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If MACRA Fails, It Will Be a Failure of IT, Not Doctors or Regulators

Posted on August 8, 2016 I Written By

The following is a guest blog by Steve Daniels, president of Able Health.

There has been a whole lot of mudslinging over the last month between regulators and healthcare providers over MACRA, which shifts Medicare payments further toward pay-for-performance starting January 1. On the one hand, CMS Acting Administrator Andy Slavitt is clear that CMS is ready for change. “We need to get out of the mode of paying physicians just to run tests and prescribe medicines,” he told a Senate Finance Committee hearing. Meanwhile, Dr. Thomas Eppes of the American Medical Association has called MACRA a “quantum shift” and pushed for a delay.

Yes, the Medicare Quality Payment Program instituted by MACRA should—and will—evolve based on comments made on the proposed rule. But the reality is the program provides enormous opportunity for providers to increase bonus payments, while streamlining reporting requirements across a patchwork of outdated and duplicative programs. And it’s worth noting that the potential penalties under the Merit-Based Incentive Payment System (MIPS) over the next four years are actually lower than the sum of the penalties of the programs it is replacing.

To meet MACRA goals, it will take a well-prepared team of providers and administrators—empowered by data and well-designed tools. Doctors can’t be solely responsible for achieving patient outcomes, reducing costs and documenting it all for CMS as they go. Unfortunately, the history of health IT has not been kind—or affordable—to doctors. And today, the health IT stack has a new challenge—keeping pace with the proliferation of value-based programs, from accessing data all the way through enabling new clinical practice.

We must move from a mindset of meeting Meaningful Use checkboxes toward supporting a more effective way of operating. And in the modern world of software-as-as-service, there’s no good reason left that IT needs to cost providers millions of dollars. We can do better. As things stand, if MACRA fails, it will be a failure of IT, not doctors or regulators.

Gathering all the data

For value-based care to work, patient data needs to be made available for providers to coordinate with each other, as well as to payers, to properly evaluate performance based on all known information. Those still blocking or jacking up prices for data access are complicit in obstructing the vision of a learning value-based system.

It is time to remove technical barriers through modern and open data standards like FHIR, as well as rules and unreasonable fees that prevent parties from accessing data when they need it. Thankfully, the Advancing Care Information performance category will reflect the emphasis on information exchange set forth in Meaningful Use Stage 3.

Calculating performance flexibly

The new era of performance-based pay requires continuous monitoring of quality and cost, with the ability to track progress across multiple programs on an ongoing basis. To measure quality today, we often use static algorithms hard-coded by EHRs vendors and health system IT departments, conforming to standards set by NCQA or CMS.

But providers need tools that are tailored not just to one or two programs like Meaningful Use and PQRS, but across the organization’s full range of value-based programs as these program continue to expand, evolve, and proliferate. With efforts to standardize IT for quality measures stalling, vendors need to focus less on one-size-fits-all quality measure calculations and more on flexible systems that enable measures to be rapidly constructed and customized to move with the trends. Expect change to be the norm.

Informing new behaviors

With so many health IT professionals focused on gathering and reporting data, it is not surprising that design has taken a back seat so far. But this year, not a single population health vendor earned an “A” rating from Chilmark, due to poor user engagement and clinical workflow. This is no longer acceptable. The challenge of enabling the new clinical and administrative behaviors associated with value-based care is too vast. User experience must be top of mind for any IT implementation, with representative users involved from the start. We have seen the impact of poor user experience in the fee-for-service system, from frustrated clinicians to alarming patient safety issues.

Design is even more important when the challenge is not just documenting billing codes but also achieving health outcomes for patients across a care team. Don’t bombard clinicians with notifications and force clumsy form-filling. Instead, employ best practices from cognitive psychology to inform professionals with lightweight and intelligent touchpoints. Automate documentation and interpretation of data wherever possible.

A new era of health IT

Whether or not it’s delayed, the Quality Payment Program is coming. And the healthcare industry is moving inexorably toward value-based care. Will health IT step up to the challenge of building toward a value-based future that is accessible to all providers? Or will we sit back and wait for the next list of requirements?

About Steve Daniels
Steve Daniels is the President of Able Health, which helps providers succeed under MACRA and value-based programs. Formerly the design lead for IBM Watson for healthcare and a lifelong patient advocate, he is passionate about the role of open data exchange and intuitive experience design in fostering a continuously improving healthcare system. Find him on Twitter and LinkedIn.

2 Major Problems with MACRA

Posted on May 4, 2016 I Written By

John Lynn is the Founder of the blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of and John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Everyone’s started to dive into the 10 million page MACRA (that might be an exaggeration, but it feels about that long) and over the next months we’ll be sure to talk about the details a lot more. However, I know that many healthcare organizations are tired of going through incredibly lengthy regulations before they’re final. Makes sense that people don’t want to go through all the details just for them to change.

As I look at MACRA from a very high level, I see at least two major problems with how MACRA will impact healthcare.

Loss of EHR Innovation
First, much like meaningful use and EHR certification, MACRA is going to suck the life out of EHR development teams. For 2-3 years, EHR roadmaps have been nothing but basically conforming to meaningful use and EHR certification. Throw in ICD-10 development for good measure and EHR development teams have basically had to be coding their application to a government standard instead of customer requests and unique innovations.

