Washington Debrief: Physician Pay to Encourage More Advanced Use of IT

2015 Physician Pay to Encourage More Advanced Use of IT

Key Takeaway: Beginning in 2015, physicians paid by Medicare would be eligible for expanded telehealth payments, subject to new EHR (electronic health record) requirements, and would be able to submit the same quality measures for both the Medicare Shared Savings Program and meaningful use.

Why it Matters: When compared with current Medicare approaches for reimbursing inpatient facilities, the proposed 2015 physician fee schedule would make several important and impactful changes to Medicare reimbursement. This is another indication of how the Centers for Medicare and Medicaid Services (CMS) can continue its transition away from fee-for-service-based reimbursement without congressional action to repeal the Sustainable Growth Rate (SGR).

CHIME will investigate the proposed rule’s impact to key policy areas. Interested members should contact [email protected] for details on how to get involved.

Containing about 600 pages, Medicare’s proposed 2015 physician fee schedule (PFS) updates and revises several provisions that determine reimbursement. New proposals aimed at telehealth services, chronic care management services, the Medicare Shared Savings Program and the Electronic Health Record (EHR) Incentive Program are briefly outlined below.

Telehealth Services

The proposed update added annual wellness visits, both for an initial visit and for subsequent visits, to the list of covered telehealth services, as long as physicians include a personalized prevention plan of service. The notice for proposed rulemaking (NPRM) also proposes to add to the list telehealth sessions for psychoanalysis and family psychotherapy, both with and without the patient being present; and for “prolonged service in the office or other outpatient setting requiring direct patient contact beyond the usual service.”

Chronic Care Management Services

To be paid for chronic care management (CCM) services, Medicare is proposing physicians use 2014 Edition Certified EHR Technology (CEHRT) beginning in 2015.

Medicare Shared Savings Program

The proposed rule seeks to align Meaningful Use CQM reporting requirements with those required of eligible providers (EPs) participating in an ACO (accountable care organization) under the Shared Savings Program. EPs participating in an ACO under the Shared Savings Program can satisfy the CQM reporting component of Meaningful Use when the eligible professional extracts data necessary for the ACO to satisfy its GPRO quality reporting requirements from CEHRT, and when the ACO satisfactorily reports the ACO GPRO measures through a CMS web interface.

Electronic Health Record (EHR) Incentive Program

CMS also proposed that, beginning in CY 2015, EPs would not be required to ensure that their CEHRT products are recertified to the most recent version of the electronic specifications for CQM reporting. However, EPs still must report the most recent version of the electronic specifications for CQM reporting. The NPRM says if CMS discovers errors in the most recently updated electronic measure specifications for a certain measure, they would use the version of electronic measure specifications that immediately precedes the most recently updated electronic measure specifications.

House Appropriations Committee Waivers on Labor-HHS Bill

Key Takeaway: House Republicans and Democrats may have hit another partisan wall as key leaders remain uncommitted to a vote on the FY 2015 Labor-HHS Appropriations bill.

Why It Matters: Key areas of the federal government have gone several years without consistent updates to their budgets, preventing many programs from investing in changes to personnel or priorities. As policymaking and regulating becomes a more complex endeavor, especially in health IT policy, it is vital that budgetary authority be granted to agencies looking to address increased program complexity.

A draft budget bill would authorize $156 billion for labor, the Department of Health and Human Services (HHS) and education programs, which includes funding for the Affordable Care Act. Despite cutting more than $1 billion in funding compared with 2014 spending, the committee has yet to find common ground to pass the bill. However, because of opposing viewpoints on spending levels and appropriations for Obamacare implementation, House leaders are signaling their hesitation to vote. The stalemate may force the committee to miss its goal of passing 12 individual appropriations bills, which could force the creation of an omnibus bill or continuing resolution if they cannot pass individual bills before October. Congress and the President have passed only one budget through its designed process in the last 27 years.

Healthcare IT Leaders See Interoperability as Key to Solving Patient Safety Challenges

Key Takeaway: CHIME and AMDIS submitted comments on a draft government report, outlining the importance of interoperability in protecting patient safety through health IT.

Why it Matters: The comments target ONC’s certification program as being the primary lever through which the government can address challenges related to both interoperability and patient safety. Without more robust, and continuous, testing of certified health IT functionality, the healthcare system will continue to limp along with technology that does not interoperate and data silos that impede efficiency.

The government's proposed risk-based approach to regulating healthcare IT gives federal regulators an opportunity to adapt its health information technology certification program to focus on the dual goals of improving patient safety and interoperability, the nation's senior executive and physician health IT leaders said in recent public comments. Responding to the tri-agency "FDASIA Health IT Report," the College of Healthcare Information Management Executives (CHIME) and the Association of Medical Directors of Information Systems (AMDIS) filed joint comments, supporting most of the federal government's strategies to improve patient safety through health IT and develop an environment of continuous learning. The healthcare IT leaders said the biggest gains to patient safety could be obtained by retooling ONC's Certification Program to require more rigorous interoperability testing. Developing a comprehensive framework to regulating healthcare IT gives the government "a unique opportunity to address some key challenges," CHIME and AMDIS said. "ONC should reconsider the role and composition of its certification program to address patient safety risks and interoperability." CHIME and AMDIS recommended that ONC retool the certification program to focus on beta-testing, post-certified performance and standard adherence in live settings.