Out of the ashes of the stock market crash of 2008 came a jobs program, the American Redevelopment and Reinvestment Act (ARRA) of 2009, designed to help put people back to work, including people in healthcare who were willing to comply with evolving national healthcare goals by manufacturing specific healthcare software or by meaningfully implementing such technology. The Feds set up private credentialing organizations for EMR vendors plus an incentive payment system (The EHR Incentive Program), and "meaningful use (MU)" was born. Despite hiccups and complaints about its administrative complexity and implementation costs, the MU program led to revolution in U.S. healthcare information technology, including two
- For the first time, a standard was created for interoperability of key healthcare records, the so-called "MU data set." This data set provided each patient record with the equivalent of a "back of the baseball card" summary, including demographics, problems, medications, allergies, smoking status, vital signs, family history, immunizations and a bit more. All complete certified EMRs were required to adhere to this standard, resulting in a near universal adoption of an interoperable record called a Continuity of Care Document (CCD).
- A standard was also created for securely moving protected health information via the internet, called Direct Messaging. In simplified terms, Direct Messaging can be viewed as secure healthcare email. To date, roughly forty Health Information Services Providers ("HISPs") have been federally approved to provide direct email addresses, certifying that the sender and receiver are in fact who they say they are and adhering to other related security standards. The use of Direct Messaging has exploded with now over 1.3 million issued addresses to mostly healthcare providers, some addresses issued to consumers, and an expectation of more than 75 million direct transactions in 2016.
“Beyond the financial impact from CMS, it seems likely that MIPS quality ratings will become a very public measure of quality – visible to patients, payers, and hospitals...”
Prior to Merge's acquisition of DR Systems in 2015, both companies developed certified technology to support the EHR Incentive Program. Today, Merge offers such technology to our users, including a patient engagement tool and HISP called Health Companion®. This enables imaging providers to offer features that are increasingly demanded by patients such as electronic appointment reminders, report delivery, breast lay letter delivery, secure messaging, the assessment for the need for appropriate imaging screening exams, and patient education. However, although these services were made available by Merge and other vendors, and despite financial incentives, most radiologists found ways to "opt out" of the EHR Incentive Program. Many claimed that they did not receive sufficient IT support to succeed with the program, while others found ways to collect hundreds of millions in aggregate bonuses.
Now comes MIPS, or the Merit Incentive Payment System, wherein adherence to a set of quality measures, continuous practice improvement activities, and certain technologies (only required for some physicians) will determine a provider's quality rating and relative Medicare reimbursement. With MIPS, completely opting out without penalty is not an option. On the other hand, at first glance, compliance seems easier. Physician compliance activities, which are required beginning in 2017, impact CMS payments beginning in 2019, and will grow to + or – 4 percent that year to + or – 9 percent by 2022. Therefore, given the size of the rewards and the inability to opt out, MIPS will likely have a greater financial impact than the EHR Incentive Program. Beyond the financial impact from CMS, it seems likely that MIPS quality ratings will become a very public measure of quality – visible to patients, payers, and hospitals – giving MIPS the potential to affect patient-directed provider choice and professional contracts.
The impact of CMS payments to eligible providers for MIPS compliance will grow over time.
Since imaging specialists often work in facilities where they are not the owners, they must compete for the attention of limited information technology human resources and capital resources. The risk to imaging providers is that they will once again become a last priority when it comes to compliance, as was often the case during the EHR Incentive Program. So what steps can imaging providers take to maintain compliance, optimize reimbursement, and score highly in the new system? We'll explore the opportunities in next month's post.
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