One of the most important considerations when deciding whether to stay with your EHR vendor or switch to a new one is the extent to which each EHR can help you take advantage of Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) participation through a merit-based incentive payments system (MIPS).
You may have heard that in 2018, physicians need to comply with certain requirements to participate in MIPS. For example, beginning in 2018 physicians must use an EHR that is 2015 certified to qualify for MIPS participation.
Selecting an EHR that is new payment model ready not only makes it easier for you to earn bonus money from the Centers for Medicare & Medicaid Services (CMS), but the features and workflows that facilitate meeting MIPS requirements are likely to improve patient care. Using your EHR to track electronic quality measures is an especially good idea if you plan to participate in a clinical registry, according to ReachMD.
It’s not too early to start researching whether your EHR vendor will be sufficiently prepared when the requirements go into effect, or whether you should find a new EHR vendor to meet upcoming qualification needs.
Below, I’ll walk you through the challenges posed by MIPS compliance and give you several key vendor questions to ask in your search for an EHR that helps with new payment models.
The three big challenges to MIPS compliance
There are three main concerns that hinder physicians’ ability to obtain full credit for new payment model participation.
The first is that most EHR vendors can’t do much to help practices perform well under new payment models. One of the most difficult aspects of getting a new pay model up and running is vendors’ failure to meet IT requirements, according to the CMS’ Dr. Laura Sessums.
Secondly: new payment models are constantly changing and becoming increasingly complex. It’s extremely difficult for practicing physicians to keep up with and fully understand CMS requirements surrounding full reimbursements and bonuses.
The third challenge is that even if you fully understand every new payment model in advance of rollout and happen to be looking for a new EHR, it’s difficult to ascertain whether and to what extent the available options will help you comply.
To get a better picture of what your EHR can do in terms of MIPS, the American Medical Association’s Koryn Rubin recommends asking your EHR vendor whether their system will support MIPS’ quality category performance requirements and whether the available electronic quality measures (ECQMs) are applicable to your practice.
That’s good advice, but it assumes your EHR sales rep will know whether ECQMs are applicable to your practice. And as for whether their system will support MIPS’ quality category performance requirements, what sales rep is going to say “No?”
There are all serious challenges, and the best way to overcome them is gaining relevant knowledge. Let’s get into the questions you can ask EHR vendors to determine whether their systemcan help you meet requirements.
The first MIPS requirement: 2015 Certification
As of today, the most advanced certified EHR technology (CEHRT) status is “2015 Edition CEHRT.” You need this CEHRT to fully participate in MIPS.
Technically, you can participate in MIPS with a 2013 CEHRT, but that level of EHR won’t help you meet your Stage 3 criteria for the EHR Incentive Program and MIPS participation as well as 2015 certification will. You also won’t benefit from other 2015 Edition CEHRT advantages, including:
- Greater interoperability
- Easier data access and exchange
- Increased privacy and security
- Improved patient safety
- Reduced health disparities
- Better support for the care continuum
- Greater reliability and transparency
MIPS EHR certification requirements details Source
Questions to ask your EHR sales rep or vendor
It’s always best practice to make sure you’re as fully informed as possible. There are several key questions you should ask before making an EHR purchase or choosing to stay with your current vendor.
I recommend asking these questions to both your current EHR vendor and reps for other EHR systems. Even if you’re not necessarily looking to switch EHRs, it’s helpful to know how your vendor stacks up against the competition.
Most of these questions concern advancing care information (ACI). Under MIPS, meaningful use (MU) goes away, along with its computerized provider order entry (CPOE) and clinical decision support (CDS) objectives. Under MIPS, ACI replaces MU.
ACI has two parts: base and performance. A physician’s total ACI score combines the points earned in each sections
Physicians earn ACI base section points in four ways:
1. Enable certain functionality in their EHR
If you record patient demographic data—such as gender, ethnicity, or religion—in your EHR, you can use this information to analyze patient care data for population health tracking.
2. Exchange medical information with one or more medical facilities
According to Rev360’s director of ECP services Brad Paepke, under Stage 3 providers can earn points by sending and receiving patient health information contained in Consolidated-Clinical Document Architecture (C-CDA) files.
3. Have one or more patients engage with their electronic medical records
Ideally, your EHR should incorporate patient-generated health data. As an example, Paepke notes that patients could enter home intraocular pressure (IOP) monitoring data into their medical records directly via a patient portal.
4. Send one prescription electronically
Physicians who prescribe immunizations must send one prescription electronically and submit associated information to an immunization registry to earn points.
Questions to ask your EHR sales rep or vendor:
Keep in mind that software functionality isn’t black-and-white. Asking whether or not your EHR can complete a particular task isn’t actually very revealing as the basic yes or no answer fails to include how easy (or difficult) it is to complete that task, how intuitive it is to learn, how many steps it takes, how the data is recorded, and how the reporting is presented.
Instead of asking a yes or no functionality question, be sure to ask your EHR vendor or sales rep to show you how to do a particular task in the EHR.
Let’s use recording patient demographic data as an example. Ask the EHR vendor or sales rep to show you how a user records patient demographic data, how that data is stored, and what the final reports look like.
- May I see which patient health information your system stores in C-CDA files?
- May I see what types of patient-generated health data patients can enter into their medical records directly via a patient portal?
- May I see the process for patients to enter such data through the portal?
- May I see how physicians use your system to send prescriptions electronically to a pharmacy?
- May I see how physicians who prescribe immunizations use your system to send electronic prescription information to an immunization registry?
Physicians earn ACI performance points through actions such as getting patients to engage with their medical records through a patient portal.
Physicians that prescribe immunizations and send information to an immunization registry via their EHR are eligible for a bonus if they connect their EHR to two or more immunization registries.
You can win clinical practice improvement points by using your EHR to coordinate patient care. For example, you may want to connect your EHR to a few state-based Health Information Exchanges (HIEs). Other ways to win points include clinical registry reporting, providing patients with timely access to their medical records, and managing patient referrals.
Questions to ask your EHR sales rep or vendor:
- Can you show me how to connect my EHR to a state-based HIEs?
- Can I view what a patient sees when they log in to their patient portal?
- Can I see the report your system produces to show when and how patients access their health information?
- Can you show me how to refer a patient to another physician using your system?
- Can you show me how to access reports of such referral details?
- Can you show me a sample patient referral report?
Sitting back and waiting for your EHR vendor to make changes to their system that will help you participate as fully as possible in MIPS will cause you to fall behind, because most EHR vendors are slow to adopt change.
It’s better to be proactive and familiarize yourself with what your EHR system can and will do to make your life easier, as well as how it measures up to other systems.
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