CMS RFI on MACRA

I’m a few weeks short of the 1 year anniversary of my departure from federal service.  I loved my time in Washington, and loved the people, the passion, the sense of purpose, and of course the focus on doing what’s right for the nation.  What was intended to be a 1-2 year adventure became a 3 years of commuting to DC from my home in Albany, New York.

Stepping away from government has given me the opportunity to get back to the front lines of the intersection of information technology and health.  Notice that I didn’t say “health care.”  Sure – “care” is part of what happens – but isn’t the goal to minimize the care that’s necessary – and maximizing health?  Glad you agree.

Until my 1 year anniversary, I’m prohibited from “engaging in certain activities on behalf of persons or entities.” Here’s the rule, in case you’re curious.  This is why I can’t testify or even engage in the FACA hearings or workgroups, call my former colleagues on the phone and give them unsolicited advice on policy matters, etc.

CMS has issued an RFI on how it implements regulations for MACRA.  I can’t submit comments (see above).  But since I still have first amendment rights – I can post my comments here.  Feel free to plagiarize when you post YOUR comments.  😉

Here is how I’d answer a few of the questions:

Under the MIPS, what should constitute use of CEHRT for purposes of reporting quality data?

MIPS should leverage the ONC’s certification program for purposes of reporting quality data. If the capabilities required for MIPS are not represented in the suite of capabilities for which products can be certified under ONC’s program, ONC and CMS should work together to create new certification opportunities under that program.  Anything other than this would be confusing, costly, and complex. CMS may be considering the creation of a separate program. What a waste that would be. Please please please don’t do that.

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Instead of requiring that the EHR be utilized to transmit the data, should it be sufficient to use the EHR to capture and/or calculate the quality data? What standards should apply for data capture and transmission?

I’ll answer an edited question – since “utilized” is used incorrectly in this sentence (who does the copy editing at CMS?) and as it is expressed – the monolithic EHR is assumed to be present.  But that should not be the case.  ONC has evolved their terminology toward “health IT” and CMS should do the same where possible.  Yes – due to the reference of “EHR” in the laws (both HITECH and MACRA) – this isn’t always possible – but perhaps we can get congress to fix that with a little wordsmithing.   (How about it, Colin and Alicia? )

Edited question: “Instead of requiring that health IT be used to transmit the data, should it be sufficient to use health IT to capture and/or calculate the quality data? What standards should apply for data capture and transmission?”

a) Health IT can and should be used by providers and provider organizations to capture and calculate quality – as tightly or loosely coupled as such organizations might be – including but not limited to BPCI awardee conveners, CPCI affiliates, ACOs (all shapes and sizes), ICNs, regional cooperatives such as a New York PPS (under the NY DSRIP program), states, RHIOs, HIEs, IDNs, MA joint ventures, etc.

b) The standards to be used for the reporting of such quality calculations should be QRDA III.

c) In the case of quality data transmission, QRDA I should be used.

d) Quality data capture (from health IT – to a quality aggregation/calculation entity) should leverage QRDA I. Health IT should be certified for the capture of data elements – as defined by ONC – referenced in the Data Elements Catalog and the Value Set Authority Center @ NLM – as is currently the case. Don’t break a good thing.

e) Outcome measures rather than process measures should be preferentially selected.