Understanding MACRA and Informatics
A quick-start guide to leveraging today’s technology to survive and thrive in the value-based future
When it comes to leveraging innovative technology, radiology has always been a leader in medicine. But the advent of Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) has changed the reimbursement landscape, and radiology must adjust its approach.
Due to the challenges of implementing certified EHR technology (CEHRT), radiology received an exemption from MACRA’s preliminary meaningful use requirement and has (thus far) avoided negative payment adjustments. That “free pass” has allowed most radiologists to ignore CEHRT in the hope it would go away.
The MACRA statute and subsequent regulations include numerous references to the use of CEHRT — foreshadowing its importance to CMS quality programs going forward. “Most likely, radiologists will not receive the CEHRT exemption indefinitely,” says Ezequiel Silva III, MD, FACR, a radiologist in San Antonio, Texas, and chair of the ACR Commission on Economics. “It is imperative for us to use this window of time to explore and expand our use of CEHRT. We need to dig into it and make sure we’re ready.”
So, when will the radiology exemption run out? No one knows for sure. “It could end as early as the 2019 reporting period, which means we would start to see negative adjustments in 2021,” says Silva. “CMS still has to craft the regulations. If there are measures being created for this scoring system, we want them to be meaningful and worthwhile for radiologists. We have to influence that public policy. The time is now!”
Informatics Under MIPS and APMs
In a recent article in the JACR, the authors noted, “By not previously integrating CEHRT into our daily workflow, radiology is now at a disadvantage in the two payment pathways of MACRA: the Merit-based Incentive Payment System (MIPS) and advanced alternative payment models (APMs). Specifically, not integrating CEHRT hampers radiologists’ ability to receive bonus points in the quality performance category of the MIPS and, in parallel, threatens certain threshold requirements for advanced APMs under the new Quality Payment Program (QPP).”1
In MIPS, Nicola says it’s clear that the centerpiece of the program is CEHRT. “If you read the legislation, you will find significant emphasis on informatics in all four MIPS performance categories,” he explains. “In fact, three of the four MIPS performance categories — quality, advancing care information, and improvement activities — specifically have CEHRT as a primary driver for data capture and collection. As we get more sophisticated at measuring cost, CEHRT will play a central role there, as well.”
On the APM side, one of the most robust models is the advanced APM, where clinicians are eligible for highly favorable reimbursement deals, including exemption from MIPS reporting. One of the three base requirements for an advanced APM is the use of CEHRT by at least 50 percent of qualified participants. According to Nicola, “Simply put, CEHRT is a hub for participating in advanced APMs and must be part of our profession’s strategic plan to thrive in this framework.”
Financial Incentive and Better Care
Whether you’re participating in a QPP under MIPS or an APM, Silva and Nicola agree that leveraging informatics like CEHRT will help you meet requirements, increase scores, and receive better financial incentives. Says Silva, “CEHRT is not just a protection against future risk. It is an actual opportunity for financial advantage today.” Adds Nicola, “CEHRT helps us improve patient care and the overall quality radiology provides.”
A Multi-Pronged Approach
Adopting and expanding CEHRT will require collaboration among radiologists, radiology IT experts, the vendor community, and policymakers. With the informatics providers, Silva says, “Most of us in radiology didn’t embrace meaningful use, because it wasn’t required.” “Since the vendors didn’t have demand for certified PACS, there was little financial incentive to pursue CEHRT status.”
The problem: When the exemption expires and penalties kick in, demand rises — but there’s no viable product to meet the need. So, vendors might rush a solution to market. “To avoid that downstream circumstance, radiology stakeholders should instead partner with technology vendors now so that we can begin the process of incorporating proven CEHRT into our daily workflow,” says Nicola.
Silva agrees, “Make your voice heard now, so that the radiology community can influence the tools and the measures to ensure the end product is what we want. Either we do it, or we trust in someone else to do it for us.”
Actions to Take Now
2. Participate in the National Radiology Data Registry®, which has been approved as a Qualified Clinical Data Registry, to collect and report quality data versus relying on a traditional claims-based approach.
3. Capitalize on informatics resources from the Harvey L. Neiman Health Policy Institute® , including the new Breast Screening Bundle Tool and the Inpatient Cost Evaluation Tool.
4. Investigate other technology solutions, including clinical decision support tools like ACR Select™ .
5. Leverage collaborative solutions like R-SCAN™ (rscan.org) to partner with referring providers to reduce inappropriate tests and procedures.
6. Start a dialogue with your IT vendors. Ensure it’s a bidirectional conversation about what tools can do and what radiologists need. In the
near future, radiology IT vendors must ensure that their RIS, PACS, and radiology reporting systems are CEHRT compliant.
7 Establish quality as a strategic guiding principle for your practice. Make a commitment to the informatics tools and resources needed to ensure success.
Linda Sowers, freelance writer for ACR Press