As announced in the final rule in November, starting in 2018, a new reimbursable Improvement Activity is being added to the Centers for Medicare and Medicaid Services' Merit-based Incentive Payment System (MIPS), which encompasses using digital tools to monitor patients outside the hospital. Three digital health companies that worked with the CMS to bring about the change weighed in today on the news.
“Patient-generated health data is a valuable tool in patient care,” Anne Weiler, cofounder and CEO of Wellpepper said in a statement. “We’re pleased that CMS has recognized this, and is enabling the collection and analysis to be used in demonstrating quality patient care.”
MIPS is a part of the CMS Quality Payment Program created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). It allows eligible physicians to receive payment adjustments by reporting performance around the four categories of quality, advancing care information, cost, and improvement activities. This was the first year of the program and the guidelines are being tweaked for next year.
To report improvement activities, physicians must choose from a list of 93 activities. The new one in question is “Engage Patients and Families to Guide Improvement in the System of Care.” It will encompass remote monitoring as well as reviewing and interpreting patient-generated health data, provided the physician uses clinically-endorsed tools that include an active feedback loop. That means the system has to return some kind of actionable information to the patient or care team.
“It's not enough to want providers to expand care beyond the four walls of the office, it’s about empowering consumers and updating all parts of the system," Michael Sturmer, Livongo's SVP of health services, said in a statement. "The new CMS MIPS Improvement Activity further connects digital health with providers and care practices and is a significant advancement in making digital health part of the fabric of the healthcare experience. It is better for patients and providers, and that's better for all of us.”
Wellpepper, a provider of personalized, digital treatment plans; HealthLoop, which makes a care coordination system that helps physicians automatically check in with their patients; and Livongo, a chronic condition management company starting with diabetes management, all lobbied CMS for the change and were also involved in a recent CMS roundtable on patient-generated health data.
The three companies authored and submitted the proposal to CMS in February, according to a blog post by HealthLoop CMIO Ben Rosner, who says he originally came up with the idea.
"As I reviewed the more than 90 Improvement Activities, ... I noticed that there wasn’t an activity that captured the essence of patient engagement — leveraging digital tools for ongoing guidance and assessments outside the clinic, including the collection and use of [patient-generated health data]," he wrote. "The closest existing Improvement Activities were related to the use of a Qualified Clinical Data Registry (QCDR) to capture patient health data. While valuable, merely collecting medical and/or clinical data through a QCDR for the purposes of improvement in the quality of care is a far cry from engaging with patients outside of the care setting through contextual guidance, and an active feedback loop."
Rosner says that while reimbursement is a big motivator, he hopes providers will embrace remote patient monitoring for other reasons as well.
“For clinicians already using a patient engagement platform, these efforts will help satisfy the Improvement Activities category and earn 10 Advancing Care Information bonus points," Rosner said in a statement. "Eligible clinicians must simply attest to completing the activity for at least 90 days to meet 2018 reporting requirements. Financial incentives aside, engaging with patients is the right thing to do. Practices using automated patient engagement solutions see reduced readmission and complication rates, lower call center volume, better online ratings for physicians, and, most important, happier, healthier patients.”
Of course, those three companies weren't the only ones that pushed for the proposed rules change. The Connected Health Initiative, a coalition of industry stakeholders, put out a statement at the time the rules passed mentioning that they also submitted a similar proposal.
“Previous CMS rules created serious disincentives for doctors to consider using new technologies," CHI Executive Director Morgan Reed said in a statement at the time. "Together with our advisory board, CHI pushed for newly enacted rules that finally level the playing field for innovators, giving doctors and patients the chance to take advantage of the best technologies available."