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Following a tumultuous period of change in the US healthcare IT market, the US Government Centre for Medicaid and Medicare (CMS) has provided initial guidance on how the next period of e-Health adoption will be managed (https://blog.cms.gov/2016/04/27/moving-toward-improved-care-through-information/) “Meaningful Use”, the much criticised multi-stage reimbursement component that led to rapid deployment and growth of the enterprise Electronic Medical Record (EMR) market, is set to be replaced by a new law, the “Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)”.
The new MACRA bill has a lengthy (over 1000 pages) technical explanation of the mechanics of how it will be implemented, covering all aspects of Medicare physician payment. For the vast majority of Medicaid physicians, the Merit-based Incentive Programme (MIPS) is due to commence payment adjustments from 2019, with surveillance beginning in 2017. The overall MIPS reimbursement plan has some intriguing pointers as to the main foci for the CMS, namely:-
- Maintaining data quality over quantity of data and greater focus on outcomes
- Driving better clinical practice
- Increasing data exchange between physicians
- Data security
- Increasing patient engagement and access to data
There are a huge volume of technical details for physicians and Health IT vendors to digest; however, the “Meaningful Use” component focused on EHR has remained relatively unchanged, albeit under a new name; the “Advancing Care Information” (ACI) component. The ACI essentially replicates the majority of defined Meaningful Use Stage 3 measures (though it drops the CPOE and CDS components which already show high adherence from Stage 2) apart from offering more flexibility with optional components including reporting into public and clinical data registries, and electronic case reporting.
While only covering single or small groups of physicians initially (hospital Medicare and all Medicaid payment schedules are yet to be addressed), there will undoubtedly be a number of market implications.
The Signify View
Unless there is a major position shift from the CMS in the forthcoming Medicare and Medicaid hospital proposals, a massive market shock is unlikely – we’re not expecting anything like the merger and acquisition activity of health providers that was seen with implementation of Meaningful Use.
In the outpatient EMR market, the most impacted by the recent CMS proposal, continued adoption and market growth should be seen in the next 3 years. Upgrades and replacements of existing systems to more advanced systems will be common, with the focus of the proposal on increasing patient engagement, access and ingestion of patient generated data, features that are more prevalent in high-featured EHR. Solutions with advanced data exchange capabilities will also help spur uptake.
The new proposal also offers some headaches for health IT software vendors, health providers and physicians. These include:-
- Data exchange security, especially with greater patient access
- Measurement of data exchange quality (although more guidance is expected from the CMS on this shortly)
- How to ingest patient generated data from third-party hardware and software
- Vendors surrendering “control” of patient data from proprietary solutions to enable exchange
While none are “game-changers” in driving vendors out of business, many are increasingly important as the maturity and adoption of EHR increases. Furthermore, this new scheme will undoubtedly change the modus operandi of the industry. Expect to see a greater ability of physicians to change EMR vendor as proprietary barriers fall, more inter-vendor partnerships and a raft of specialist acquisitions by EMR vendors of companies in patient engagement, health information exchange and cybersecurity. Additionally, the CMS decision to make submission of data to clinical and patient registries optional suggests there is little desire to drive population health management at a public or macro-scale anytime soon. Instead, it would appear the much anticipated population health management and analytics era will be left to the private market for the immediate future.
Moreover, the new CMS proposal also has connotations for digital health technology adoption, especially with the greater focus on patient engagement and use of patient-generated data. While still a hugely contentious area for physicians and providers given the possible legal implications and limited experience of ingesting into a longitudinal electronic patient record, the ongoing swell of personal health monitoring and telemedicine innovation enabled by digital health devices will push towards more uptake. As a result, also expect a greater number of health IT and digital health partnerships to occur in the coming years.