As CMS Promotes Interoperability, EHR Takes Center Stage

Ever since the Centers for Medicare & Medicaid Services (CMS) introduced the Merit-Based Incentive Payment System (MIPS) in 2017, the provider community has raised many questions regarding the potential impact. With the move to value-based care, physicians are no longer reimbursed only on a fee-for-service model. Instead, providers must now report on four primary measures—quality (50 percent), cost (10 percent), improvement activities (15 percent), and interoperability (25 percent). While all four buckets will be important moving forward, CMS has recently placed particular emphasis on interoperability through its “Promoting Interoperability” (PI) initiative. Because of these changes and the increasing emphasis on interoperability and standardized reporting, your EHR system and the data that reside in it are more important than ever before.

The Path to Interoperability and Practice Performance Improvement

In April 2018, CMS announced it would overhaul the EHR Incentive Program, including renaming the Meaningful Use program and the MIPS Advancing Care Information performance category into the consolidated “Promoting Interoperability.” With its new Interoperability program in place, CMS affirms its position that the future of value-based reporting will depend on the industry’s ability to create and adopt interoperable EHR systems and at least some degree of standardized reporting.

With CMS making regular updates, dermatology practice leaders should remain current on relevant federal requirements with regard to interoperability and value-based reporting. This will help ensure that they advance quality care, while also running a successful practice and furthering the industry as a whole. Consequently, it’s also increasingly important that dermatologists select the right EHR partner to share in the effort to navigate, and even educate about, these shifting regulations.

Picking an EHR that Promotes Interoperability

With the right EHR and data, physicians can benchmark their performance against that of their peers and monitor how their practice performs compared to the rest of the industry. At strategic and tactical levels, this insight can empower them to both meet CMS requirements and run a more efficient and profitable organization. So, what questions should dermatologists ask their current or prospective EHR vendors, particularly as it relates to interoperability and quality-based reporting?

Does your software have the latest certification (EHR 2015 CEHRT)?

As a result of recent changes, CMS will likely require providers to use 2015 edition certified EHR technology (CEHRT) in 2019 to demonstrate meaningful use and qualify for federal incentive payments. The updated technology—from 2015 and after—includes the use of APIs, which have the potential to improve the flow of information between providers and patients. With this next level of integration, patients could collect their health information from multiple providers and potentially incorporate all of their health information into a single portal, application, program, or other type of software.

Does your EHR support dermatology-specific quality measures and/or registries?

Dermatologists need an EHR vendor that will work closely with them to gather input in order to help build appropriate data collection. With so much emphasis being placed on quality reporting for hospitals and primary care, it is essential to work with an EHR company with dermatology in its DNA. Familiarity and/or integration with dermatology specific registries can go a long way to ensure you aren’t being forced into quality measures that pertain to another area of medicine.

How are you addressing CMS changes on the backend of your EHR?

Having a built-in MIPS platform within an EHR that is constantly updated to reflect changes to CMS regulations can virtually automate quality reporting. It can help dermatologists to gather, track, benchmark, and submit data across all four of the primary measures set forth by MIPS. It’s also important to identify an EHR vendor that provides top notch customer support and enhanced advisory services for that extra treatment. Finally, while an easy-to-use system can ease the burden of reporting for providers and staff members, an EHR vendor that can assist with manual reporting when necessary is key.

How does your EHR interact with other systems, if at all?

If you’re unsure how your current EHR vendor interacts with other systems, ask. Next-generation EHR providers deploy numerous strategies to help further interoperability and improve physician workflows.

You also should ensure that a prospective EHR supports third-party APIs. The inclusion of APIs enables connectivity across vendors and platforms for virtually unlimited exchange of data, be it quality measures or other patient information. With a system like this you should be able to share data with all stakeholders, be it CMS, private insurers, other physicians or your patients. This improved communication can help your patients receive the right care at the right time.

Is your EHR server-based or cloud native?

Cloud-based—or Software-as-a-Service (SaaS)—technologies tend to be more flexible and typically require less upkeep or administrative effort from the practice. Cloud-based systems are also easier to update, making them beneficial for navigating updated regulations. A vendor may be able to update their SaaS EHR system overnight. In such instances, providers could utilize the updated version of the software when they turn on their iPad or desktop computer before seeing their first patient.

On-premise—or server-based—systems require a more robust IT infrastructure, which typically requires a technical person employed or outsourced by the practice to maintain the software. In addition, in most cases this technical staff must manually update all of the hardware in the practice each time the vendor releases a new version. Finally, because patient data is stored on-site using a server-based system, data storage, back-up, and recovery is the responsibility of the provider.

What are the costs associated with switching and is it worth it?

Costs for switching to and from any EHR system can vary. That said, if you’re even considering making the switch, research all of your options. Understand what issues and qualities of an EHR system are most important to your practice and providers, whether that’s built-in MIPS functionality, customer service, inventory management, telehealth, an integrated practice management system, or revenue cycle management services. By understanding your practices’ clinical, operational and financial goals, you can make a more informed decision when it comes to your EHR provider. Also, ask around to see what your peers use. They can give you a better sense of who they used before, what system they use now, why they switched, and how their practice has benefited from the switch.

Looking Ahead: Regulatory is Improving; Still a Work in Progress

Historically, regulatory changes specific to health technology have been challenging, because many times the individuals making the regulatory decisions aren’t actually involved in EHR development. So, while they are generally well intentioned, they simply don’t understand the complexities of what they would call “simple” changes. The good news is CMS increasingly understands how much effort it takes for vendors, like Modernizing Medicine, to effectively implement the changes in policy within their systems.

With all that said, the regulatory landscape can frequently be updated, so there should be a balance between meeting today’s requirements and anticipating tomorrow’s requirements. At the same time, providers should not lose sight of their goals of high quality patient care and building a successful practice, while also reducing time-consuming administrative burdens. Interoperability is challenging, but once we identify how to organize and open up the lines of communication among systems more efficiently, it should help to improve outcomes for providers and their patients. The task of increased interoperability doesn’t have to fall on one stakeholder in healthcare and should be viewed as a collaborative endeavor. As it continues to become more widely implemented, make sure you understand how and if your EHR can help your practice.

Ida Mantashi is Director of Product Management at Modernizing Medicine (modmed.com). With over 18 years of technical experience, her work at Modernizing Medicine focuses on building the compliance capabilities of EMA™, the company’s specialty-specific electronic health record (EHR) system.

In addition to her full-time role at Modernizing Medicine, she acts as Chair of the EHRA Quality Measurement Workgroup.