Just today I heard the Founder of SOAPware, Randall Oates, MD, say “I’m grieving MACRA to a great degree.” He’s grieving because he knows that for many months his company won’t be able to focus on innovation, but will instead focus on meeting government requirements. In fact, he said as much when he said, “We don’t have the liberty to be innovative and creative.” And no, meeting government regulations in an innovative way doesn’t meet that desire.

I remember going to lunch with a very small EHR vendor a year or so ago. I first met him pre-meaningful use and he loved being able to develop a unique EHR platform that made a doctor more efficient. He kept his customer base small so that he could focus on the needs of a small group of doctors. Fast forward to our lunch a year or so ago. He’d chosen to become a certified EHR and make it so his customers could attest to meaningful use. Meaningful use made it so he hated his EHR development process and he had lost all the fire he’d had to really create something beautiful for doctors.

The MACRA requirements will continue to suck the innovation out of EHR vendors.

New Layers of Work With No Relief
When you look at MACRA, we have all of these new regulations and requirements, but don’t see any real relief from the old models. It’s great to speak hypothetically about the move to value based reimbursement, but we’re only dipping our toe in those waters and so we can’t replace all of the old reimbursement requirements. In some ways it makes sense why CMS would take a cautious approach to entering the value based world. However, MACRA does very little to reduce the burden on the backs of physicians and healthcare organizations. In fact, in many ways it adds to their reporting burden.

Yes, there was some relief offered when it comes to meaningful use moving from the all or nothing approach and a small reduction in the number of measures. However, when it comes to value based reimbursement, MACRA seems to just be adding more reporting burdens on doctors without removing any of the old fashioned fee for service requirements.

MACRA is not like ICD-10. Once ICD-10 was implemented you could see how ICD-9 and the skills required for that coding set will eventually be fully replaced and you won’t need that skill or capability anymore. The same doesn’t seem to be true with value based care. There’s no sign that value based care will be a full replacement of anything. Instead, it just adds another layer of complexity, regulation, and reporting to an already highly regulated healthcare economic system.

This is why it’s no surprise that many are saying that MACRA will be the end of small practices. At scale, they’re onerous. Without scale, these regulations can be the death of a practice. It’s not like you can stop doing something else and learn the new MACRA regulations. No, MACRA is mostly additive without removing a healthcare organization’s previous burdens. Watch for more practices to leave Medicare. Although, even that may not be a long term solution since most commercial payers seem to follow Medicare’s lead.

While I think that CMS and the people that work there have their hearts in the right place, these two problems have me really afraid for what’s to come in health IT. EHR vendors the past few months were finally feeling some freedom to listen to their customers and develop something new and unique. I was excited to see how EHR vendors would make their software more efficient and provide better care. MACRA will likely hijack those efforts.

On the other side of the fence, doctors are getting more and more burnt out. These new MACRA regulations just add one more burden to their backs without removing any of the ones that bothered them before. Both of these problems don’t paint a pretty picture for the future of healthcare.

The great part is that MACRA is currently just a proposed rule. CMS has the opportunity to fix these problems. However, it will require them to take a big picture look at the regulation as opposed to just looking at the impact of an individual piece. If they’re willing to focus MACRA on the big wins and cut out the parts with questionable or limited benefits, then we could get somewhere. I’m just not sure if Andy Slavitt and company are ready to say “Scalpel!” and start cutting.

Meaningful Use Is Going to Be Replaced – #JPM16

Posted on January 12, 2016 I Written By

John Lynn is the Founder of the blog network which currently consists of 10 blogs containing over 8000 articles with John having written over 4000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 16 million times. John also manages Healthcare IT Central and Healthcare IT Today, the leading career Health IT job board and blog. John is co-founder of and John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit and LinkedIn.

Big news came out today during the JP Morgan annual healthcare conference in San Francisco. Andy Slavitt, acting administrator of CMS, live tweeted his own talk at the event including this bombshell:

Technically meaningful use is not quite over, but it’s heading that way. We always read about lame duck head coaches in sports. I guess this is the version of a lame duck government program? Of course, this is just coming from the acting administrator of CMS. It’s not yet law. So, all those working on meaningful use reports, keep working.

The end of meaningful use as we know it will be generally welcome news to most in healthcare. Although, I’m sure that most will also take it with a grain of salt. Many in healthcare likely worry that the “something better” that replaces meaningful use and MACRA will actually be something worse. The cynics might argue that nothing could be worse, but I’ve never seen the government back down from that challenge.

What interests me is what levers they have available to them to be able to make changes. Can they do it without congressional action? Are doctors angry enough that congress will take action? What will happen to the remaining $10-20 billion allocated to meaningful use? What will hospitals and doctors that were counting on the meaningful use money do? Will they not get it anymore or will it be available in a new program? Obviously, there are more questions than answers at this point.

All in all, I’m glad to hear that Andy Slavitt is open to change. I suggested they blow up meaningful use a couple years ago.

Andy also did a tweetstorm to outline the 4 themes for reforming the MACRA and post-MU tech program:

These all seem surprisingly reasonable and mirror many of the comments I hear from doctors. However, the challenge is always in the implementation of these ideas. Some of them are very hard to track and reward. I can’t argue with the principles though. They highlight some of the major challenges associated with healthcare tech. It’s going to take some time to infuse entrepreneurship instead of regulation back into the EHR world, but these guidelines are a good step towards that effort.

UPDATE: Here’s the full text of Andy Slavitt’s talk at the JP Morgan Healthcare Conference.