Ask Adele: Evolving Through Meaningful Use
Thursday, October 8, 2015
By Adele Allison, Director, Provider Innovation Strategies, DST Health Solutions
Editor's Note: Adele will be presenting on a variety of topics at the Fall Primary Care Conference
Question: I hear that for Medicare providers Meaningful Use incentives are over but the program has been made permanent. Can you clarify and explain where Medicaid eligible professionals (EPs) stand in relation to Meaningful Use?
The CMS Medicare and Medicaid EHR Incentive programs known as “Meaningful Use” (MU) are provider entitlement programs created through legislation known as the American Recovery and Reinvestment Act of 2009 (ARRA). Each Medicaid eligible professional (EP) is allowed to earn up to $63,750 paid over six years for meaningfully adopting and using interoperable, certified electronic health records technology (CEHRT) as set forth under ever-evolving CMS regulations. Be aware that the latest an EP can initiate MU and receive the maximum statutory Medicaid incentives is 2016.
In contrast to the Medicaid program, Medicare EPs were authorized to earn incentives up to $44,000 paid over five years, driven by year of achievement, stage of adoption, and the amount of Medicare Physician Fee Schedule (MPFS) reimbursement received over a calendar year. Medicare MU incentive payments ended after 2014. Additionally, beginning this year Medicare EPs are subject to escalating penalties in the form of payment adjustments for non-adoption.
CHC and RHC clinicians are not paid for Medicare services using a MPFS. This essentially makes them unable to receive incentives under the Medicare side of the MU programs. Medicaid is also a state-run program, making a state’s participation in the Medicaid MU entitlement optional. Even though all states and territories have launched Medicaid MU programs, penalties for non-adoption cannot be imposed through Medicaid by the federal government; and, because CHCs and RHCs bill Medicare using revenue codes instead of the MPFS, payment adjustments simply do not apply.
MU becomes a Medicare measurement of quality
Today, the majority of Medicare providers are reimbursed on a MPFS, but this is changing fast. In April, the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) was enacted, which includes a new Medicare cost containment program for MPFS providers starting in 2019. This law signals the beginning of the end for traditional fee-for-service payment. Under MACRA, MPFS providers will be required to select one of two payment paths for Medicare reimbursement:
1. Alternative Payment Model (APM) – Providers choosing this path will automatically receive a five percent Medicare incentive payment. APM payment methods include but are not limited to accountable care organizations (ACOs), bundled payments, and such other programs set forth on the CMS Innovation Center website. These models require community coordination of care and the ability to accept and responsibly manage risk, both of which need advanced technologies, strong data and analytics to succeed.
2. Merit-based Incentive Payment System (MIPS) – MIPS is essentially a fee-for-service payment model with differential adjustment based upon provider performance data. Sources of data will include the Physician Quality Reporting System (PQRS), the Affordable Care Act’s (ACA) Value-based Payment Modifier (VBM), the Medicare MU program, and a new category known as the Clinical Practice Improvement Activities (CPIA). Metrics will be compiled to create a composite score ranging from 0-100 for practitioners. Providers whose performance data ranks them in the lower fourth quartile will receive an adjustment; high performers in the top quartile will receive a bonus. Adjustments/bonuses will reach up to the following amounts based on calendar year performance:
A proposed rule has been released by CMS further outlining these key Medicare payment reforms. But Medicare is not the only one moving down the payment reform path. APMs and performance-based differential payment is permeating commercial and Medicaid programs, as well.
Why do Medicaid MU if I don’t have to?
You need to decide whether you are striving towards what “has to be done” or what “should be done” for the sake of your patients. Health IT holds the promise of modernized operations for financing improvement, operational efficiency, increased quality and safety, expanded reporting, and compliance, but only if it is used as a true change agent to maximize these benefits and rewards. This makes strong business sense given the capital, resource and cultural investment a clinic must make to achieve success.
Let’s face it. Reengineering the medical practice must occur on top of everything you have to do today. You don’t get to close the clinic doors for three months to adopt technology and implement new workflows. Change is a painful process. Yet, using health IT for purposeful process improvement over the bare minimum imposed by MU can lead to a competitive advantage, strategic positioning and, most importantly, enriched value for the patients you serve.
Sure, the federal government is taking the lead in altering the way care is delivered and paid for in the U.S.; and, its reach may be limited to traditional Medicare providers. However, all payers and patients are seeking value over volume in healthcare and data plays a critical role in achievement. Your data will determine how you are reimbursed and publicly profile your performance. It can also deliver a vehicle to structure an ongoing quality improvement program within your clinic and community. This is why health IT adoption and use is required within the scope of health home recognition/accreditation programs.
For example, used properly, clinicians can identify patients who are not adhering to clinical guidelines for wellness, prevention and management of chronic disease. This empowers your clinic to manage entire patient populations, perform outreach and reduce disparities instead of delivering reactive care that is limited to a single patient in the clinic. Technology can be used to improve access for people living a long distance away or with transportation issues by connecting providers and patients through telehealth solutions. Health IT can create interconnectedness between a patient’s care team by sharing information across the continuum such as notifying you when a patient is in the emergency department or admitted.
Using technology tools can also help your patients by providing timely, accurate access to personal health information. Think about it. A patient is awake approximately 6,000 hours in a year, but may only be in your clinic for one hour over that same time period. Why not arm your patients with information and tools to support strong health, self-management and good choices when they are away? Patient portals offer a vehicle for improved communication where you can push results and education to your patients rather than having them pull information from you. It can engage patients, involving them with choices about their own care by providing personal health information or material on treatment options and self-management.
2015 NWRPCA/CHAMPS Fall Conference
I hope you will plan to join me at the 2015 Fall Primary Care Conference in Seattle, WA. In addition to offering you the opportunity to collaborate with your peers, NWRPCA, CHAMPS, and WCN will be playing host to an incredible slate of domain experts. This conference represents and outstanding opportunity to get involved, learn about cutting edge innovation and share ideas.
I hope to see you there and thank you for your question!
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