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Nation’s clinical informatics professionals urges CMS to orient MVPs towards outcomes of interoperability

In comments submitted to the Centers for Medicare and Medicaid Services (CMS), the American Medical Informatics Association (AMIA) largely supported proposals to amend some documentation requirements and create a new participation pathway for the Merit-based Incentive Payment System (MIPS). However, AMIA cautioned CMS that the proposed changes to the documentation requirements are still not sufficient to decrease documentation burden. The group also urged CMS to go beyond the numerator/denominator measurement paradigm in the new participation pathway.

In late July, CMS published its CY2020 Physician Fee Schedule proposed rule, which details requirements for Medicare physician payments for non-hospital providers, as well as the Quality Payment Program (QPP), under which MIPS and Alternative Payment Models (APMs) are administered. While much of the program remained unchanged or is aligning with what was finalized for hospitals earlier this year, CMS proposed adopting revised E/M code definitions developed by the AMA CPT Editorial Panel. Further, CMS proposed a new MIPS participation framework, “MIPS Value Pathways (MVPs).” This framework aims to align and connect measures and activities across the Quality, Cost, Promoting Interoperability, and Improvement Activities performance categories of MIPS for different specialties or conditions.

AMIA hailed the E/M coding proposals to remove history and physical exam requirements and the option to document using time or medical decision-making (MDM) as “the greatest opportunity medicine has had to re-think how the patient’s story is captured and conveyed for care continuity.” It however cautioned that (1) reimbursement incentives and fears of audit will continue to perpetuate the practice of over-documentation; (2) data capture and documentation solutions are immature and more closely resemble adaptation of paper-based forms than true alternatives; (3) compliance with CMS quality and payment programs will continue to hamper EHR usability and compel atypical workflows; and (4) a whole generation of clinicians know of no other way to tell the patient’s story, but through E/M guideline requirements, drop down menus, and cut/paste functionality. To address these concerns, AMIA recommended that CMS support the development of IT-enabled documentation solutions and work with specialty societies develop both best practices and model notes for MDM and time-based billing.

AMIA additionally supported the goal of the MVP framework to simplify MIPS, improve value, reduce burden, help patients compare clinician performance, and better inform patient choice in selecting clinicians. It pointed out, however, that MVPs also provide an opportunity for CMS to modify the Promoting Interoperability performance category to focus on the outcomes of health IT, rather than measuring its use.

“As experience with EHRs grows and functions/standards evolve,” AMIA wrote, “we no longer see need for a numerator/denominator measurement paradigm for health IT use.” AMIA thus recommended that CMS orient MVPs as a way to measure the outcome of interoperability through eCQMs and certified health IT-enabled Improvement Activities.

“CMS is already thinking creatively about how to reduce provider burden, but that’s only one part of the equation,” said AMIA President and CEO Douglas B. Fridsma, MD, PhD, FACP, FACMI. “These proposals also give us the additional and unique opportunity to show why our nation-wide investment in certified health IT was worth it.”

Click here for AMIA’s full response to the CY2020 Physician Fee Schedule proposed rule.



AMIA, the leading professional association for informatics professionals, is the center of action for 5,500 informatics professionals from more than 65 countries. As the voice of the nation’s top biomedical and health informatics professionals, AMIA and its members play a leading role in assessing the effect of health innovations on health policy, and advancing the field of informatics. AMIA actively supports five domains in informatics: translational bioinformatics, clinical research informatics, clinical informatics, consumer health informatics, and public health informatics.