Naomi Levinthal, Health Care IT Advisor
The industry is abuzz after CMS Administrator Andy Slavitt said this week that "the meaningful use program as it has existed will now be effectively over" in the wake of the Medicare Access and CHIP Reauthorization Act (MACRA).
However, this is does not mean that meaningful use will end—instead, it will evolve. The meaningful use program is required by the 2009 American Recovery and Reinvestment Act, and that cannot change without legislative action by Congress. But the program will likely look different for eligible professionals (EPs) than it does for eligible hospitals and critical access hospitals (collectively, EHs).
From our experts
As of now, the meaningful use program will continue through 2016 as-is for both EPs and EHs.
In future years, the meaningful use program will almost certainly change for EPs, as CMS implements the Merit-Based Incentive Payment System (MIPS) as part of MACRA. The MIPS program includes meaningful use as a component, and MACRA definitively states that the program must determine whether an EP is a "meaningful EHR user."
Meanwhile, meaningful use is set to continue as-is post-2016 for EHs because MACRA impacts only EPs. However, CMS may move to align EH meaningful use so that the requirements are similar to those in the forthcoming revisions to the EP program.
I suggest our members consider the following as they digest these comments from Slavitt:
- There are still a lot of unknowns about how meaningful use will evolve. For example, Slavitt indicated that the meaningful use program "focus will move away from rewarding providers for the use of technology and towards the outcome they achieve with their patients." This statement suggests that the revised meaningful use component of MIPS could become more difficult than the way meaningful use is structured now.
- Providers should maintain existing EH and EP meaningful use initiatives for the year-long 2016 program year and continue to work toward meeting the meaningful use requirements as they currently stand. Providers that do not meet meaningful use in 2016 will forfeit any incentives due and are subject to payment adjustment in 2018.
- The MIPS program overall may be more challenging and require increased EP engagement as CMS seeks to tie payments to outcomes, quality, value, and practice improvement, all while requiring that EPs qualify as meaningful EHR users.
- The hallmarks of meaningful use—care coordination, patient engagement, and information exchange—remain critical to organizations that wish to stay competitive in evolving value-based payment models. Slavitt’s statement has no impact on that key fact.
Our IT research team will publish further analysis and guidance about any forthcoming meaningful use changes—so stay tuned.