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Christian Mibelli
Vice President
Government Affairs & Client Solutions

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The Centers for Medicare & Medicaid Services (CMS) recently posted a blog entry regarding the future of Meaningful Use (MU). While we try to interpret CMS’ statements to the best of our ability, understanding CMS’ future intentions is not always simple. With that in mind, here is our evaluation of the information published by CMS which is subject to change as new information is released.

What CMS’ Post States & What We Know Today:

• CMS has not stated that Meaningful Use is going away
  • As stated by CMS in their 1/19/16 post, “the current law requires that we continue to measure the meaningful use of ONC Certified Health Information Technology under the existing set of standards.”
  • “We encourage you to look for the MACRA regulations this year; in the meantime, our existing regulations – including meaningful use Stage 3 – are still in effect.”
• In the article CMS representatives state that changes are expected and that MU would be “improved”
  • CMS stated “we will continue to listen and learn and make improvements based on what happens on the front line.”
  • MU has been changed almost every year since creation, so additional proposed changes are nothing new.
• Congress passed MACRA in October 2015 which introduced the MIPS program (Merit-Based Incentive Payment System)
  • MACRA was passed with sweeping bipartisan support
    • Senate: 92 “yeas,” 8 “nays”
    • House: 312 Republicans voting “yea,” 33 voting “nay;” 180 Democrats voting “yea,” 4 voting “nay”
  • MIPS is expected to begin in 2017
  • MU is a portion of the MIPS program
  • In order for MU or MIPS to go away, it will literally require an act of Congress
  • While MIPS was passed as part of MACRA, the actual regulations and rules have not yet been published
    • TSI Healthcare will continue to monitor regulatory filings for additional details and will notify our clients when additional information is available

Click here to learn more about the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)

Brief MIPS Summary:

• MIPS is focused on combining programs to streamline payment adjustments and quality reporting
• It is based on a points system and providers can earn 0-100 points
  • PQRS/VBM = 60 points
  • Clinical Practice Improvement= 15 point
  • Meaningful Use = 25 points
    • Under the MACRA Key Principles, existing MU principles will likely stay the same in some form
• Based on the total points, CMS can then assess one single payment adjustment rather than separate payment adjustments as it does today
  • Today:  one payment adjustment for MU, one separate payment adjustment for PQRS, and another payment adjustment for VBM
  • Under MIPS:  one single payment adjustment that covers all areas of total performance.
• Again, while MIPS was passed as part of MACRA, the actual regulations and rules have not yet been published
  • We will notify our clients when additional information is available

It is important to keep in mind that MU may slightly change under MIPS, however the underlying principles of what providers are required to do today as part of Modified Meaningful Use will be part of that new transition. Additionally, CMS has clearly stated that existing regulations are still in effect. Ultimately, these kinds of quality performance programs are here to stay in some form as our health system continues the transition away from fee for service toward value based payments.

As your partner through this process, we are committed to offering our practices optional services and new offerings to assist with these federal programs.

Additional Resources:
Additional resources are available exclusively to TSI Healthcare clients at MU Central.

Visit www.tsihealthcare.com/mucentral

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