Stage 3 comments: ACP says 'recast MU under MIPS'

Meaningful Use (MU) is a significant component of the Merit-Based Incentive Payment System (MIPS) but both will fail without substantial changes, according to the American College of Physicians (ACP) in its comments to the Centers for Medicare & Medicaid Services about the MU Stage 3 final rule. Unlike several other organizations, ACP is not seeking an MU stop or delay. 

“To be successful in a value-based payment system, clinicians need to successfully accomplish in a very short time what MU was supposed to have done: have us focus on meaningfully using health IT to make care operations efficient and effective, and have us intently focus on quality, safety and cost,” said Peter Basch, MD, chair of ACP’s medical informatics committee. 

“Very few docs and other clinicians, even those friendly to the goals of MU--such as the ACP--could say that most docs are anywhere near where they should be in regards to engagement with their EHRs and health IT--such that they are ready for MIPS,” he added. 

In its comments, ACP offers a way to “recast MU, such that it, along with the PQRS and VBM programs, can become a useful and usable unified program under MIPS.”

Much of what had to be done at the beginning of MU is no longer necessary, according to ACP. Now that there are clinical quality measures, MU incentives are no longer needed to pay for performance of highly defined EHR use measures. “We believe the time is right to reverse that approach--and the structure of MIPS makes this possible,” said Basch.

MU inside of MIPS should contain no thresholds for EHR functional use measures, he said, because thresholds have led to clinical workarounds. “EHR functional use measures can continue, as long as they are not overly prescriptive, as they can provide learnings for how health IT is used and can be used in different settings of care and by different specialties,” he added.

MU inside of MIPS can include requirements for continuing education to be collaboratively developed by government agencies and relevant medical specialty and professional societies.

MU inside of MIPS should support relevant quality and cost measures, as well as practice improvement activities. MU inside of MIPS should not layer on additional requirements, especially highly defined EHR use measures that distract attention from patients and patient care.  Meaningful Use is a significant component of the Merit-Based Incentive Payment System (MIPS) but both will fail without substantial changes, according to the American College of Physicians.

“To be successful in a value-based payment system, clinicians need to successfully accomplish in a very short time what MU was supposed to have done: have us focus on meaningfully using health IT to make care operations efficient and effective, and have us intently focus on quality, safety and cost,” said Peter Basch, MD, chair of ACP’s medical informatics committee. 

“Very few docs and other clinicians, even those friendly to the goals of MU--such as the ACP--could say that most docs are anywhere near where they should be in regards to engagement with their EHRs and health IT--such that they are ready for MIPS,” he added. 

In its comments, ACP offers a way to “recast MU, such that it, along with the PQRS and VBM programs, can become a useful and usable unified program under MIPS.”

Much of what had to be done at the beginning of MU is no longer necessary, according to ACP. Now that there are clinical quality measures, MU incentives are no longer needed to pay for performance of highly defined EHR use measures. “We believe the time is right to reverse that approach--and the structure of MIPS makes this possible,” said Basch.

MU inside of MIPS should contain no thresholds for EHR functional use measures, he said, because thresholds have led to clinical workarounds. “EHR functional use measures can continue, as long as they are not overly prescriptive, as they can provide learnings for how health IT is used and can be used in different settings of care and by different specialties,” he added.

MU inside of MIPS can include requirements for continuing education to be collaboratively developed by government agencies and relevant medical specialty and professional societies.

MU inside of MIPS should support relevant quality and cost measures, as well as practice improvement activities. MU inside of MIPS should not layer on additional requirements, especially highly defined EHR use measures that distract attention from patients and patient care.