The letter from HIMSS' echoes the belief that the certification EHR technology requirements should be the same for the EHR program and APM participants. HIMSS also recommends that CMS implement an "aggressive and thorough" quality measures testing program before requiring them for MIPs and asks that CMS consider greater flexibility for providers who try to meet Meaningful Use but can't meet the exact thresholds.
Both entities were responding to CMS' request for comment on MIPs and APMs, both part of the Medicare Access and CHIP Reauthorization Act (MACRA) enacted earlier this year, which repeals the Sustainable Growth Rate formula for compensating physicians in the Medicare program. MACRA also moves physicians out of the Meaningful Use program and into MIPS.
Other entities have responded to CMS' request for comment on MACRA, with CHIME recommending that reporting be streamlined and that the pass/fail Meaningful Use model be jettisoned. AMIA suggested that CMS rethink its informatics policies as the industry moves to value based payment models.