Provide Feedback on Proposed Changes to the Promoting Interoperability Programs
On April 23, 2019, the Centers for Medicare & Medicaid Services (CMS) (@CMSGov) issued the FY 2020 Inpatient Prospective Payment System (IPPS) and Long-term Acute Care Hospital (LTCH) Prospective Payment System (PPS) Proposed Rule.
Submit a Formal Comment by June 24, 2019
Comments on the FY 2020 IPPS and LTCH Proposed Rule are due no later than 5 p.m. ET, June 24, 2019. The public can submit comments in several ways:
- By regular mail
- By express or overnight mail
- By hand or courier
- Electronically (due at 11:59 p.m. ET): Follow the “submit a comment” instructions on the Federal Register
Please review the proposed rule for specific instructions for each method and submit comments by one method only.
Promoting Interoperability Programs Proposed Changes
The FY 2020 IPPS and LTCH Proposed Rule includes proposals affecting the Promoting Interoperability Programs, including:
- Establishing an EHR reporting period of a minimum of any continuous 90-day period in calendar year (CY) 2021 for new and returning participants;
- Removing the Verify Opioid Treatment Agreement measure beginning in CY 2020;
- Changing the Query of Prescription Drug Monitoring Program (PDMP) measure in CY 2020 from required to optional; and
- Converting the Query of PDMP measure from a numerator/denominator response to a yes/no attestation beginning with the EHR reporting period in CY 2019.
eCQM Proposed Changes
The FY 2020 IPPS and LTCH Proposed Rule proposes three changes for reporting eCQMs. These proposals align with the Promoting Interoperability Program’s Clinical Quality Measure proposals:
- For the CY 2020 reporting period/FY 2022 payment determination and CY 2021 reporting period/FY 2023 payment determination, extending the current eCQM reporting and submission requirements finalized for the CY 2019 reporting period, such that hospitals submit one, self-selected calendar quarter of discharge data for four self-selected eCQMs in the Hospital IQR Program measure set;
- For the CY 2022 reporting period/FY 2024 payment determination, requiring hospitals to report one, self-selected calendar quarter of data for: (1) three self-selected eCQMs, and (2) the proposed Safe Use of Opioids – Concurrent Prescribing eCQM, for a total of four eCQMs; and
- Requiring EHR technology be certified to all eCQMs available to report for the CY 2020 reporting period/FY 2022 payment determination and subsequent years.
Other Proposals for Public Comment
Additionally, CMS seeks comments on topics, including:
- Opioid measures based on existing efforts by National Quality Forum and the Centers for Disease Control and Prevention for potential inclusion in the Promoting Interoperability Programs;
- Measures to engage vendors and clinicians in improving the efficiency of healthcare providers’ use of EHRs;
- Inclusion of Medicare Promoting Interoperability Program data on the CMS Hospital Compare website;
- Integration of Patient-Generated Health Data into EHRs using certified EHR technology;
- Activities that promote the safety of the EHR; and
- Measures requiring the use of an open application programming interface (API), including reporting of such a measure as an alternative to the patient access measure.