Excerpts from the Proposed ‘Promoting Interoperability’ Initiative
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7.10.2018 By Leslie Krigstein, VP Congressional Affairs, CHIME |
On April 24, the Centers for Medicare & Medicaid Services (CMS) released the Inpatient Prospective Payment System (IPPS) proposed rule that included changes to the Meaningful Use program. The proposal included renaming Meaningful Use to Promoting Interoperability, a new scoring methodology and other changes that would impact hospitals, health systems and the health IT companies that serve them. The proposed rule is expected to be finalized in August.
Here are some excerpts from the proposed rule that may be of interest to Foundation firms, followed by links to CHIME documents.
2015 Edition of Certified Electronic Health Record IT (CEHRT)
“We continue to believe it is appropriate to require the use of 2015 Edition CEHRT beginning in CY 2019. In reviewing the state of health information technology, it is clear the 2014 Edition certification criteria are out of date and insufficient for provider needs in the evolving health IT industry. It would be beneficial to health IT developers and health care providers to move to more up-to-date standards and functions that better support interoperable exchange of health information and improve clinical workflows.”
Application programming interfaces (APIs)
“We also note that the Provide Patient Access measure’s technical requirements are updated in the 2015 Edition and support health care providers’ interest in providing patients with access to their data in a manner that is helpful to the patient and aligns with the API requirement in the Promoting Interoperability Program. … We want to ensure that health care providers have the opportunity to thoroughly test their systems and make adjustments in order to successfully attest for the EHR reporting periods in CYs 2019 and 2020. In addition, we believe that health care providers may need extra time to fully implement and test workflows with the 2015 Edition of CEHRT, which is required beginning in CY 2019, as well as the current proposal to require use of an API to incorporate patient data in the Provide Patients Electronic Access to Their Health Information measure.”
New scoring methodology and measures
“We also are proposing … an updated scoring methodology for eligible hospitals and CAHs (critical access hospitals) that would begin in 2019, as well as two new opioid measures and one new health information exchange measure that we believe eligible hospitals and CAHs will want to report on as soon as those measures are available in their CEHRT. We want to provide flexibility to health care providers as they are becoming familiar with the new scoring methodology and measures that we are proposing, as well as adequate development time for EHR developers and vendors to test and incorporate the new scoring system and measures for deployment and implementation. Therefore, we are proposing changes to the EHR reporting periods in 2019 and 2020 and believe the changes would result in a reduction in burden on health care providers and EHR developers and vendors. We are proposing these changes for 2019 and 2020 as we believe it may take more than one year for eligible hospitals and CAHs to adjust to the new scoring methodology.”
On June 25, CHIME sent comments to CMS that reflected members’ thoughts and concerns. CHIME commended CMS for exercising flexibility allowed under the 2018 Bipartisan Budget Act to remove a “pass/fail” policy under Meaningful Use. Other key points in the comment letter included finalizing new measures proposed in the Promoting Interoperability program but keeping two under an e-prescribing objective voluntary; allowing policies designed to speed interoperability a chance to take root before considering other policy levers; and addressing a list of barriers that would impede interoperability.
The comment letter is available here. The policy team also prepared a cheat sheet on the proposed changes, which can be found here.