Fee Schedule Proposes Changes to Quality Reporting, EHR Requirements

CMS is proposing that all MIPS participating clinicians submit quality data on six measures from medical specialty−specific quality measure sets. If finalized, this proposed change would mean that physicians cannot select measures from different specialty sets. However, psychiatrists do not have to select from the proposed Mental/Behavioral Health Specialty Measure Set if there is another set that better meets their patients’ needs. Once a psychiatrist selects a particular measure set, he or she must use that set for the remainder of the MIPS performance year.

CMS is proposing to incrementally remove process measures that they determine are “low value” from the quality performance category. This is intended to allow room for quality measures that provide greater meaning to patients and their providers. However, it could be problematic for psychiatrists if a number of measures deemed to be low value are ones that psychiatrists commonly use. Included among those proposed for removal is one that measures the percentage of patients with depression or bipolar disorder assessed for substance use disorder. Should this measure be removed from the Mental/Behavioral Health Specialty Measure Set, the set will not include any measures that address substance use other than alcohol and opioids.

All eligible professionals (EPs) must now use 2015 Edition Certified Electronic Health Record Technology (CEHRT). This is a change from the first two years of the program that allowed eligible providers to use 2014 CEHRT or a combination of 2014 and 2015 CEHRT. Psychiatrists should check with their EHR vendor to ensure that they meet the 2015 standard. There are already a limited number of psychiatry-specific, certified EHRs available (for a complete list, visit the ONC’s Certified Health IT Product List https://chpl.healthit.gov/#/search), so limiting participants in MIPS to 2015 products may reduce reporting options for reporting year 2019.

The “Advancing Care Information” category of MIPS (formerly known as the “Meaningful Use” program) has been renamed “Promoting Interoperability.” For reporting year 2019, CMS proposes requiring fewer measures under this category. Also, the scoring methodology has been changed to eliminate reporting thresholds and, instead, uses one that is performance based. This will give psychiatrists participating in MIPS greater flexibility in reporting under this category and will help to avoid a downward payment adjustment in 2021.

CMS proposes two new measures for the Promoting Interoperability: Query of Prescription Drug Monitoring Program and Verify Opioid Treatment Agreement. If included in the 2019 MIPS Final Rule, these measures would be optional under the e-prescribing measure, and reporting on them would earn MIPS participants up to 5 bonus points for each measure. ■