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IHS and Electronic Health Record Incentive Programs

by CDR Mark Rives, D.Sc., Chief Information Officer

I have been receiving some questions from Tribal health facilities and Urban Indian Health Programs about the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs Exit Disclaimer: You Are Leaving . These clarifications might be helpful to administrators and health care providers within the Indian health system.

On January 11, 2016, Mr. Andy Slavitt, the Acting Administrator for the Centers for Medicare & Medicaid Services (CMS), gave a speech at the J.P. Morgan Health Care Conference in San Francisco Exit Disclaimer: You Are Leaving  during which he highlighted the CMS agenda for 2016. In his comments, he mentioned how the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) consolidates several existing Medicare quality reporting programs - including the EHR Incentive Program - into the Merit-Based Incentive Payment System (MIPS).

A subsequent blog post Exit Disclaimer: You Are Leaving  Mr. Slavitt and Dr. Karen DeSalvo, National Coordinator for Health IT and Acting Assistant Secretary for Health, provided further clarifications on the guiding principles for this transition. I'd encourage you to read the full post for more details, but here are key excerpts:

What Comes Next

. . . All of this work will be guided by several critical principles:

  1. Rewarding providers for the outcomes technology helps them achieve with their patients.
  2. Allowing providers the flexibility to customize health IT to their individual practice needs. Technology must be user-centered and support physicians.
  3. Leveling the technology playing field to promote innovation, including for start-ups and new entrants, by unlocking electronic health information through open APIs - technology tools that underpin many consumer applications. This way, new apps, analytic tools and plug-ins can be easily connected to so that data can be securely accessed and directed where and when it is needed in order to support patient care.
  4. Prioritizing interoperability by implementing federally recognized, national interoperability standards and focusing on real-world uses of technology, like ensuring continuity of care during referrals or finding ways for patients to engage in their own care. We will not tolerate business models that prevent or inhibit the data from flowing around the needs of the patient.

What This Means for Doctors and Hospitals

As we work through a transition from the staged meaningful use phase to the new program as it will look under MACRA, it is important for physicians and other clinicians to keep in mind several important things:

  1. The current law requires that we continue to measure the meaningful use of ONC Certified Health Information Technology under the existing set of standards. While MACRA provides an opportunity to adjust payment incentives associated with EHR incentives in concert with the principles we outlined here, it does not eliminate it, nor will it instantly eliminate all the tensions of the current system. But we will continue to listen and learn and make improvements based on what happens on the front line.
  2. The MACRA legislation only addresses Medicare physician and clinician payment adjustments. The EHR incentive programs for Medicaid and Medicare hospitals have a different set of statutory requirements. We will continue to explore ways to align with principles we outlined above as much as possible for hospitals and the Medicaid program.
  3. The approach to meaningful use under MACRA won't happen overnight. Our goal in communicating our principles now is to give everyone time to plan for what's next and to continue to give us input. 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.
  4. In December, Congress gave us new authority to streamline the process for granting hardship exception's under meaningful use. This will allow groups of health care providers to apply for a hardship exception instead of each doctor applying individually. This should make the process much simpler for physicians and their practice managers in the future. We will be releasing guidance on this new process soon . . . .

IHS, Tribal and Urban Indian Health Programs have realized significant benefits from the EHR Incentive Programs, including financial benefits and new capabilities for our health care providers and patients. IHS remains committed to the meaningful use program and to the planned MACRA implementation.

The IHS Office of Information Technology (OIT) is currently evaluating both the EHR Incentive Program-Stage 3 and Modifications to Meaningful Use in 2015 through 2017 final rule Exit Disclaimer: You Are Leaving  and the 2015 Health Information Technology Certification Criteria final rule Exit Disclaimer: You Are Leaving  to identify the potential impacts on policy, clinical and administrative workflow and IT systems. OIT will be engaging IHS, Tribal and Urban Indian Health Program stakeholders in this effort as well as we proceed with detailed planning and analysis.

It is critical that all Eligible Professionals, Eligible Hospitals, Critical Access Hospitals, and supporting staff in the Indian health system continue to focus on achieving Meaningful Use. CMS has provided a summary of the 2015 program requirements online Exit Disclaimer: You Are Leaving .

Additional resource information from CMS' EHR Incentive Program can be found at Exit Disclaimer: You Are Leaving 

MACRA The Merit-Based Incentive Payment System (MIPS) & Alternative Payment Models (APMs): Exit Disclaimer: You Are Leaving 

If you have questions about IHS's efforts please email the OIT meaningful use team.

To stay up to date on developments with the IHS meaningful use program, join the meaningful use LISTSERV email group.

CDR Mark Rives is the Chief Information Officer for the Indian Health Service. He holds a Doctor of Science degree in Information Systems and Communications as well as a Master degree in Computer Information Systems.

CDR Mark Rives, D.Sc., Chief Information Officer