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IPPS Final Rule - Inpatient Medicare Promoting Interoperability Overview

Yesterday, CMS dropped their final rule on the Inpatient Payment System (IPPS). Looking at the aspects dealing with the Promoting Interoperability program, everything is mostly finalized as projected from its NPRM, but I will summarize it here.

It should be noted that this rule focused on the inpatient side of the Promoting Interoperability program for eligible hospitals (EHs) and critical access hospitals (CAHs) and not for eligible providers (EPs). This gets confusing given just last month CMS proposed many of these same changes for the EPs in their PFS NPRM.

First, they did finalize the name change from the “EHR Incentive Program” to “Promoting Interoperability” (which will be shortened to “PI” for this post).

Second, they set the reporting period for the PI measures to 90-continuous days in CY 2019 and CY 2020 and confirmed only 2015 Edition CEHRT can be used.

Third, they followed through with the streamlining of measures. In CY 2019, there are six required measures with two bonus/optional e-prescribing related measures (Querying PDMP and Verify Opioid Treatment Agreement). The measures are listed below. The Support Electronic Referral Loops by Receiving and Incorporating Health Information measure is technically a new measure, but it is really just combining the very similar the Request/Accept Summary of Care measure and the Clinical Information Reconciliation measure into one measure. VDT, secure messaging, and patient-generated health information measures are now dropped.

In CY 2020, the PDMP measure becomes required, but the verify opioid treatment agreement measure will remain bonus/optional for CY 2020. Regarding these new eprescribing related measures, CEHRT capabilities must be used. For Querying PDMP, CMS believes the existing 2015 Edition criteria, specifically in the e-Prescribing criterion (315.b.3), contains the necessary functionality to complete the requirements in these measures. However, CMS acknowledge some additional rulemaking could provide some better support for these measures, such as automatic PDMP querying within EHRs.

For Verify Opioid Treatment Agreement, CMS acknowledges the minimum requirements within CEHRT is somewhat lacking to fully meet this measure, which is one reason it is optional through CY 2020. However, CMS believes some C-CDA based exchanges from 2015 Edition CEHRT can be used in meeting this measure. Expect to see ONC offer guidance to help on these e-Prescribing measures in its own NPRM coming this fall.

Within the public health measure, two of those measures must be met. CMS did state that claiming an exclusion to a registry measure, for example electronic case reporting is not possible for a EH or CAH due to its lack of a local registry, can count as one of the measures in meeting requirement. Previously, these excluded public health measures would not count if another public health measure was available.

One change from the NPRM is they had proposed to require syndromic surveillance measure to be met, but they have backed that down and now are just asking for any two of the registry measures to be satisfied.

Fourth, they did change the scoring system to determine who qualifies as a “meaningful EHR user”. Since the beginning of the program, EHs and CAHs had to meet certain threshold numbers for a specific measure (e.g. 50% of unique patient had X completed) to pass that measure, and enough measures had to be “passed” in order to qualify. Now, each measure is given a point value or weight and the score of each measure is multiplied by its weight and then added together. The total score must exceed 50 to then qualify as a “meaningful EHR user” and avoid negative penalty adjustment.

It should be emphasized that even with the minimum 50-point scoring threshold that all required measures must be reported on to qualify. This includes the Security Risk Analysis. For example, even if the scoring in the non-public health measures is greater than 50 but the EH does not report “yes” on two of the public health measures then the EH does not meet the requirements to be a “meaningful EHR user” and thus will receive a negative payment adjustment.

These changes to the PI measure scoring are only required for the Medicare side of the PI program. However, states have the option, and in fact are encouraged, to change their reporting requirements for their Medicaid reporting to align with Medicare reporting.

Finally, they finalized their proposal to reduce the number eCQMs to report to eight down from the existing sixteen beginning in the CY 2020 reporting period which aligns with the Hospital IQR Program requirements.

In terms of submission for CY 2019 reporting period, the rules are basically the same as in this current CY 2018 reporting period. EHs and CAHs are required to submit electronically but can still submit via attestation if electronic submission is not feasible. For electronic submission, EHs and CAHs can report on four of the self-selected CQMs for one calendar quarter. For attestation, the reporting period is calendar year on all sixteen measures.

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