On Friday, April 14, the Centers for Medicare & Medicaid Services (CMS) released the Notice of Proposed Rulemaking for the Fiscal Year (FY) 2018 Hospital Inpatient Prospective Payment System (IPPS), which includes changes to the calendar year (CY) 2017 and 2018 Medicare and Medicaid Electronic Health Record (EHR) Incentive Program Requirements for Eligible Hospitals (EHs), Critical Access Hospitals (CAHs), and Eligible Professionals (EPs). Comments on this proposed rule are due to CMS on June 13, 2017.
In terms of the CMS proposal for an electronic clinical quality measures (eCQMs) reporting period in CY 2017, EHs and CAHs would have to report two self‑selected quarters of CQM data for at least six (self-selected) of the available CQMs. These changes are reduced from the eight CQMs that CMS had previously required EHs and CAHs to report for a full year in 2017.
For the CY 2018 reporting period, CMS is proposing that EHs and CAHs report six self-selected eCQMs for the first three quarters of CY 2018, which is a reduction from the previously-finalized reporting of eight measures for a full year. These changes bring the Medicare EHR Incentive Program for hospitals into alignment with the electronic reporting requirements for CQMs in the Hospital Inpatient Quality Reporting (IQR) Program.
CMS is also proposing to change the CY 2017 eCQM reporting period for EPs in the Medicaid EHR Incentive Program to at least a continuous 90-day period during the calendar year. In addition, CMS is proposing to align the CQMs available to EPs participating in the Medicaid EHR Incentive Program with those available to eligible clinicians participating in the Merit-based Incentive Payment System (MIPS) in the Quality Payment Program.
The agency is also proposing more general Medicare and Medicaid EHR Incentive Program changes. For 2018, CMS proposes to modify the EHR reporting periods in both Medicare and Medicaid to at least any continuous 90-day period during the calendar year from the previously-finalized requirement for a full year.
Moreover, there are two changes required in the 21st Century Cures Act that CMS is proposing in this rule. CMS is proposing to add a new exception from Medicare payment adjustments for those program participants that have not been able to comply with reporting requirements because their certified EHR technology has been decertified under ONC’s Health IT Certification Program. The agency is also proposing a process to implement a policy to provide that no payment adjustments will be made for EPs who furnish “substantially all” of their services in an ambulatory surgical center (ASC).
The IPPS Proposed Rule also includes additional changes that impact health IT in the implementation of the Hospital IQR Program, Hospital Value-Based Purchasing (VBP) Program, Hospital-Acquired Conditions (HAC) Reduction Program, and Hospital Readmissions Reduction Program (HRRP).
Additional analysis of the IPPS Proposed Rule will be posted to www.himss.org in the coming days.