Disclaimer: Dr. Weinstein authored this article in his personal capacity. The views expressed are his own and do not necessarily represent the views of Falcon, LLC, DaVita Physician Solutions or DaVita, Inc.
We recently announced certification changes to Falcon Silver, and as of January 1, 2018, Falcon Silver will not be a Certified EHR Technology (CEHRT).
This change was made to reflect changes in the CMS quality payment program (QPP), and I think it is important to examine how these regulatory and technological changes will impact our Falcon Silver users in 2018.
With the transformation from Meaningful Use to MACRA/QPP’s Advancing Care Information (ACI) the requirements for calculating quality metrics (and receiving payment penalties or bonuses based on these metrics) have changed.
Because of the differences between MU and ACI, the DaVita Physician Solutions team (formerly Falcon Physician) believes that spending further time and effort on maintaining CEHRT for Falcon Silver is not the best investment for our resources. We believe that our patients and our users are best served if we are able to refocus these resources on building a better tool for caring for dialysis patients. No longer maintaining certification for Falcon Silver will also provide us the opportunity to focus on dialysis-focused quality metrics that support our shared goal: the clinical care of our patients.
Under MACRA/QPP, providers can use any amount of data from patient encounters documented with a certified EHR, even if that data represents only a minority of their total encounters. This change to Falcon Silver will not impact provider’s ability to collect data for the ACI category in any other certified EHR, such as their office platform. Even though Falcon Silver won’t be a certified EHR platform in 2018, patient encounters documented in locations with Certified EHRs can be used for ACI reporting.
Under Meaningful Use, CMS used the “50% rule” to determine if a provider could qualify for hardship exemption from the program or not. Specifically, this meant clinicians were eligible for a hardship exemption if greater than 50% of their outpatient encounters occurred in service locations without CEHRT, and the decision whether or not to use a certified platform was out of the clinician’s control (e.g. when rounding at a hospital, the requirement to use the hospital’s non-certified software). If a clinician was granted a hardship exemption, they were ineligible to receive either the meaningful use program’s potential bonus or penalty for that year.
Under MACRA/QPP, the hardship exemption for ACI does not eliminate bonus or penalty opportunities. If a provider chooses to apply for the QPP/ACI hardship exemption, the scoring weight of a provider’s MIPS categories shifts, making the ACI category worth zero points and increasing the relative value of the quality, resources use and improvement activity categories. Remember, without ACI the total MIPS composite score percentage is calculated with a denominator of 75 rather than 100 (removing the 25 points for ACI).
We are excited to be able to move forward with Falcon Silver and look forward to years of developing the best dialysis rounding tool possible.
(Also, please note: Falcon Platinum is and will continue to be a Certified Electronic Health Record in 2018. Encounters and data documented in Falcon Platinum will count toward QPP/ACI and users will have full access to all QPP scorecards)
For more QPP resources and regulatory information, visit:
About the Author:
Adam Weinstein, MD, is VP of medical affairs with Clinical IT Services at DaVita and a part-time clinical nephrologist in Maryland. He serves as the American Medical Association Relative Value Scale Update Committee (RUC) advisor for the Renal Physicians Association (RPA) and chairs the RPA clinical data registry workgroup.
Dr. Weinstein is a co-founder of the Kidney Health Center of Maryland. He has worked as VP of medical affairs at the University of Maryland, Shore Regional Health and has served on the Maryland Healthcare Commission and RPA board of directors. He completed his training in internal medicine and nephrology at the University of Maryland School of Medicine and University of Maryland Medical Center.