Regional health information organizations (HIOs) have been working over the past few years to move from the startup phase to sustainability by increasing the number of revenue-generating services they provide. One way they can start adding value in 2017 is by offering providers reporting help with CMS’ Merit-Based Incentive Payment System (MIPS).
During a recent webinar presentation, Genevieve Morris, senior director of the health IT policy team at Baltimore-based consulting and technology firm Audacious Inquiry, outlined several ways HIOs can be of service to ambulatory providers getting ready for MIPS.
Quality Measures
Some HIOs already offer providers quality measurement tools, Morris noted, but if they don’t already, this is an area they could move into. There are bonus points available for providers who use end-to-end electronic reporting of CQMs (clinical quality measures). “This is a place where an HIO could step in and help providers calculate their quality measures and electronically submit them to CMS and allow providers to pick up an extra 10 percent in bonus points, which for the quality measure category can be really important,” she said. For quality measures, providers are measured against each other, so however they perform on a particular quality measure gets benchmarked against every other provider in the country that submitted on that same measure. Therefore, picking up bonus points can make a difference between a negative penalty, a neutral payment or an increase in their payment adjustment.
Morris noted that, working in conjunction with Maryland’s state HIE CRISP, Audacious Inquiry released a clinical quality measure calculation tool called CAliPHR as open-source technology to support providers’ successful participation in federal and state incentive and value-based payment programs
There are a few other ways to do quality measure reporting electronically, she said, but you can’t use back-end ETL (extract, transform and load) or manual data entry methods to count for the bonus payment. “You want to make sure any providers using your tools to submit to the program are following all the regulations correctly,” she said. “We think this is an area where HIOs can provide support, particularly to smaller eligible clinicians, who may not have EHR systems certified for submitting quality measures and who want to maximize their scores.”
Advancing Care Information
The second area that HIOs can support is the Advancing Care Information (ACI) category, Morris explained. Several HIOs were already doing this with the current Meaningful Use regulations, and some of that work can be expanded in the ACI category.
For example, HIOs are well positioned to support the transition of care measure, she said. CMS removed the requirement that you have to use Direct as your transport method. The only requirement is that you use a certified EHR to generate a CCDA document. Whatever transport method they use, as long as it is in CCDA format, will count toward that measure. One stipulation that CMS did carry over: if you just make a CCDA available for query, the provider doesn’t get credit for that unless they can verify that the provider being referred to used the summary of care. Using an HIO as the transport mechanism or some notification service could be really helpful to providers, Morris added, particularly if they don’t know all the contact information of the provider they are referring to.
“HIOs are incredibly well positioned for transitions of care that come to a provider when they receive a patient or a referral,” Morris said. Providers have to receive and incorporate a summary of care into the patient chart. CMS has said they can use an HIO to query for the summary of care. They do have to be able to pull the CCDA itself. Pulling a PDF or text file does not help toward this measure. Providers need a machine-readable CCDA. They need to have the ability to pull it from the HIO into their EHR. “That is a really strong area where HIOs can support ambulatory practices,” she said. “If they are getting CCDAs from hospitals when patients are discharged, making that available to their ambulatory providers to incorporate into their charts will become very useful.”
There are two patient access measures in ACI. One involves providing patients access to their records within 48 hours after the data becomes available; the second measure requires that patients be able to view, download or transmit their information or access it via an API. There are some HIOs who have patient portals that can support this measure, Morris noted. “You would have to have technology that is certified to the proper criteria. If that is something you consider supporting, make sure you have proper technology in place,” she said.
Public health reporting offers a bonus score of 10 percent and if providers report to another clinical data registry they can get an additional 10 percent as well. “A lot of providers are actually planning to get 100 percent on ACI through the use of registries,” Morris said, “and if HIOs can support that, that helps them get their bonus points.”
Improvement Activities
The third section of MIPS that HIOs can support is in Improvement Activities. Most of the activities that an HIO can support are medium-weighted, she noted. One is about providing care management after emergency department visits. “If you have a system that notifies ambulatory providers when a patient is discharged from a hospital, that helps them follow up with patients routinely and meet this measure,” she said.
The second is around closing the referral loop. HIOs can help give specialist reports back to the primary care provider who referred them over, which can help them count toward that measure. “The practice still has to document it in their certified EHR, but the HIO can help them close that referral loop,” she said.
If an HIO has technology that allows providers to create longitudinal care plans, it can support them in meeting that improvement activity.
If an HIO has connections with community-based resources, such as nutritionists, or some sort of chronic disease management program, and it is helping share data, that will give providers credit for that improvement activity.
Other activities to support include use of a prescription drug monitoring program (PDMP) or working to provide analytics on total cost of care.
Morris stressed that just as with Meaningful Use, CMS will audit providers. The agency has not yet announced how many providers they plan to audit each year, “but if you support these activities for ambulatory providers, it is really important that you have documentation you can provide them so they can submit that information to auditors,” she concluded. “You could put them at risk if you can’t document it.”
