Physicians talked, CMS listened
Through the rulemaking process and other initiatives, CMS has engaged in extensive outreach with physicians and other stakeholders to solicit feedback on QPP implementation, and that was evident in its proposal for year two.
In a press release announcing the proposed rule, CMS Administrator Seema Verma reaffirmed the agency’s commitment to working with physicians and other health care providers to improve policies and reduce clinician burden: “We’ve heard the concerns that too many quality programs, technology requirements, and measures get between the doctor and the patient. That's why we're taking a hard look at reducing burdens. By proposing this rule, we aim to improve Medicare by helping doctors and clinicians concentrate on caring for their patients rather than filling out paperwork.”
The American Association of Clinical Urologists (AACU) has been quite vocal about the burden of MACRA on urologists and the many implementation difficulties they face. As such, it has submitted extensive comments voicing these concerns on past MACRA-related proposed rules, including the QPP implementation policy for the 2017 performance period, voicing these concerns.
Among the policies finalized in the 2017 QPP rule, one of particular concern for the AACU related to the adoption of Certified EHR Technology (CEHRT). The final 2017 QPP rule gave physicians the option to use either the 2014 or 2015 Edition of CEHRT, or a combination of both. But starting in 2018, physicians would no longer have this option and instead would be required to use only the 2015 Edition CEHRT.
However, as the AACU and other urology organizations have pointed out, very few vendor products meet the 2015 certification criteria required for approval by the government-mandated Health IT Certification Program. As such, many urologists worry that requiring the 2015 Edition CEHRT starting in 2018 would unfairly subject them to financial penalties or force them to file for hardship exceptions due to unavailable vendor products.
In response to this negative feedback from the provider community, CMS proposed to continue allowing MIPS-eligible physicians to use either the 2014 or 2015 Edition CEHRT in 2018, granting a bonus to physicians using only the 2015 Edition CEHRT in 2018 as opposed to penalizing those who do not.