In comments submitted to the Centers for Medicare & Medicaid Services (CMS), the nation's leading data scientists in health care urged federal officials to use new payment policies to reassess how providers are required to use informatics tools, and rethink how quality is measured in a digital world. Officials from AMIA said new and novel ways to deliver care will rely on dynamic uses of IT and other informatics tools, so government policies dictating the use of IT should be flexible and evolve as more experience is gained with new care models.
CMS issued a request for information (RFI) in October asking for stakeholder input on how best to implement a range of policies required by the Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 (PL 114-10). The Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs) established by MACRA will replace the current fee-for-service payment model for Medicare by 2017 and 2019, respectively. This system of reimbursement will rely heavily on electronically-specified clinical quality measures (eCQMs) to pay physicians based on how well their patients recover, rather than the number of services delivered. In comments, AMIA said it supported this move to value-based reimbursement, but voiced concern with the industry's ability to generate accurate and complete eCQMs, and urged more focus on outcomes-oriented quality measurement.
"AMIA supports the overall direction of moving to an outcomes-based payment system, predicated on demonstrating value for payment," the organization said in comments. "As we transition away from fee-for-service payment, so too must we move away from the quality measurement paradigm underlying that system. Despite earnest efforts, quality measurement has not become 'a by-product of care delivered,' as envisioned, and we are concerned the current mode is insufficient to enable this."
To improve the current approach, AMIA urged officials to devote more resources to testing both the accuracy of the measure calculation, as well as the feasibility of the data collection requirements, and pilot all new eCQMs before their release for use. CMS should also establish a regular cadence of updates/revisions to eCQMs, ensuring adequate time is allowed for implementation of revisions by both the vendor and provider. Further, AMIA suggested these policies create new opportunities to develop better outcome measures, rather than relying on current process measures.
Additional questions posed by the RFI sought input on how officials should implement policies that require the use of certified EHR technology, and whether new certification criteria are needed to help providers succeed within new payment models. AMIA recommended federal officials avoid overly prescriptive requirements to determine how providers use informatics tools within APMs, but rather focus on the outcomes sought by the use of such tools.
"Ours is a dynamic environment of innovation and invention," says Blackford Middleton, MD, MPH, MSc, FACMI, and current AMIA board chair. "AMIA sees policy development for MIPS and APMs as not just an opportunity to change our payment system, but as an opportunity to revisit policies meant to spur adoption and guide use of health IT."
AMIA President and CEO Douglas Fridsma, MD, PhD, FACP, FACMI, says, "In much the same way that fee-for-service era policies skewed incentives and provider behavior, overly prescriptive documentation and 'use' requirements of the same era have influenced how health IT is developed, implemented, and leveraged to improve care. We must evolve both sets of policies if we are going to succeed in this new paradigm."
Visit www.amia.org/sites/default/files/AMIA-Response-to-CMS-MACRA-RFI.pdf to read AMIA's full comments to the CMS RFI regarding implementation of MIPS and promotion of APMs.