When was the last time there were people dancing at work? I remember seeing some sweet dance moves in 2014 when Centers for Medicare and Medicaid Services (CMS) announced it was going to push the transition from International Classification of Diseases ninth revision (ICD-9) to ICD 10th revision (ICD-10) for the billing of diagnosis and procedures for one more year. It wasn't because we weren't going to be ready, but because it was going to take a lot of work. It was a relief to be able to take a breath of fresh air and draw up a new plan with more time to get us across the finish line. With that one delay, I think the entire industry was better equipped because of the flexibility offered to us.
2017 has come and almost gone, and thanks to the 2015 edition Certified Electronic Health Record Technology (CEHRT) delay, we've been granted that breath of fresh air again. That means now is the time for rubber to meet the road as health care systems get ready for the big year ahead in 2018 – because if we do, we'll all be better off for it.
Here are some things providers, hospitals and health care systems can expect in the way of 2018 regulatory updates:
Full implementation of 2015 CEHRT
2015 Certified EHR Technology (CEHRT) must be fully implemented before hospitals roll into 2019. It's required for more than Meaningful Use. There is a myriad of other programs that need it, the Merit-based Incentive Payment System (MIPS), Comprehensive Primary Care Plus (CPC+) and other Advanced Alternative Payment Models (A-APMs),, with more likely being added to the list. This technology lays the foundation across the industry for key interoperability advancements, further enabling patients to own their data across providers, geographies and EHRs by requiring standard nomenclature and exchange methods for the exchange and provision of electronic health information.
Analyzing MIPS performance
2017 is the first performance year for the MIPS program designed to create a new world of Value Based Care (VBC) for Eligible Clinicians (ECs) as well as encouraging participation in A-APMs. That means CMS will publish results next year, spelling out the winners and losers of the program. Did a hospital incur penalty? Did it break even? Did it get an incentive?
The performance results can be a great indicator of where a health system should focus attention next year. Since 2017 was the first year for MIPS, only four percent of Medicare Part B payments are at risk an EC or group of ECs. In 2018, that increases to five percent, and the determination of incentives and penalties will include calculation of the new cost category.
Attesting to Meaningful Use Stage 3
2018 will likely be the first year we see a Meaningful Use Stage 3 attestation. They’ll have the flexibility to choose any 90 days next year in which to attest. If they choose, they can stick with Stage 2 in 2018 – but they’ll still need to be ready for Stage 3 starting January 1, 2019.
Here are some things health systems can work on now to make sure they’re are ready to start their reporting period:
- Complete the 2015 CEHRT project. This is a must before beginning the reporting period in 2019.
- Train and educate end users regarding new workflows. There are some high measurements for Stage 3, so focusing on adoption and performance monitoring will be crucial.
- Have a plan in place for when a patient asks, "Can I use this app to access my records?" No matter the application, health systems will need to be able provide patients with access.
- Plan out your health information exchange (HIE) objective by walking through the request/accept and clinical reconciliation measures. Many providers enter the process planning to use transition of care (ToC) and request or accept as their measures for HIE, but leave the process going with ToC and clinical reconciliation.
Value-based care opportunities
Health care organizations should begin or continue exploring the value-based care opportunities available like CPC+ or Accountable Care Organizations (ACOs). The list of alternative payment models and voluntary bundle payments will continue to grow in 2018 – and CMS uses the Centers for Medicare and Medicaid Innovation (CMMI) to create, announce and maintain VBC programs.
Thanks to the Meaningful Use program, the technological foundation of EHRs has evolved to support the free flow of information from one health care system to another. Because of the continued increase in national and state spending on health care, as well as a rise in Medicare and Medicaid-covered patients, we can expect federal and state lawmakers and organizations like CMS and ONC to continue pulling their levers to achieve the quadruple aim of health care.
Though CMS is still learning and progressing in its APM journey, CMS isn’t the only payor moving down the road of VBC. Payors across the spectrum, from commercial insurance, to Medicare Advantage, to Medicaid, and even TRICARE are on the same journey. We are all reading the maps and finding our paths. The journey won’t be easy, but if we can achieve the quadruple aim, the journey will be worth it.
If a health care organization is in need of regulatory guidance, the Regulatory Compliance team at Cerner is here to help. We have created a regulatory consumption machine and are well-equipped to provide high value advisory services that fit every organization. Contact us today to learn more.
In 2018, Cerner Regulatory Compliance is hosting our 8th annual Regulatory Alignment Summit events in Kansas City. These educational and strategic planning sessions will equip organizations with the information needed to get ahead in 2018. Register to attend one of the five free sessions here:
All five summits are open to Cerner Millennium clients. We recommend that Cerner Soarian clients attend the March 21-22 event for the most relevant information.