MACRA and Informatics
How do technology tools factor in to new reimbursement models — and what does it all mean for radiology?
As I'm sure you've heard, 2017 is the first performance period of the MACRA-derived Quality Payment Program (QPP). The QPP includes two payment pathways, and almost all radiologists will be scored under the Merit-Based Payment System (MIPS).
We are receiving special considerations as "non-patient facing" in 2017. In particular, we are exempt from the Advancing Care Information (ACI) performance category, which is the continuation of the earlier Meaningful Use (MU) program. Most interventional radiologists will also be exempt from ACI, based on their status as hospital-based physicians. Thus, we are not required to use certified electronic health records (CEHRT) technology to avoid negative payment adjustments.
From a risk-averse perspective, this is favorable, as the existing ACI measures may be challenging for us to fulfill. But we may not receive this ACI exemption indefinitely. In fact, the MACRA statute and subsequent regulations include numerous references to the use of CEHRT. Therefore, radiologists should take advantage of the time period of our exemption to explore the importance of CEHRT in the QPP and to create ways for radiology to participate more fully. To that end, Gregory N. Nicola, MD, chair of the ACR MACRA Committee, and I attended the ACR Informatics Commission meeting in early February to discuss several topics, some of which I will share in this column.
The American Recovery and Reinvestment Act of 2009 made MU the law, but radiology subsequently received a five-year hardship exemption. Without the fear of negative payment adjustments, the radiology community has been slow to invest in CEHRT. As a result, we are behind other specialties. Should we make that investment in CEHRT now, and does the QPP provide sufficient motivation to do so? Since this investment will involve our entire profession, including the vendor community and providers, the question is far-reaching.
The QPP clearly encourages the use of CEHRT. Within the MIPS Quality Performance category, the use of CEHRT gives us more reporting options and providers receive bonus points for end-to-end electronic reporting using CEHRT. Within the Improvement Activities (IA) performance category, several of the 90 available activities specifically describe the use of CEHRT. For example, the improvement activity of providing specialist reports back to referring physician states that the interaction "could be documented or noted in the certified EHR technology" (read more about each activity at qpp.cms.gov/measures/ia). CMS will periodically make calls for new IAs. This gives radiologists the opportunity to propose IA favorable to our profession, which could include the use of CEHRT if we are capable. The QPP regulations also allow bonus points for reporting improvement activities with CEHRT.
The long-term goal of the QPP is to evolve into alternative payment models (APMs). As that occurs, CEHRT will also be relevant. New APMs will fall into different categories. The most robust form of APM is the Advanced APM, which may provide participants complete exemption from MIPS scoring. One of the three base requirements for an advanced APM is the use of CEHRT. Another form of APM is the Physician-Focused Payment Model (PFPM), largely being developed by a MACRA-mandated committee called the Physician-Focused Payment Model Technical Advisory Committee (PTAC). One of the PTAC's evaluation categories for a viable PFPM involves "health information technology." This means that CEHRT will be viewed favorably by the PTAC and could be a requirement in some PFPMs. Emerging APMs will require radiology services, and those radiology practices that have embraced CEHRT may have a competitive advantage in collaborative APM efforts with other specialties and broader health care systems. For instance, a hospital system implementing a new APM will look for a radiology provider who will help satisfy the requirements for successful reporting, including CEHRT. Put differently, a practice not using CEHRT may not be considered at all.
Our profession remains exempt from the required use of CEHRT. This exemption will likely go away in the future, which should motivate us to explore and expand the use of CEHRT now. This effort will require collaboration between radiologists, radiology IT experts, the vendor community, and policymakers. The use of CEHRT will allow us to better fulfill the requirements under MIPS. And as APMs evolve, the use of CEHRT will better position us to contribute to these future models. More important, CEHRT stands to improve patient care and the overall quality radiology provides.
By Ezequiel Silva III, MD, FACR, Chair