More than 3,800 stakeholders have weighed in with comments on the Centers for Medicare & Medicaid Services’ proposed rule implementing the Medicare Access and CHIP Reauthorization Act (MACRA) and the new Merit-Based Incentive Payment System (MIPS). While many comments addressed the payment mechanisms for doctors, there also were numerous comments relating to health IT. 

For instance, while the proposed rule allows for more flexibility in selecting measures and streamlined reporting, many commenters expressed concern with the proposed three-part attestation requirement that providers were not involved in information blocking. The College of Healthcare Information Management Executives (CHIME) shared concerns on how information blocking was defined, and said that patient matching problems shouldn’t be considered data blocking. The Electronic Health Record Association viewed the proposed provider attestation of compliance with standards and of patient access as overreaching beyond what Congress had intended. The American Medical Informatics Association (AMIA) also saw those two attestation provisions difficult to implement, saying they created wide variation in interpretation, which could cause confusion for providers.

The surveillance attestation provision also was a concern. Health IT Now and AMIA did not support the requirement that providers attest that they cooperate with surveillance of their use of certified EHR technology under the Office of the National Coordinator for Health IT's certification program, citing that ONC doesn’t have authority of oversight of customers of such technology. The American Medical Association suggested that this provision be reissued after the rule addressing ONC’s surveillance authority is finalized.

There also were concerns about the short timeframe between the release of the final rule and MACRA’s Jan. 1, 2017, start date, since the final rule isn’t expected to be published until this November. The AMA suggested that there be a transition reporting period for the first year beginning July 1, 2017, and that CMS adopt an interim final rule, not a final one. AMIA, HIMSS and the Association of Medical Directors of Information Systems suggested that the reporting period be reduced from a year to a shorter period because of the short timeframe before implementation.

To learn more:
- view the regulation and comments