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industry updates

Are you required to participate in a registry for the Merit-Based Incentive Payment System?
Posted: May 17, 2016

Hello RevolutionEHR users!

With a growing team of ODs to help educate and inform you, I am pleased to send you this note that has been compiled with the tremendous assistance of Dr. Brett Paepke.  When topics are must-read, I try to let you know that, and this is a MUST-READ.

You might have seen an article in last week’s AOA Week In Focus e-newsletter regarding the Medicare Access and CHIP Reauthorization Act of 2015 (or MACRA, for short).  The complete article appears here: http://goo.gl/h1axHu.

As you will recall MACRA is the new legislation that will shift your payments for Medicare patients from fee-for-service payments to fee-for-value considerations, including the formulas that will calculate your clinical quality care and then relate your quality measures of such to your payments.  In short, the better you care for your patients, the better you will be paid.

The bulk of the AOA article provides a solid, factual recap of information from the MACRA final rule proposal.  However, the piece closes with an opinionated quote that, in our view, could lead readers to misunderstand the facts as we see them:  “The bottom line: If you don’t participate in a registry, then you can’t get the maximum reimbursement.”  This is not accurate, and thus, we are going to illuminate this topic for you with hope that you will better understand this important upcoming reimbursement topic.

First, the proposed quality care measures program will deliver a point-based program to grade each provider’s quality.  While the definitions of this program are ongoing, the current proposal that is undergoing review will be based on a variety of actions (MU participation – to be renamed Advancing Care Information, PQRS, etc.)

As part of this reconstitution of measuring your quality care, MACRA proposes to alter the Public Health Reporting objective under Advancing Care Information (formerly MU) within the Merit-Based Incentive Payment System (MIPS) in a manner which places less emphasis on registry participation.  As all RevolutionEHR OD users will remember from past MU activities, Registry participation has always been excluded for MU attestation because Immunization registries were not relevant to optometry care.

Going forward, Immunization Registry engagement would be required unless not applicable while participation with other types of registries (Syndromic Surveillance, Specialized Registries, etc.) would be optional.  That’s a shift from the current system which expects 2 active registry engagements if two are applicable.  The good news is that if a clinician chooses to participate in additional registries beyond Immunizations, they stand to be awarded a “bonus point” toward their Advancing Care Information score.  The actual value of this bonus point, though, depends on the clinician’s scoring across the 8 “performance” measures.

Next, Qualified Clinical Data Registry (QCDR) participation offers a number of paths for success within the Clinical Practice Improvement Activities category of MIPS.  These are not, however, the only paths to success.  While QCDRs offer a high-value road, clinicians have over 90 activities from which to choose including the offer of extended office hours and same day appointments for urgent care, timely communication of test results, clinical checklists and practice assessments, etc.

Finally, CMS encourages all clinicians to consider electronic reporting mechanisms as we move into this new frontier of merit-based pay.  These methods, which include submissions via certified EHRs, qualified registries, QCDRs and web interfaces, offer the promise of increased flexibility, accuracy and efficiency leading to decreased burden on providers.  Providers who embrace electronic reporting processes stand to earn a bonus point within the “Quality” category of their MIPS composite score.  Electronic reporting, however, is not a requirement.

RevolutionEHR has been a supporter of AOA’s MORE registry and is in ongoing work with AOA to send the data that is considered core to any participation in that registry.  Given the AOA article of last week, and the quote that MORE participation is the only way to achieve maximum reimbursement, we felt that it is important that you know there is nothing within the proposal that places such an absolute requirement on an OD who does not perform immunizations to participate in a registry to achieve optimal scoring and reimbursements.  While registry participation can offer certain benefits toward that goal, it is by no means the only path to get there.

Want to learn more about MACRA and the Merit-Based Incentive Payment System proposed rule?  Stay tuned for an announcement as it’s on the agenda for our next educational webinar.

Scott A. Jens, OD, FAAO
CEO
RevolutionEHR




  


  


  


  

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