Deborah L. Benzil, MD, FACS, FAANS, AANS (right)
Chair, AANS/CNS Communications and Public Relations Committee
Mount Kismo Medical Group
Columbia University Medical Center
Mt Kisco, New York
Rachel Groman, Vice President, Clinical Affairs and Quality Improvement (left)
Hart Health Strategies
“We have to get the hearts and minds of physicians back…I think we’ve lost them.”
The AANS, CNS and all of neurosurgery applaud the important steps announced by the Centers for Medicare & Medicaid Services (CMS) in transforming EHR incentives for the benefit of our patients and quality patient care. Creating reasonable regulations for true meaningful use of electronic health records (EHR) has been a high priority for neurosurgery and all of organized medicine for many years. Recently, CMS announced its intent to use the Medicare Access and CHIP Reauthorization Act (MACRA) as an opportunity to shift away from what has been a deeply flawed strategy of incentivizing “meaningful use” of EHRs. Ongoing barriers persist, and we are hopeful that this change in strategy will help to address the current lack of specialty-relevant functionalities and measures, as well as interoperability, which continues to impede the meaningful use of these technologies.
Before any of this can succeed, CMS must ensure that EHR systems resolve essential cornerstones necessary for data exchange including:
- Development of standardized data elements;
- Addressing barriers related to privacy and security; and
- Minimizing data blocking.
CMS must focus primarily on increasing the functional interoperability between vendors and among vendors and registries before holding physicians accountable for these activities. Unfortunately, the current federal “certification” process often limits the potential utility of EHR technology by constraining functionality to accommodate specific measurements, calculations, and arbitrary thresholds.
Since meaningful use is a significant component of MACRA’s Merit-based Incentive Payment System (MIPS) — accounting for 25 percent of a physician’s total performance score — it is critical that CMS make changes to refocus the program and to ensure that meaningful use is achievable and useful for all physicians, including specialists. The current pass-fail nature of the program fails to recognize the diversity of clinical practices and patient populations and is just unsustainable. Going forward, physicians should have the flexibility to demonstrate meaningful use in an accumulative fashion, receiving points for incremental efforts that are most relevant to their practice.
It is equally critical that meaningful use measures be redesigned to focus on clinically relevant information, rather than processes and data entry. Rather than emphasizing counting and thresholds, measures should focus on whether data is accessible and usable. As part of this process, we urge CMS to recognize better physician participation in a clinical data registry as an activity that supports the goals of meaningful use. CMS also should collaborate with national specialty societies to develop health IT-enabled alternatives or pilots that could be optionally used to satisfy the meaningful use component of the MIPS composite score.
In the future, meaningful use should continue to provide protections so as not to penalize physicians based on circumstances largely beyond their control — such as subspecialty/scope of practice, location/setting, health information exchange (HIE) network availability, and patient population.
Organized neurosurgery has and will continue to work with CMS to offer insights on how to create a meaningful interoperable system that benefits patients and quality patient care.