The health information technology (HIT) world was shaken to its core last week by Andy Slavitt, Acting Administrator of the Centers for Medicare & Medicaid Services (CMS), who announced that the CMS Meaningful Use (MU) program was over. More precisely, he stated, “The Meaningful Use program as it has existed, will now be effectively over and replaced with something better.” He tweeted this as well, and it was retweeted by Dr. Karen DeSalvo, Director of the Office of the National Coordinator for Health IT (ONC). A transcript of his comments were posted in The CMS Blog. The health IT media was quick to pick up on his remarks.
Does this mean that eligible professionals and hospitals will no longer need to meet MU criteria to get CMS incentive dollars or avoid penalties. Sort of. Months ago, in one of the few bipartisan moves of the current Congress, passed the Medicare Access and CHIP Reauthorization Act (MACRA) legislation . This legislation is best known as the “doc fix” because it fixed the problem of the old sustainable growth rate (SGR) formula of Medicare that threatened to substantially decrease physician reimbursement under Medicare.
Another part of the MACRA legislation addressed some criticisms of the various Medicare incentive programs, such as their multiple number, i.e., not only MU, but also the Physician Quality Reporting System (PQRS) and the Value-Based Payment Modifier (VM). These will all be rolled into a single Merit-based Incentive Payments (MIPS) program, which will start to assess penalties in a graduated way, from 4% in 2019 up to 9% in 2022. After 2019, CMS will also provide another pathway to incentives via Alternative Payment Models (APMs), such as through accountable care organizations (ACOs).
The MIPS program will consist of four categories of measures (divided among percentages): quality (30%), resource use (30%) , clinical practice improvement activities (15%), and MU of certified EHR technology (25%). The details of these are under development by CMS, but it is clear that within MIPS, MU will be part of what eligible hospitals and eligible professionals will need to achieve to qualify for Medicare incentives and avoid penalties. As of right now, that includes MU, including Stage 3 . What any new approach will look like going forward is not known. Stay tuned!
Some suggestions for improving MU going forward from John Halamka speaking on behalf of about 30 healthcare delivery organizations and Peter Basch and Thomson Kuhn speaking on their own but as leaders from the American College of Physicians.
Both Basch and Kuhn as well as Halamka deem MU Stage 1 a success in terms of achieving widespread adoption, but note it is time to move beyond the functional-use measures of MU. They call for Stage 3 as it is currently planned to be abandoned and also note how the highly persecutive approach stifles innovation by clinicians and boxes in the work of EHE developers. Basch and Kuhn go farther in terms of making recommendations. They call for a reconfiguration of MU within MIPS, with the elimination of functional-use measure thresholds (e.g., 80% of patients with problem lists or use of five clinical decision support rules), judicious use of non-threshold functional-use measures, practical interoperability that allows the delivery of high-quality care, more flexible engagement with patients, more innovative approaches to participating in and measuring quality initiatives. A final call they make is for continuing medical education within the domains of health IT so that physicians (and others) can learn how to deliver the best care using IT.
When writing about the present situation of the HITECH Act, I often harken back to what I wrote when it was first unveiled: "This is a defining moment for the informatics field. Never before has such money and attention been lavished on it. HITECH provides a clear challenge for the field to 'get it right.' It will be interesting to look back on this time in the years ahead and see what worked and did not work. Whatever does happen, it is clear that informatics lives in a HITECH world now." It is now time to move on from HITECH and MU to a more sustaining health IT that meets the needs of the healthcare system going forward.
1. Doherty, RB (2015). Goodbye, sustainable growth rate—hello, merit-based incentive payment system. Annals of Internal Medicine. 163: 138-139.
2. O'Neill, T (2015). Primer: EHR Stage 3 Meaningful Use Requirements. Washington, DC, American Action Forum. http://americanactionforum.org/uploads/files/research/2015-10-20_Primer_Stage_3_Meaningful_Use_Final_Rule_%28CH_edits%29_ej_mg_sh_....pdf.