- Late last week, HHS released the final rule for the Quality Payment Program under MACRA, establishing a set of requirements that eligible clinicians must follow in order to avoid a negative payment increase in 2019. Chief among them are several that facilitate better patient access to health data.
As noted in the final rule, the Quality Payment Program has two options: the Advanced Alternative Payment Models (Advanced APMs) or the Merit-based Incentive Payment System (MIPS). Although eligible clinicians will need to focus on patient engagement activities in order to be a successful Advanced APM, most of the concrete patient engagement requirements fall under MIPS.
In 2017, MIPS will include three performance score categories: quality, improvement activities, and advancing care information, the program which is replacing meaningful use. (The proposed performance category of cost does not apply to the transition year.)
The MACRA implemenation final rule includes six patient-centered data requirements as part of the advancing care information performance category, many of which involve boosting patient access to health data. These requirements rely on a robust and interoperable health IT and EHR system.
Here's a closer look at those requirements.
Patient data access
Overall, the Quality Payment Program's patient engagement requirements focus on improving patient access to their health data through various digital methods. This first requirement specifically calls for general patient access.
According to the final rule, patient health data access means “the MIPS eligible clinician provides patients (or patient-authorized representative) with timely electronic access to their health information and patient-specific education.”
For this first reporting year, which begins on January 1, 2017, eligible clinicians must allow at least one patient with view, download, and transmit capabilities. They also must enable at least one patient to view their health data using any health device via an application programming interface (API).
The second patient engagement requirement makes eligible clinicians responsible for providing patient education materials.
“The MIPS eligible clinician must use clinically relevant information from CEHRT to identify patient-specific educational resources and provide electronic access to those materials,” the final rule says.
Eligible clinicians must supply these educational materials to at least one unique patient for the reporting period.
Care coordination through patient engagement
The care coordination through patient engagement requirement likewise relies on patient health data access. According to the final rule, eligible clinicians must extend data access to at least one patient, who then transmits the data to a third-party such as a separate provider.
This can be conducted either through view, download, and transmit capabilities or through API access.
Secure direct messaging
This provision requires eligible clinicians and their patients to utilize messaging capabilities on various health IT devices, including patient portals or mHealth tools.
Clinicians must exchange at least one secure direct message with at least one unique patient. Eligible clinicians may also satisfy this requirement by responding to a message initiated by a patient.
Patient-generated health data
The patient-generated health data component demands providers integrate data collected outside of the episode of care into their EHRs. Data may be collected through mHealth wearables or remote patient monitoring tools.
Eligible clinicians must collect patient-generated health data from at least one unique patient for this reporting period.
Health information exchange
This final patient-centered requirement calls for eligible clinicians to coordinate care amongst one another for the benefit of the patient. Clinicians will coordinate care through referrals and transitions.
“The MIPS eligible clinician provides a summary of care record when transitioning or referring their patient to another setting of care, receives or retrieves a summary of care record upon the receipt of a transition or referral or upon the first patient encounter with a new patient, and incorporates summary of care information from other health care clinician into their EHR using the functions of CEHRT,” the final rule says.
During referrals, eligible clinicians must transmit the summary of care to the new provider for at least one unique patient. When accepting a referral, eligible clinicians must request and incorporate the summary of care from the original provider for at least one unique patient.
Care transitions will also require clinical information reconciliation. This includes medication lists (type, dose, frequency, route of medication), medication allergies, and current problem lists.
Picking your own pace
These patient engagement requirements are all included in the first Quality Payment Program reporting year. However, for that year, CMS has introduced the pick your own pace option. Pick your own pace offers eligible clinicians four different options for the 2017 reporting year.
First, eligible clinicians may choose not to participate in the program; however, they will be subject to a negative payment adjustment in 2019.
Second, they may submit at least some data in order to receive a neutral payment adjustment in 2019.
Third, they may submit all of the requirements but for a shortened reporting period of less than one year. Last, they may participate in the program fully, reporting all requirements for the full calendar year. These options may result in modest to full positive payment adjustments in 2019.