CHIME calls for longer transition period, streamlined reporting, cybersecurity incentives for MACRA

The College of Healthcare Information Management Executives is urging the Centers for Medicare and Medicaid Services to provide even greater flexibility and a longer transition period into MACRA, as well as pushing for further streamlining of standards and IT reporting requirements and incentives for clinicians to take steps against cybersecurity threats.

The organization sent lengthy comments to CMS Acting Administrator Andy Slavitt citing three major challenges facing the healthcare industry as it moves forward and strives to understand and implement the detailed new rules. Those challenges included a "persistent lack of interoperability", a need for synchronization across all meaningful use programs and the need for more attention on cybersecurity, the comments said.

Providers, industry leaders and advocates have long lamented the complexity of the 2,000 plus page rule, and that trend is continuing. First, CHIME is pressing CMS to make 2018 a transition year as well. The Pick Your Pace policy unveiled this Fall made 2017 such a period, and greatly reduced the amount of reporting necessary to achieve basic MACRA compliance and avoid penalties.

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CHIME said they believe "additional clarity is needed" on how the new policies actually work. Specifically the organization said they've fielded questions from members on whether a clinician would need to report for the entire year or just 90 days in order to receive a score of 100 under MIPS, and are recommending further education for clinicians.

The group said members have expressed concern over having to comply with multiple tracks of Meaningful Use, including one for MIPS, another for Medicare hospitals, and yet another for Medicaid providers. The road ahead could be treacherous for providers, and CHIME is asking for better alignment of the three sets of reporting requirements. First, they recommended establish a 90-day reporting period for all reporting requirements in perpetuity; postpone any Stage 3-like measures and use of EHRs certified to Version 2015 until no earlier than 2019; removing pass/fail policies, especially for hospitals, and instead allow providers to meet at least 75% of the requirements and still pass; allow facility-based clinicians to use their institution's performance rates as a proxy for the MIPS' clinician's quality score.

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Additionally, CHIME said the current state of interoperability will not support MIPS requirements, and a more uniform set of widely adopted standards for "seamless data exchange" are needed so that patients patients can be identified throughout the "care continuum."

Vendor and provider readiness go hand in hand, and neither are where they need to be for clinicians to succeed under the new payment programs, CHIME said. Just 23 products out of thousands are ready for Version 2015 certification under Meaningful Use, compared to more than 4000 that are 2014 certified. Right now, these systems are required to be 2015 certified by the year 2018. CHIME said this time table is far too abrupt, and is pushing for the use of Stage 3 or Stage 3-like measures to be implemented no earlier than 2019.

"It is clear most vendors are not yet ready. 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," CHIME said. "...The low number calls into question vendors' ability to deliver products in time for providers to meet Stage 3 / Stage 3-like measures in 2018."

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Cybersecurity is top of mind across the healthcare industry, with thousands of data breaches affecting and sometime crippling organizations, not to mention exposing sensitive information for patients and other stakeholders. CHIME expressed disappointment that CMS had not heeded their suggestion to give clinicians credit for activities aimed at strengthening their practices' ability to ward off cyber criminals and practicing "good cyber hygiene." They strongly recommended CMS implement clinical improvement activities that provide incentives for clinicians in this are, the comments said.

"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. As healthcare grows more digital, more data is susceptible to compromise," CHIME said.

Twitter: @BethJSanborn