The Future of Meaningful Use

The Future of Meaningful Use

Is Meaningful Use ending? This is a question we’ve been hearing a lot lately (and not just from those who simply wish it would end). The recent interest in the demise of the Meaningful Use (MU) program is a result of comments made earlier this year by Andy Slavitt, acting administrator of CMS. “The Meaningful Use program as it has existed, will now be effectively over and replaced with something better,” he said at a conference in January.

The statement was part of a much longer speech that thoughtfully detailed the steps CMS is taking to improve the reach of its programs and patient health and reduce fiscal and administrative burdens to healthcare providers.

But social media and the blogosphere glommed on to that singular sentence, and in the interest of character limitations or generating a sensationalist headline, the statement became, “Meaningful Use is Dead!” says CMS. Friedrich Nietzsche could not be reached for his thoughts on gross interpretation.

While there has never been an expectation that the Meaningful Use program would continue in perpetuity, these articles and posts led many to believe that MU was ending soon, or at least sooner than anticipated. The reality is that Meaningful Use will continue to exist, as planned, as will the Physician Quality Reporting System (PQRS) and Value-Based Modifier (VBM) program. Healthcare providers and administrators must continue to swim in the alphabet soup of regulatory programs through the end of 2018.

The “something better” referred to by Slavitt is the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which provides the framework for what’s to come in the post-MU landscape. The first provision of MACRA to go into effect repealed the Medicare sustainable growth rate reimbursement formula and replaced it with a more stable method of positive annual payment updates of .05% from July 1, 2015 through December 31, 2018. So far, so good.

The reform of regulatory programs will begin in 2019, when providers will need to choose one of two payment tracks: the Merit-Based Incentive Payment System (MIPS) or the alternative payment model (APM). Both tracks are designed for eligible providers, although APM participants must meet specific eligibility criteria to qualify.

MIPS is a lot like the 60s supergroup Cream, except instead of bringing together three of Britain’s best blues-rock musicians, MIPS combines MU, PQRS, and VBM into one powerhouse program. And while it’s well documented that Cream broke up because Eric Clapton could no longer deal with the constant clash of egos between Ginger Baker and Jack Bruce, MIPS seems intent on avoiding the same fate by arranging many of the measures and metrics of each program into four new performance categories: clinical quality, resource use, meaningful use (of certified EHR technology), and clinical practice improvement activities.

Providers will receive a composite score for their performance in each category and will be incentivized or penalized based on that score. How much they’re rewarded or penalized depends on how well a provider scores relative to the average score. For anyone who thinks 2019 is too far in the future to worry about, here the rub: payment adjustments (negative and positive) for 2019 will be based on the performance scores of MIPS-eligible professionals from the 2017 reporting year. This means providers who haven’t submitted any quality measure data for PQRS or as part of MU should begin participating as soon as possible. Consider this one of the few times that the preseason actually matters.

Providers who qualify can opt to participate in an APM, such as an Accountable Care Organization or the Medicare Health Care Quality Demonstration Program. Qualifying participants will receive an additional 5% payment bonus annually to encourage Medicare providers to move toward value-based payment models. These providers must use quality measures comparable to MIPS measures and receive at least 25% of their Medicare revenue through an APM; the revenue threshold will increase to 50% in 2021 and 75% in 2023 and must be met to continue receiving the annual incentive.

If the APM has a musical counterpart, it would be the Tommy Dorsey Orchestra: a large ensemble, well-rehearsed and with little room for improvisation. Indeed, the precision with which alternate payment models like ACOs operate require a great deal of coordination amongst a knowledgeable team in order to support better care and lower costs.

Although the specifics of MIPS and APM are still being hashed out, the principles that guide them are clear. Certified EHR technology remains integral to the success of these programs, with an emphasis on rewarding providers for outcomes achieved through the use of technology, encouraging the customization of Health IT to better serve providers and practices, and the prioritization of interoperability. Through the luxury of hindsight, it’s easy to see that “Meaningful Use”, as a program descriptor, was ahead of its time. As we prepare ourselves for the next ten years with a new model and a new mindset, it appears that the era in which technology is used meaningfully by providers to improve patient care is finally here.


The Low Down

2015: MACRA is in effect! It’s mostly a money thing for Medicare providers at this point.

2016-2018: Regulatory programs (MU, PQRS, VBM) continue as scheduled.

2018: MU Stage 3 is mandatory. Grin and bear it.

2019: The dawn of a new era! Choose your own reimbursement adventure by participating in either MIPS or APM.