Proposed Changes to Meaningful Use Focus on Interoperability, Access
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4.26.2018 Mari Savickis – VP, Federal Affairs |
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Brad Simonich – Coordinator, Public Policy |
The Centers for Medicare and Medicaid Services (CMS) released late Tuesday their draft rule for 2019 Inpatient Prospective Payment Systems (IPPS) that reflects the agency’s desire to increase interoperability across the healthcare system and facilitate patients’ access to their health information. The CHIME public policy team and the Public Policy Steering Committee are currently reviewing the proposed rule to assess the impact on providers and hospitals. In the meantime, we will provide a breakdown of key elements that may affect members. Those include:
- Renaming of the Medicare and Medicaid EHR Incentive Programs to Promoting Interoperability Programs
- Continuing the use of a 90-day EHR reporting period in both 2019 and 2020
- Maintaining the requirement to use the 2015 Edition CEHRT, beginning in 2019
- Implementing a new scoring methodology for eligible hospitals and critical access hospitals, beginning in 2019
- Adding two new opioid measures and one new health information exchange measure for bonus points
Promoting Interoperability Programs
CMS wrote that the proposed rule is shifting from its original focus with three stages targeting data capture and sharing, advanced clinical processes and improved outcomes to interoperability and improving patient access to health information. The renaming is designed to better reflect its current priorities.
“We believe this change will help highlight the enhanced goals of the program and better contextualize the program changes discussed in the following sections,” CMS wrote. “We also note that the former name, Medicare and Medicaid EHR Incentive Programs, does not adequately reflect the current status of the programs, as the incentive payments under Medicare generally have ended … and will end under Medicaid in 2021.”
90-day reporting period
Last year CMS eased policies for providers, recognizing more time was needed to secure vendor upgrades for moving to the 2015 Edition CEHRT and thus allowed continued use of 2014 CEHRT in 2018. The agency further adopted a 90-day reporting period rather than a full year for 2018 as originally planned. CMS now has proposed to offer EHR reporting of any continuous 90-day period within each of the calendar years 2019 and 2020 for new and returning participants attesting to CMS or a state Medicaid agency. The incentive payment year, payment adjustment years and deadlines for attestation would remain the same as established in prior rulemaking.
2015 Edition CEHRT
CMS wrote that they determined that it was appropriate to require the use of 2015 CEHRT beginning in 2019 because the 2014 Edition certification criteria were “out of date and insufficient for provider needs in the evolving health IT industry.” They argued that the 2015 Edition offered improvements that complemented CMS’s goals, including application programming interface (API) functionality and certification criteria critical for interoperable exchanges. In the past, CHIME has voiced concerns with APIs, including a lack of standardization and cybersecurity issues.
“We continue to recognize there is a burden associated with development and deployment of new technology, but we believe requiring use of the most recent version of CEHRT is important in ensuring health care providers use technology that has improved interoperability features and up-to-date standards to collect relevant patient health information,” CMS wrote. “The 2015 Edition includes key updates to functions and standards that support improved interoperability and clinical effectiveness through the use of health IT.”
New scoring methodology
This appears to one of the biggest changes under the rule’s proposal to overhaul the program. The performance-based scoring methodology is based on 100 possible points for an eligible hospital or critical access hospital. A score of 50 points or more would be sufficient to meet the program’s requirements while a score under 50 points would be insufficient and subject to penalties.
In moving away from a “pass-fail” policy, CMS appears to be exercising some of the flexibility made available to them through provisions of the continuing resolution passed earlier this year (and which funded the government through March 23). However, CMS has called for requiring providers to attest to having met the risk assessment which is required under HIPAA but that no points would offered for it. Yet, failure to attest would mean forfeiting any points for the entire Promoting Interoperability Programs. CHIME has long advocated for CMS to remove the pass-fail policy, including last year’s testimony to Congress by Board Chair Cletis Earle, who strongly recommended removal of this flawed policy.
CMS wrote that they were sensitive to providers’ need to become familiar with the new scoring methodology and measures, and EHR developers and vendors’ need for time to adequately test and incorporate the new scoring system and measures. They said that they recognized that it may take more than one year for hospitals to adjust.
Please see the tables at the end of this article for more information about the methodology.
New opioid measures
CHIME has made the reduction of opioid addiction and opioid-related deaths a top public policy priority. CHIME launched an Opioid Task Force to harness the healthcare IT knowledge and skills of members to address this national epidemic. The public policy team and some members of the task force will be examining the proposed measures to assess their feasibility and efficacy.
Proposed Performance-Based Scoring Methodology for EHR Reporting Periods in 2019
| Objectives | Measures | Maximum Points |
| e-Prescribing | e-Prescribing | 10 Points |
| Bonus: Query of Prescription Drug Monitoring Program (PDMP) | 5 points bonus | |
| Bonus: Verify Opioid Treatment Agreement | 5 points bonus | |
| Health Information Exchange | Support Electronic Referral Loops by Sending Health Information | 20 points |
| Support Electronic Referral Loops by Receiving and Incorporating Health Information | 20 points | |
| Provider to Patient Exchange | Provide Patients Electronic Access to Their Health Information | 40 points |
| Public Health and Clinical Data Exchange | Syndromic Surveillance Reporting (Required)
Choose one or more additional: Immunization Registry Reporting Electronic Case Reporting Public Health Registry Reporting Clinical Data Registry Reporting Electronic Reportable Laboratory Result Reporting |
10 Points |
Proposed Performance-Based Scoring Methodology Beginning with EHR Reporting Periods in 2020
| Objectives | Measures | Maximum Points |
| e-Prescribing | e-Prescribing | 5 points |
| Query of Prescription Drug Monitoring Program (PDMP) | 5 points | |
| Verify Opioid Treatment Agreement | 5 points | |
| Health Information Exchange | Support Electronic Referral Loops by Sending Health Information | 20 points |
| Support Electronic Referral Loops by Receiving and Incorporating Health Information | 20 points | |
| Provider to Patient Exchange | Provide Patients Electronic Access to Their Health Information | 35 points |
| Public Health and Clinical Data Exchange | Syndromic Surveillance Reporting (Required)
Choose one or more additional: Immunization Registry Reporting Electronic Case Reporting Public Health Registry Reporting Clinical Data Registry Reporting Electronic Reportable Laboratory Result Reporting |
10 Points |
Proposed Scoring Methodology Example
| Objective | Measures | Numerator/
Denominator |
Performance Rate | Score |
| e-Prescribing | e-Prescribing | 200/250 | 80% | 8 points |
| Query of Prescription Drug Monitoring Program | 150/175 | 86% | 5 bonus points | |
| Verify Opioid Treatment Agreement | N/A | N/A | 0 points | |
| Health Information Exchange | Support Electronic Referral Loops by Sending Health Information | 135/185 | 73% | 15 points |
| Support Electronic Referral Loops by Receiving and Incorporating Health Information | 145/175 | 83% | 17 points | |
| Provider to Patient Exchange | Provide Patients Electronic Access to Their Health Information | 350/500 | 70% | 28 points |
| Public Health and Clinical Data Exchange | Syndromic Surveillance Reporting (Required)
Choose one or more additional: Immunization Registry Reporting Electronic Case Reporting Public Health Registry Reporting Clinical Data Registry Reporting Electronic Reportable Laboratory Result Reporting |
Yes | N/A | 10 points |
| Total Score | 83 Points | |||
The CHIME Washington team is doing a more thorough analysis of the 1883-page rule and looks forward to offering more details soon.
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