- In a recent comment letter on the final rule for the Quality Payment Program, the College for Healthcare Information Management Executives (CHIME) contends that a lack of healthcare interoperability will pose significant challenges for participants in the Merit-based Incentive Payment System (MIPS).
In fact, the organization representing healthcare CIOs and other IT leaders lists a “persisting lack of interoperability among and across our disparate health system” as one of three significant challenges that the federal agency still needs to address. The two others pertain to alignment of all meaningful use programs and more attention to cybersecurity.
CHIME’s comments on healthcare interoperability pertain specifically to MIPS requirements for eligible clinicians under the advancing category information component of the incentive program that replaces the EHR Incentive Programs along with the the Physician Quality Reporting System (PQRS) and the Value-Based Modifier (VBM).
As the organization notes, this MIPS category borrows measures from meaningful use and at the same time inherits and exacerbates many of the challenges associated with that program.
“Many of the measures in ACI are carried over from the Meaningful Use program and the concerns we have with them under this program are no different from the concerns we have articulated throughout the history of the Meaningful Use program,” the letter states. “In fact, success in the ACI performance category will require clinicians to perform well beyond the thresholds set under Meaningful Use in so much as the better a clinician performs on a measure the more likely they are to score higher on MIPS.”
According to CHIME, charting the right path to true (i.e., semantic ) interoperability — in the organization’s words, a “stretch goal” — requires an agreement on a uniform set of health IT standards as well as giving developers of certified EHR technology (CEHRT) time to make their systems interoperable.
“Requiring clinicians to meet more aggressive measures that hinge upon interoperability sets them up for failure,” it cautions CMS Acting Administrator Andy Slavitt. “The root causes for the lack of interoperability cannot be solved by CEHRT alone. In fact, we believe quite the opposite; a stronger state of interoperability facilitated by a uniform set of standards, including a national solution ensuring accurate patient identification, is our best hope for driving better care.”
If providers are unlikely to meet the requirements of the Quality Payment Program beginning in 2017, then CEHRT are even more unlikely to be ready, CHIME claims.
“In fact, some of our members have already alerted us to the fact that they will not receive their upgraded products until well into 2018,” the organization writes. “If you couple this with the concerns we have outlined around interoperability, it becomes clear that the road ahead, while paved with good intentions, is fraught with signals and warning signs.”
What’s more, the organizations calls for the federal agency to work with ONC (which is responsible for health IT certification) to promote the adoption of health IT standards facilitating efficient health data exchange and support patient identification and matching efforts in the private sector.
The interoperability concerns aired by CHIME extend to a lack of emphasis on health information exchange as part of the improvement activities performance category under MIPS.
“The transformation of our healthcare system is predicated on robust data exchange and the ability for clinicians to access data where and when they need it. Meanwhile, patients are increasingly demanding ubiquitous access to their records,” the letter reads.
Other high-level recommendations in the CHIME comment letter include making 2018 a transition year in addition to 2017, reducing all reporting periods to 90 days, incentivizing cybersecurity defense among providers, and limiting the number of attestations providers must affirm relative to data blocking provisions.
“CHIME appreciates the opportunity to lend our perspective to this new program and stands ready to aid the Administration navigate the technical landscape such that policies put into place best support patients and the providers who serve them,” the letter concludes.