Promoting Interoperability Program Update - CY 2020 IPPS Proposal
Lost amid the ONC release of its 2nd draft of TEFCA and extending the comment period on the Cures proposal, CMS released its annual Inpatient Prospective Payment System (IPPS) rule, and they used it to update their requirements for the Promoting Interoperability (PI) program for hospitals.
This proposal does not address the MIPS program for eligible professionals, but it is for the hospitals in their PI (i.e., the old Meaningful Use) program. However, I think eligible clinicians should still take note of these proposals as CMS has made a concentrated effort to align their PI and MIPS programs. Last year’s changes to measures and CEHRT requirements for PI in the hospital’s IPPS rule were basically the same changes proposed in the MIPS rule. Thus, what CMS is stating here is likely to go into the upcoming MIPS annual rule proposal.
The quick take away is that not much is changing. The PI measure reporting period is still 90 days and likely will be for the foreseeable future. The measures themselves are largely the same with just one of the Verify Opioid Treatment Agreement bonus measure getting dropped. CQM reporting is mostly the same with a few tweaks and a roadmap laid out through CY 2023.
The most notable change on the PI measures is that CMS is proposing to restrict the activity which counts in the numerator to events occurring only within the reporting period. Previously, CMS indicated that numerator is not constrained to the EHR reporting period unless expressly stated in the numerator statement. FAQ 8231 clarifies this past position.
However, CMS is now looking to change this where “both the numerators and denominators of measures in the Medicare Promoting Interoperability Program would only increment based on actions that have occurred during the EHR reporting period that was selected by the eligible hospital or CAH.” If this is accepted, it would force a change on to developers in their measure reporting as the current ONC test data permits for events outside the reporting period as long as they are within the calendar year.
Beyond that, the biggest effort done in this PI proposal is not for specific measures or program rules but with CMS requests for information (RFI) on several different topics CMS is considering and seeks industry feedback. I counted eight different RFIs on a range of topics, several addressing topics proposed in recent ONC Cures proposal.
Below is a bullet list of the other changes or suggestions CMS is putting forth.
CMS believes that there are no Medicaid-only eligible hospitals or “dually-eligible” hospitals still able to receive funding in the Medicaid Promoting Interoperability program based on industry feedback. The funding for that aspect of the program ends in CY 2021, and CMS still makes reference to the program as it still exists in theory, but it is very likely that it is practically speaking over.
Some minor clarity on the Support Electronic Referral Loops by Receiving and Incorporate Health Information measure is provided. CMS explicitly states that the denominator activity (receiving the electronic summary record) and the numerator activity (reconciliation for medication,medication allergy, and current problem list) must be done by the CEHRT certified capabilities.
Clarified both optional eRx measures are worth 5 full points, not just “up to 5 points” in CY 2019. Thus, you get 5 points for having just 1 in the numerator.
Query of PDMP measure will again by optional in CY 2020 and eligible for 5 bonus points. Query PDMP goes from numerator/denominator to just yes/no attestation. A “yes” response would indicate that for at least one Schedule II opioid electronically prescribed using CEHRT during the EHR reporting period, the eligible hospital or CAH used data from CEHRT to conduct a query of a PDMP for prescription drug history, except where prohibited and in accordance with applicable law. However, because currently there are not standards-based interfaces between CEHRT and the PDMPs, health care providers may manually track the number of times that they query the PDMP outside of CEHRT.
The Verify Opioid Treatment Agreement measure is being dropped from the Promoting Interoperability Program beginning with the CY 2020 EHR reporting period. They are dropping the measure for several reasons including confusion on specifications as well as how to measure the 30-day look back activities.
As previously stated in last year's rule, CMS is dropping 8 of their CQMs to align with the Hospital IQR program. That leaves 8 remaining hospital CQMs for CY 2020: ED-2, PC-05, STK-02, STK-03, STK-05, STK-06, VTE-1, VTE-2.
In CY 2021, CMS proposes to add two new measures associated with opioids: (1) Safe Use of Opioids – Concurrent Prescribing CQM (NQF #3316e); and (2) Hospital Harm – Opioid-Related Adverse Events eCQM.
CMS does expect CEHRT to be certified to all eCQMs which means these two new measures would need to be certified.
The PI CQM reporting for CY 2020 and CY 2021 remains as it is in CY 2019:
If electronically reporting, report on one calendar quarter for four self-selected CQMs from the set of available CQMs.
If reporting via attestation because electronic is not feasible, report on all CQMs from the set of available CQMs for full calendar year.
For CY 2022, CMS proposes a slight change in reporting. The new option is reporting on one, self-selected calendar quarter of data for: (a) three self-selected CQMs from the set of available CQMs; and (b) the proposed Safe Use of Opioids – Concurrent Prescribing CQM (NQF #3316e), for a total of four CQMs. If electronic reporting is not available, report on all CQMs from the set of available CQMs for full calendar year.
For CY 2023, CMS is proposing to not allow any more attestations but only accept electronic submission.
As mentioned, CMS has several RFIs included seeking feedback on a variety of ideas and activites. Some highlights:
RFI on future direction of the opioid CQMs.
RFI on changing the Patient Access measure to be no later than 1 business day instead of the current 4 business days. The idea is based on the growth of APIs and general expectation that electronic health data can be made available almost instatenous to it being recorded and approved by the clinician.
RFI on whether to add bonus points in their measure scoring for early adoption of a certified FHIR API in ONC's proposed 315.g.10 criteria.
RFI on adding the newly proposed EHI Export criteria (315.b.10) as part of the Patient Electronic Access measure objective, either required or bonus measure.
RFI on bring back patient-generated health data measures in some means. They were dropped last year.
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