AMIA urges CMS to focus on health IT improvement activities in hospital payment rule
In comments submitted to the Centers for Medicare & Medicaid Services (CMS), the American Medical Informatics Association (AMIA) applauded federal officials for balancing burden reduction provisions with a need to continue making progress on health IT adoption and use. As part of the EHR Incentive Program’s continued evolution, the nation’s leading clinical informaticians called on CMS to abandon program reliance on prescriptive measures, in favor of hospital-developed improvement activities.
CMS announced in April several new proposals aimed at changing the EHR Incentive Program, also known as Meaningful Use, for hospitals. The newly renamed “Promoting Interoperability (PI) Program” would require the use of 2015 Edition CEHRT 2019 and continue a 90-day EHR reporting period through 2020. The PI Program would also include a new points system scoring methodology and fewer required measures for hospitals to report. AMIA largely supported these proposals, while recognizing that important functionalities related to retired patient engagement measures, such as secure messaging, education, and use of patient-generated health data, must remain part of CEHRT.
The proposed rule sought information on how CMS could enhance the program in future years to further nationwide interoperability, improve health information exchange, and promoting innovative uses of health IT. In response, AMIA called for a dramatic shift in how the PI Program of the future should be administered.
“AMIA recommends CMS abandon the construct of measure reporting in favor of an activity-based approach,” AMIA wrote in response. This approach, AMIA argued, “will enable organizations to demonstrate clinically meaningful use of health IT for their specific patient populations and priorities without forcing novel enactment strategies.” AMIA recommended replacing required measures with clinically-relevant “Inpatient Improvement Activities (IIAs).” While similar to the Improvement Activities under the Merit-based Incentive Payment System (MIPS) program, AMIA envisions that such hospital-specific improvement activities would:
- Rely on the most recent Edition of Certified EHR Technology (CEHRT);
- Align with a small number of broad strategic priorities established by HHS;
- Be hospital-developed with a description of expected data inputs, processing, and action steps, with an assessment of impact;
- Involve a high percentage of all clinicians who deliver care in the facility; and
- Be posted publicly for purposes of transparency.
Recognizing the difficulty in crafting such a program, AMIA recommended that CMS initiate a broad and inclusive conversation regarding the characteristics of IIAs, and further recommended the CMS Innovation Center (CMMI) initiate pilots to understand what systems and controls are needed to support this program. AMIA hopes that a revamped PI Program will be operational by 2021 for hospitals that are willing to transition away from prescriptive, numerator/denominator-driven measurement.
In addition to these long-term changes to the PI Program, AMIA urged CMS to avoid adding more requirements not currently supported by CEHRT. AMIA pointed to proposed measures not currently supported by 2015 CEHRT as requirements that should not yet be finalized. “A general principle CMS should follow is ensuring that ONC’s Certification Program supports all CMS requirements,” AMIA wrote.
AMIA strongly supported the proposed requirement for providers to use only 2015 Edition CEHRT starting in 2019, while underscoring the need to find ways to expand incentives for adoption to other settings of care.
