This Week – May 28, 2016

This Week in Washington, D.C.

  • ACG MACRA Tidbit for the Week
  • Meaningful Use in 2016: Practice Management Conundrum?

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Is “Advancing Care Information” just Lipstick
on a “Meaningful Use” Pig?

 
In short, the answer is “yes.”  However, on a positive note, it is a potentially more attractive pig.  How so?

This category adopts some current Meaningful Use Program objectives.  However, CMS is also proposing to reduce practice management burdens by: eliminating the duplicative clinical quality reporting requirements and getting rid of the “Clinical Decision Support” and “Computerized Provider Order Entry” objectives that are currently required in Meaningful Use.  Advancing Care Information is also not an “all or nothing” reporting program like in Meaningful Use (please see clarification below).

So in 2017, instead of reporting any Modified Stage 2 requirements, MIPS and APM participants will instead be reporting and attesting to measures under this new Advancing Care Information category.

…but this is still related to Meaningful Use, so it has to be a bit more complicated, right?  Of course.  It is still a pig.  Here’s how it works:  CMS proposes a total of 131 points.

First 50 points: Providers are required to report 6 objectives as a “base score” for this category: Protect Patient Health Information (“yes” required), Electronic Prescribing (numerator/denominator), Patient Electronic Access (numerator/denominator), Coordination of Care through Patient Engagement (numerator/denominator), Health Exchange Information (numerator/denominator), and Public Health and Clinical Data Registry Reporting (“yes” required).

Second 81 points: Your numerator/denominator on the following 3 objectives will determine a “performance score” for this category: Patient Electronic Access, Coordination of Care through Patient Engagement, and Health Exchange Information.  CMS proposes to require reporting to an immunization registry.  However, a provider could potentially receive an additional point by participating in a “qualified clinical database registry” like GIQuIC.

Please note that CMS places an emphasis on the Protect Patient Health Information objective.  Providers must attest to this category at least once to receive any score. If providers earn 100 -131 points in this category, they will receive the full 25% of the total MIPS composite score.   If providers earn less than 100 points, their overall MIPS score in this category declines proportionally.  Thus, this is not an “all or nothing” program or category.

Check out ACG’s “Making $ense of MACRA” summary for more analysis of MIPS and APMs.


From ACG National Affairs Committee Chair, Whitfield L. Knapple, MD, FACG

Meaningful Use in 2016: Practice Management Conundrum?  

As mentioned above, “Advancing Care Information” requirements will replace Meaningful Use beginning in 2017.  What’s more, Congress passed legislation last year that allows ACG members to apply for a blanket hardship exemption for 2015 Meaningful Use reporting requirements.  ACG members have until July 2016 to apply for this exemption.

So is 2016 a Meaningful Use “donut-hole” year?

Since Meaningful Use — err, Advancing Care Information — should reduce provider reporting burdens by eliminating the “Clinical Decision Support” and “Computerized Provider Order Entry” objectives starting 2017, and since ACG members can still take advantage of the 2015 reporting exemption (avoiding a 2017 payment cut) … is it even worth participating in Meaningful Use in 2016?  Would your practice benefit from just accepting the 3% payment cut in 2018?

Only you can answer this question based on your individual Medicare fee-for-service revenue and practice management operations. (ACG is not officially recommending this).  Somethings to consider could include: the CMS estimated amount of time and cost in participating in Meaningful Use in 2016; comparing that to your practice’s actual time and cost when participating in Meaningful Use for 2016; whether or not your practice can make up for this 3% cut in Medicare Part B revenue by not participating in Meaningful Use but freeing up more time to see and treat Medicare Part B patients.

Read the full blog post here.

Please check out ACG’s Meaningful Use toolkit to learn more on important dates and 2016 reporting requirements.