HIMSS Submits Comment Letter on MACRA Final Rule

In a December 19th letter to Andy Slavitt, Acting Administrator of the Centers for Medicare and Medicaid Services (CMS),HIMSS offered it comments to the  Medicare Program; Merit-Based Incentive Payment System (MIPS) and Alternative Payment Model (APM) Incentive Under the Physician Fee Schedule, and Criteria for Physician-Focused Payment Models Final Rule.

HIMSS appreciates the content of the Final Rule and the reduction in the number of required measures and the flexibility provided to practices to select the measures that they believe best represents their patients’ needs.  HIMSS welcomes the additional pathways in the Final Rule to participate in Advanced Alternative Payment Models (APMs).  HIMSS notes that the simplification of the quality components of the program and alignment of the measurement of certified electronic health record (EHR) technology (CEHRT) with quality will further ensure that certified EHRs are being used to support high-quality care. 

HIMSS does note that while CMS will be working annually on Quality Payment Program (QPP) modifications the possible two-month window between publication of a final rule and a January 1 start date of the next performance period will not allow vendors and eligible clinicians (ECs), those reporting as groups, and APMs the appropriate implementation timelines necessary for systems to be updated and for the appropriate care delivery workflows to be developed and incorporated for the purpose of accurate data capture for any electronic clinical quality measures (eCQMs) that were not part of purchased certified EHR Technology systems.

HIMSS does note that it is disappointed in the limited role given to these technologies within the MIPS framework.

HIMSS remains committed to fostering a culture where health IT is optimally harnessed to transform health and healthcare by improving quality of care, enhancing the patient experience, containing cost, improving access to care, and optimizing the effectiveness of public payment.