Is CMS Still Serious About Patient Engagement?

• On 14th October 2016, the Centers for Medicare & Medicaid Services (CMS) released its Final Rule implementing the Medicare physician payment reforms enacted as part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)
• The Advancing Care Information (ACI) performance category is one of four key performance categories included within MACRA, and is a key driver for the patient engagement platform market in the US
• In CMS’ original draft proposal, published in May 2016, there were 11 required measures that made up ACI, many of which would cement patient engagement functionality as a central component of Certified Electronic Health Record Technology (CEHRT).
• In the Final Rule the number of required measures has been reduced to five. The requirements around patient engagement being the ones that have taken the brunt of the reduction, as illustrated below.

The Signify View

Four of the measures that have been dropped from the required list are measures that had patient engagement at their heart. These were:

• CEHRT driven patient-specific education
• Patient view, download or transmit (VDT) CEHRT health data to a 3rd party
• Patient-provider secure eMessaging via CEHRT
• Patient-generated healthcare data (PGHD) incorporated into CEHRT

The remaining ones that have a focus on patient-provider communication relate more to simple portal access and ePrescriptions, which represent only the tip of the iceberg in terms of the possibilities that patient engagement platforms can offer. The other remaining required measures all focus on ensuring that data exchange between different providers/public health authorities is well supported, so have a limited impact on driving patient engagement solutions.

So on the face of it, it would appear that the CMS’ drive to put patient engagement at the heart of MACRA has been significantly watered down with this Final Rule.

This is further reinforced when considered that a transition year has also been introduced, that results in only four of the five required measures being reported on in 2017, that the reporting period be only 90 days instead of a full year, and that for many of the measures the provider is only required to report on one unique patient to hit the target!

Devil is in the Detail

However, as you dig into the detail on the ACI measures, it becomes apparent that the structure of the measures will mean that MACRA will still act as a significant driver for the patient engagement platform market.

For one, the ‘required’ measures will contribute to only a maximum of 50% of the base score a provider needs to hit to receive the full reimbursement quota related to ACI. In order to push this to the upper ceiling of 100% (more is technically possible), the provider also needs to be addressing a selection of other ‘optional’ and ‘bonus’ measures. The aforementioned patient engagement measures that were dropped from the ‘required’ list make up four of these twelve ‘optional’ and ‘bonus’ measures that providers can choose from.

The reality is that many providers will still report on these other four measures and build in platforms to their CEHRT that provide the functionality to do so. And as the provider will already have invested in a patient engagement platform in order to meet the ‘required’ measures, Signify Research believes that in the majority of cases the provider will continue to focus on the patient engagement-centric measures, such as secure messaging and VDT to 3rd parties, when selecting the optional measures to report on. Similarly, the 90-day reporting period and single patient reporting element are also expected to have only a minimum impact on the platform market. Healthcare providers still need to be building the platforms and functionality into their CEHRT solutions to address this requirement, and once done are likely to then continue to maximise the use of these platforms.

Therefore, ultimately the measures will still have the effect of driving provider uptake of patient engagement platforms; albeit potentially with lower licencing revenues than the original ruling would have resulted in.

New Market Report from Signify Research Publishing Soon

This and other issues will be explored in full in Signify Research’s upcoming market report ‘Patient Engagement Platforms & Portals – World Market Report 2017‘, publishing in February 2017. For further details please contact Alex.Green@signifyresearch.net