Electronic Health Record (EHR)
Successful reporting on many of the performance measures under MACRA will require increasing the use of Certified Electronic Health Record Technology (CEHRT) over time. In 2017, a clinician can use the 2014 edition CEHRT, 2015 edition CEHRT, or a combination of the two. However, ALL clinicians must be on the 2015 edition of CEHRT beginning with the 2018 performance period.
Check you EMR for Certification
To support the Advancing Care Information requirements (ACI) of MIPS, a system will need to meet the following criteria:
Design and Performance
Quality and Safety
Finally, CEHRT must also be able to exchange key health data known as the Common Clinical Data Set using specified vocabulary standards when applicable. This will allow systems to “speak the same language” when sending and receiving patient data. All clinicians using a 2015 ONC edition CEHRT should be able to electronically send the following clinical information about a patient:
Common Clinical Data Set
- Patient Name
- Preferred language
- Smoking Status
- Medication allergies
- Lab tests and results
- Implantable Devices
- Assessment and plan of treatment
- Health concerns
- Care team members
Care Management (Population Health Management)
Care management systems support care coordination, interventions and education for targeted patients (those identified as high-risk or those with a chronic condition). The system can be part of the EHR or can be a stand-alone system that integrates data with the EHR. Traditional EHRs are not designed for care management purposes as they lack automated workflows that alert the care manager to follow-up on critical work items to support the patient.
Care management systems aggregate patient data across multiple health information technology resources, create a single patient record, identify opportunities for improved patient outreach and track the interventions. The platform provides real-time insights to the care team to identify and address gaps in care within the patient population.
Care management and care coordination systems support the care managers based on an Identify, Engage, Enroll and Monitor workflow model.
The system supports a registry tool that identifies specific populations and patients based on diseases, conditions or other factors. Once the patient is identified, the system supports the engagement of that patient including the development of an evidenced-based care plan. The care manager teaches patients about their condition and the steps the patient should take to achieve and manage goals.
Once the personalized patient care plan is developed, the patient is engaged by the care manager (via phone calls, virtual encounters or face-to-face interactions) to support the patient over a period of time. Updates and changes to the care plan are entered into the system. As the patient achieves their goals, the system will support ongoing monitoring of the patient to ensure the patient is staying compliant with the care plan.
A care management workflow management system facilitates a team-based approach and includes the following:
- Patient Registries (Conditions/Diseases)
- Patient Attribution and Assignment
- Performance Management – Clinical and Cost Measurements and Outcomes
- Evidence-Based Protocol (Conditions/Diseases)
- Care Management Team Work Queues and Workflows
- Personalized Care Plans - Build, Track and Document Care Plan
- Patient Education Materials
- Care Team/System Communication
- Wellness Program Management
Under MIPS, the reporting methods are broken into two categories: individuals and groups.
Reporting methods for individuals include: claims, qualified clinical data registry (QCDR), qualified registry, and electronic health records (EHR). The Advancing Care Information (ACI) and Improvement Activities (IA) categories will include attestation options. There is no data submission for the cost performance category, as the Centers for Medicare & Medicaid Services (CMS) will calculate this for Eligible Clinicians (ECs) based on Medicare claims data.
Reporting methods for groups include: QCDR, qualified registry, EHR, and CMS Web Interface. Groups will also be able to attest for the ACI and IA performance categories. The CMS Web Interface option is only available to groups of 25 or more ECs.
Some clinicians may choose to report using an EHR to avoid additional costs or frustrations of implementing and learning a new system. If you choose this path, you will need to invest time in understanding the nuances of the submission requirements. You should check with your EHR vendor to make sure you’re compliant and that this reporting method can be easily executed.
Do note that after you have selected the measures that are most applicable to your practice, you might discover that some measures work better with the Registry submission method while other measures earn you a higher score with the EHR Submission method.
CMS has developed a secure Internet-based application for MIPS data submission available for pre-registered groups of 25 or more clinicians. CMS provides more information and a step-by-step guide:
Qualified Clinical Data Registry (QCDR) is a specialty specific registry developed by various specialty organizations to allow groups and individuals to populate their database with specific quality measures applicable to that specialty. All patients, regardless of coverage, are reported to the QCDR. For specialties that include both technical and professional components, both are reported to the QCDR. QCDRs are distinct from qualified registries and are CMS-approved entities that collect medical and/or clinical data for the purpose of improving the quality of care. QCDRs can submit quality measures, IA and ACI to CMS on behalf of its participants.
Review the list to see if you are affiliated with a QCDR. Check the quality measures supported by each individual QCDR to see if they align with the measures you or your practice intend to focus on. https://qpp.cms.gov/docs/QPP_2017_CMS_Approved_QCDRs.pdf
A qualified registry is a CMS-certified entity that submits Quality Payment Program (QPP) data to CMS as a batch end-of-year submission on behalf of eligible clinicians. While some EHRs and registries may overlap functionally, registries typically include more robust performance analytics than EHRs as they are designed specifically for interpreting MIPS measure data. Some registries are also supplemented by educational resources and support teams that can help you figure out how best to navigate confusing submission rules, and how to use the data you already have to maximize your quality improvement and MIPS payment adjustment.
Many HIT Vendors have submitted and been approved for this status. Review the list to see if you’re affiliated with a vendor that is an approved entity and can submit on your behalf or to explore potential partners that may also assist in advice and analytics around MIPS.
This resource provides guidance on the different MIPS reporting mechanisms available: