Yesterday CMS released their annual NPRM for Inpatient Prospective Payment System (IPPS) for acute care hospitals and long-term care hospitals, and they used the opportunity to propose several changes to Meaningful Use Program. Read on to see what has changed.
A rose by any other name...
First, they are renaming the official name to EHR Incentive Program to Promoting Interoperability (PI). All Medicaid incentives end by CY 2021 so it make sense to drop the “incentive” part, but I agree with Dr. Reider that a better name can be chosen. It looks like they also change the MIPS category of Advancing Care Information to Promoting Interoperability as well.
Of their changes, they largely follow in the vein of modifying Medicare PI to be more like MIPS ACI PI category. CMS continues to try and align these programs.
2015 Edition Only with 90-day Reporting Period
Looking to the CY 2019 reporting period, CMS clearly states they that only 2015 Edition CEHRT will be allowed. This is not a change in policy and same as in MIPS, but it should remove any doubts about the need to get certified on 2015 Edition now rather than later.
Another change mirroing that of MIPS is reflected in declaring that the reporting period for Medicare PI in both CY 2019 and CY 2020 to be a consecutive 90-day period which is what MIPS is doing, at least in CY 2019. This is applicable both for eligible providers and eligible hospitals. Thus, the “deadline” to get your EHR certified to 2015 Edition is end of September 2019.
Change in Measure Lineup
Before going any further, it should be noted that these changes discussed below are for the hospital reporting aspect of the Promoting Interoperability program. CMS did request comment if these changes should be made to the objectives and measures for eligible professionals (EPs) in the Medicaid Promoting Interoperability Program. Of course, most clinicians on the ambulatory side are more impacted by MIPS reporting which is not addressed in this rule.
A rather telling change is reducing of measures. Under the proposal, Stage 3 measure would be reduced to a smaller set of objectives covering only e-Prescribing, Health Information Exchange, Provider to Patient Exchange, and Public Health and Clinical Data Exchange. This takes the number of required measures to report from 16 to 6 in CY 2019 and focus more on the priorities of interoperability and patient access.
Some of the measures have been “removed” by essentially combining them into a new measure. Request/Accept Summary of Care and Clinical Information Reconciliation measures would be replaced by the Support Electronic Referral Loops by Receiving and Incorporating Health Information measure which combines the required functionality. This does make sense as those two measures had too much overlap.
Four of the measures – Patient-Specific Education; Secure Messaging; View, Download or Transmit; and Patient Generated Health Data – would be removed. CMS indicates they have heard from health care providers that these measures are burdensome and not beneficial.
Three new measures are being proposed: Query of Prescription Drug Monitoring Program (PDMP), Verify Opioid Treatment Agreement, and the aforementioned Support Electronic Referral Loops by Receiving and Incorporating Health Information. The new prescription-based measures are reflective on the administration's focus on the opioid-related health harms.
Two measures are staying the same functionality but given a new name.
Send a Summary of Care -> Support Electronic Referral Loops by Sending Health Information
Provide Patient Access to Provide Patients -> Electronic Access to Their Health Information
Here is the CMS provided summary of the proposed measure changes.
Modified Measure-Scoring to More Mimic MIPS
Another proposed change is moving away from a pure threshold scoring methodology to a more flexible one similar to MIPS. Hospitals will have up to 100 possible points to score on in their measures, but they only need to exceed 50 points to meet the meaningful EHR user definition required to avoid payment adjustments.
Different measures wll have different weighted values. In CY 2019, the two new prescription measures will work like bonus points to allow hospitals and developers time to implement, but they will be in normal measures in CY 2020.
In Public Health reporting, only two measures will be required for submission, and the only measure required is Syndromic Surveillance. What is more interesting is CMS indicated they would like to completely drop the Public Health and Clinical Data Exchange objective and measures no later than CY 2022 and are seeking public comment back on this plan.
Below are material from CMS on what the measures scoring methodology will be along with an example. CMS did provide some clarification on when exclusions on certain measures, like e-Prescribing, are claimed how their points would be redistributed.
Request for Comment on Two Additional Measurse
CMS is requesting comment on possibly adding two additional measure:
Support Electronic Referral Loops by Sending Health Information Across the Care Continuum
Support Electronic Referral Loops By Receiving and Incorporating Health Information Across the Care Continuum
This would basically be measuring data exchange from entities other than an eligible hospital or CAH. CMS seems particularly interested in supporting exchanges with long-term care and post-acute care settings, skilled nursing facilities, and behavioral health settings.
Request for Comment on Support of TEFCA
CMS is requesting comment on making hospitals support of participating in ONC's Trusted Exchange Framework and Common Agreement (TEFCA) effort a credit wihin the the Health Information Exchange objective in lieu of reporting on measures for this objective. I think they have to do something like that if they are going to gain adoption for TEFCA, and it makes sense to reduce this redunacy of implementation.
PI-Medicaid is Set by States
Both the scoring and modified measure list is only affecting the Medicare-based PI. “Medicaid-only” eligible hospitals would follow their state’s Medicaid HIT Plans, although states can choose to adopt this new scoring methodology used in Medicare. Hopefully states will choose to align with the CMS Medicare scoring to make it simplier for both developers and hospitals.
CMS continues to pursue alignment of their programs and within the PI reporting of CQMs, they want to align with the Hospital IQR. For CY 2020, their proposal is to drop eight of the current sixteen CQMs leaving only eight to report. The CQM reporting period would be one, self-selected calendar quarter of CY 2019 data.
For CY 2019, the sixteen existing CQMs would be eligible for use although CMS seems to open up request for comments on dropping down to eight in CY 2019 as well.
For CY 2019, they are proposing reporting for a one, self-selected calendar quarter for Medicare PI. As before the states in the Medicaid PI can determine their own reporting periods.
So What Does This Mean
Obvious disclaimer, this is only proposed and not final and thus all subject to change, but assuming it does become final as is, what is the real impact to EHR developers (at least those targetting hospitals)?
The most obvious is adding support for the measures, specifically the two new prescription-based measures. I will be curious to see if ONC adds any new criteria related to this in the upcoming proposed rule supporting Cures. Developers will need to plan to update their measure dashboard reporting to support the new measures.
Related to that, developers should look to see how to best implement and improve their e-prescribing workflows, especially with controlled substances, and also their health information exchanges. These are going to be priorities for the government, and they have large support from providers and hospitals as well.
Some measures and by effect their associated ONC criteria have been elevated in importance (Syndormic Surveillance) and others diminished (Patient-Generated Health Data). I will be interesting to see if CMS still keeps the PGHD criteria (e.3) as required for CEHRT status given this.
However, the key rule is still to come. When the ONC proposed rule comes out this month or next, it will give direction on TEFCA, interoperability, information blocking, and other features which will provide direction for next health IT activities needed for government compliance.