As most readers will know, when CMS released details on MIPS and the Alternative Payment Model incentives it embarked on a new direction for quality programs generally. As most readers will know, MIPS consolidated PQRS, the Physician Value-based Modifier and the Medicare EHR Incentive Program for EPs (Meaningful Use). But CMS is still updating the Medicaid incentive program.
If I were a physician, I’d be even more interested in the CMS initiative dubbed Promoting Interoperability. In some of the biggest news to come out of the agency in ages, CMS is restructuring the EHR Incentive Programs to become the Promoting Interoperability Programs. Promoting Interoperability replaces the Advancing Care Information category of MIPS.
Whoa. That would be a big enough deal on its own, but the issues the rule raises are an even bigger one.
CMS’s has been working towards this goal for a few years. Per HIMSS, here are some changes suggested in the proposed rule that might have the biggest impact on the health IT world:
- The rule would cut down measures from 16 to six
- It would use a new performance-based scoring methodology which would include measures of performance on e-prescribing, health information exchange, provider to patient exchange and public health and clinical data exchange
- The agency will define and work to prevent “information blocking”
On a related note, CMS has posted a request for information asking for stakeholder feedback on program participation conditions. This is pretty unusual for the agency.
Like many CMS proposals, this one leaves some important questions open. (Apparently, CMS itself wonders how this thing will work, as the request for information suggests.)
For example, the new performance-based scoring method will award providers anywhere from 0 to 100 points. Measuring health IT performance is always a tricky thing to do, and there’s little doubt that if this becomes a final rule, both providers and CMS will have to go through some struggles before they perfect this approach. In the meantime, providers face some big challenges. How will they adapt to them? Its too soon to say.
Addressing so-called “information blocking” should be an even bigger challenge. Everyone from members of Congress to providers to vendors acts as though there’s one way to describe this practice, but there’s still a lot of wiggle room. Honestly, I’ll be amazed if CMS manages to pin it down the first time around.
Still, the time is more than overdue for CMS to take on interoperability directly. Without real data interoperability, many promising digital health schemes will collapse under their own weight. If CMS can figure out how to make it happen, it will be pretty neat.