Earlier this quarter, CMS came out with a rule that establishes a new methodology for MIPS eligible providers and encourages eligible professionals to participate in APMs. Lantana supports several stages in the value-based purchasing information lifecycle, and we have a sharp interest in the success of these programs as a transformative agent for healthcare. Our response to this proposed rule focused on the quality performance category (Section II.A.3), with comments on quality measures, standardized reporting, and data accuracy promotion.

Lantana submitted a letter on October 30, 2015 in response to a request for information on the proposed rule for Implementation of the Merit-Based Incentive Payment System (MIPS), Promotion of Alternative Payment Models, and Incentive Payments for Participation in Eligible Alternative Payment Models from CMS and DHHS, which was open for comment between October 1st and November 2nd. The proposed rule sunsets program payment adjustments and consolidates parts of the PQRS, VM, and EHR incentive program. Under this program, CMS promotes the creation of APMs, provides incentive payments for eligible EPs participating in APMs, and encourages the development of PFPMs.

Our key recommendations included:

• A long and short term approach to standardizing reporting
• More outcome based measure creation
• Strategies for improving data accuracy
• Ways that data standards improve data integrity
• Approaches to reviewing and qualifying registries, QDRs, and health IT Systems
• Testing feedback recommendations

So much of our work at Lantana revolves around making interoperability a reality within a data-driven healthcare system. We hope to continue to improve the current strategies and approaches to quality reporting, as well as data accuracy and integrity.

Greater detail on these comments is available here .

Comments by other organizations are available here

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Acronyms:

APM     Alternative Payment Model

CMS     Center for Medicaid and Medicare Services

DHHS     Department of Health and Human Services

EHR     Electronic Health Record

PFPM     Physician Focused Payment Models

PQRS     Physician Quality Reporting System

VM     Value-Based Payment Modifier