Audacious Inquiry’s Comments on MACRA

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We appreciate the time and effort Centers for Medicare & Medicaid Services (CMS) put into crafting the NPRM and recognize that this is a complex program and therefore a complex regulation. Ai’s comments are primarily focused on the Advancing Care Information (ACI) category, as Ai subject matter experts have provided Meaningful Use consulting services since the start of the program, and on the use of health IT and certified electronic health record technology (CEHRT), since Ai has a quality measurement product, CAliPHR. We are seeking clarification on a number of points and offering suggestions on how CMS can improve the regulation in some places.

Summary of Comments

Ai offers the following overarching comments to CMS which are described in more detail in the remainder of the letter.

General

  • We recommend that CMS take steps in future rulemaking to align the measures and reporting mechanisms in the Medicaid EHR Incentive program with those in the Advancing Care Information performance category.
  • We ask CMS to clarify how the composite score calculation will work for groups with ECs that have different performance category weightings.
  • Ai agrees with CMS’ approach to identify qualifying APM professionals (QPs) by a combination of the APM identifier, APM entity identifier, TIN, and NPI. We strongly encourage CMS to make the QP identifiers available to stakeholders via an API, similar to how CMS has made NPPES data available via an API.

Data Submission

  • We ask CMS to work with ONC to clarify in the final rule what the expectations/requirements are for third party submission methods and their interactions with Certified Electronic Health Record Technology (CEHRT).
  • We recommend that ECs be allowed to use multiple data submission methods across the performance categories both in 2017 and in future years of the program.
  • We ask that CMS work with ONC on how QCDRs, QRs, and health IT vendors are working with CEHRT in practice today, and adjust and clarify their intentions for these third party data submission methods.
  • We believe that the industry as a whole should be moving towards including eCQMs as an important method for measurement rather than solely relying on claims-based, and chart review-based CQMs. We feel that CMS should encourage and support such a transition by encouraging providers to use certified Health IT Module reporting methods, rather than manual methods, such as QCDRs.
  • We recommend that CMS release XML formats for data submissions for Advancing Care Information and CPIA as soon as possible.

ACI Performance Category

  • We strongly recommend that CMS collaborate with ONC to ensure that relevant certified health IT modules are able to aggregate, de-duplicate patients, filter by provider, and calculate scores for groups in the Advancing Care Information performance category.
  • We encourage CMS to continue down the path of providing greater flexibility to ECs in how they meet the requirements of the ACI performance category. However, we recommend that CMS change the proposed policy in the NPRM and allow ECs to earn a performance score and bonus score even if they fail the base score.
  • A number of changes were proposed to the 2017 existing measures. We strongly encourage CMS not to make any changes that increase the difficultly of measures in 2017.

Quality Performance Category

  • CMS should consider adding the criterion at § 170.315(c)(4) (Clinical quality measures—filter) to the definition of CEHRT for MIPS to ensure all participating providers have the needed functionality to filter eCQMs to support group reporting.
  • We are very supportive of CMS’ plans to encourage the use of CEHRT and electronic reporting of CQMs for the quality performance category by providing a bonus for such submission. However, we recommend that CMS allow ECs who are using CEHRT/health IT vendor to report CQMs for the Quality performance category to have an exemption from reporting a cross-cutting measure.