Healthcare: How the CIO & C-Suite Can Lead Strategy In a MACRA World

How Healthcare CIO’s & The C-Suite Can Take the Lead With MACRA

With MACRA being released October 14, this provides an opportunity for CIO’s and CMIO’s to “be the business”. MIPS, the dominant payment framework has four parts and we list seven topics below that CIO’s, CMIO’s, the C-Suite, and productive board members need to know. We hope this provides a framework for you to initiate and define a series of meetings in your organization to drive consensus and shared ownership for your strategy, and more importantly execution plans. Here you can see what we’ve advised to physician leaders with respect to tackling MACRA, both the Quality and Advancing Care Information portions together accounting for 85% of MIPS in 2017.

Healthcare Informatics gives pointers on where to focus and they encourage you to “try to estimate what your MIPS baseline score is based on the rules in the final rule. You can leverage your existing PQRS [Physician Quality Reporting System] and meaningful use data to get a read on Quality and ACI, which are now 85 percent of the score since they set cost equal to 0 percent under MIPS. Also, look at what practice improvement activities seem attractive to you.”

Further, they highlight that CMS proposes three options for providers subject to MIPS [Merit-Based Incentive Payment System] in 2017, the easiest of which providers can meet by reporting a single metric. CMS has also raised the low-volume threshold, exempting more small practices from MIPS. “Pathways range from sending in only some data into the Quality Payment Program; to sending in more data but for a reduced period of time; to “going all in” for an advanced APM.”

MACRA immediately impacts physicians though it is a signal for what’s to come for all providers generally. I have pasted what we feel is a helpful infographic below illustrating these four items of MIPS. The Quality portion (biggest at 50%) is replacing the following:

A) Physician Quality Reporting System

B) Value Modifier Program

C) Medicare Electronic Health Record (EHR) Incentive Program.

From CMS Executive Summary on MACRA

According to Becker’s Hospital CFO, “CMS is allowing some third party intermediaries to submit data on behalf of clinicians to help alleviate the burden associated with reporting under MIPS. The article also infers that for strategic planning purposes, to the degree that the health system wants to keep independent surrounding practices alive “Small practices are going to need to start thinking about virtual groups soon because in 2018 they will need to be in those groups, ready to compete amongst larger practices and hospital-based practices.”

credit: Physician Sentry

Below are the seven topics worthy of your focus:

  1. Physician Network Plans Awareness: Physicians can choose to start between Jan-Oct 2017 and their data needs to be submitted by March 2018. The CIO & C-Suite will want to know what their physicians are planning and would be wise to be helpful and look to partner to shape decisions based on current and imminent technological capabilities.
  2. Quality improvement: replaces PQRS and value modifier; physicians report 6 measures (instead of 9). A CIO and your peers can review your institution’s quality metrics with your CMO to identify high priority areas that can be targeted for technology enabled workflow improvements. CMS plans to use historical PQRS data as quality benchmarks for 2017. Select measures here that best fit your physicians’ practice
  3. Advancing Care Information: This is replacing meaningful use. One important aspect for a CIO to know is that EMR’s will have to be accountable to certification standards to “share data” to support use of health information. From Becker’s Health IT: “The U.S. Office of the National Coordinator for Health Information Technology has issued the final rule on its Health IT Certification Program. The final rule, slated to be published Wed., Oct. 19, focuses on increased accountability, oversight and transparency for certified health IT products. The rule includes a regulatory framework for ONC to review certified health IT products and a commitment to publishing the surveillance results of these products. “Today’s final rule strengthens the program by ensuring that certified health IT helps clinicians and individuals use and exchange electronic health information safely and reliably,” said Vindell Washington, MD, national coordinator for health IT. “More transparency and accountability in health IT is good for consumers, physicians and hospitals.” Review of page 7 in this CMS Fact Sheet is essential to understand ACI.
Credit, P.768 of the published MACRA final rule
  1. Clinical Improvement: The CIO, CMIO, and team can align with physicians (and whomever is the head of Safety) on which of the 90 activity choices will be picked to focus on in areas of patient engagement, patient safety, and care coordination.
  2. Tie Your Investments to P&L: CIO’s and to some degrees, CMIO’s and CMO’s are being challenged to be business partners beyond the great technology and clinical partners you are today. To that end, consider if you aren’t already, reviewing payer contracts to see which service lines can be positively impacted by, or hampered by current and future Health IT.
  3. Review this CMS Fact Sheet For MACRA: Pages 5 & 7 are essential to review payment adjustments and Advancing Care Information in Detail. For the advanced “business oriented” CIO, pages 11 & 12 can also be reviewed.
  4. Measurement On Cost Timing: According to Becker’s Hospital CFO, during the first year of MIPS 2017, providers will not be evaluated on cost. Here, there is a newer CMS fact sheet which is helpful for additional context.

Please let me know how we could have made this more clear or anything important to be considered. We can’t wait to see how you shape your organization’s future!

If you are a Medigram adviser, customer, investor, partner, or otherwise part of our support network and you have a question about the legislation, final rule, and parts of MIPS and APM’s, here is the link. Let us know if you still have questions that we can help answer for you.

For advanced providers, Becker’s Health CFO outlines here Advanced Payment Models:

“The following models will qualify as advanced APMs in 2017:

  • Comprehensive End Stage Renal Disease Care Model, Large Dialysis Organization and non-LDO arrangement
  • Comprehensive Primary Care Plus
  • Medicare Shared Savings Program ACOs, Tracks 2 and 3
  • Next Generation ACO Model
  • Oncology Care Model, two-sided risk arrangement”