Making sense of proposed EHR incentive program changes for MIPS providers | Geneia

Making sense of proposed EHR incentive program changes for MIPS providers

June 26, 2018
Heather Lavoie, Chief Strategy Officer


Junior doctors walking with a tablet.

Why is everything so complicated? My query seemed simple enough – how does the CMS (Centers for Medicare & Medicaid Services) proposed rule from April 24 to streamline quality reporting and improve EHR programs impact Medicare providers on the MIPS track of the Quality Payment Program? I should have known better than to ask.

There’s a lot to unpack.

Quality Measure Reduction

The proposal overall is promising. Goals include removing quality measures that are duplicative, topped out or overly burdensome across five acute care and value-based purchasing programs. Given the continuous high rate of physician dissatisfaction, I emphatically applaud every effort to reduce click-time and increase patient-time.

EHR Incentive Program Overhaul

The proposal revamps the existing EHR incentive programs to improve flexibility, remove outdated and redundant regulations, and make it easier for patients to obtain their medical records electronically. CMS hails the overhaul as a new phase of EHR measurement.

Specifically, the proposed rule lightens data reporting requirements for Clinical Quality Measures (CQMs) that fall under 2018 Medicare hospital inpatient services. It also reduces the mandatory reporting period for the EHR Incentive Program from a full year to a single, continuous 90-day stretch.

The proposed rule reinforces, but does not change, the 2019 deadline for providers to adopt 2015 Certified EHR Technology (CEHRT) to demonstrate meaningful use and thereby qualify for incentives and avoid reductions in Medicare payments.

Conditions of Participation

Hidden deep in the rule is the suggestion that CMS tie hospital conditions of participation in the Medicare program to the sharing of data with patients in a universal electronic format. This suggestion leverages CMS health and safety standards to further interoperability goals and link payment to interoperability between providers, sites of service, third parties, and patients upon discharge, transfer or request.

The proposal makes 2019 the year hospitals will be required to provide patients with their comprehensive medical records in a secure, usable electronic format upon discharge.

Name Changes

As an outward expression of commitment to improving interoperability and patient access to health information, the proposal renames the existing EHR Incentive Programs as the Promoting Interoperability (PI) Programs. To maintain alignment across programs, the proposal renames the MIPS Advancing Care Information category to Promoting Interoperability performance category.

What does this mean for MIPS reporting? 

Short answer? Not. A. Thing.

It is a change in name only. The proposal makes significant changes to EHR incentive programs to align them with existing MIPS measures, without impacting MIPS measures.

The 2018 requirements for the MIPS Promoting Interoperability performance category are the same as those finalized for the Advancing Care Information category.

Bear in mind, in the Quality Payment Program final rule, CMS made significant changes to the 2018 performance year requirements for MIPS reporting. Most notably, the final rule:

  • Extends MIPS transition timeframe to 2022
  • Expands flexibility for small practices
  • Allows virtual group reporting
  • Sanctions use of 2014 CEHRT
  • Awards bonus points for the use of 2015 CEHRT

To learn more

It was surprisingly difficult to discover a whole lot of nothing. I did it, so you don’t have to. We at Geneia are committed to keeping you abreast of ongoing MACRA changes, even those that only appear to have an impact. Visit our resource center for more information.

A doctor confronts a smiling senior with good news.


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