HIMSS Comments on CMS IPPS Proposed Rule

In a June 25, 2018 letter to Administrator Seema Verma, HIMSS offered comments to the Centers for Medicare and Medicaid Services’ (CMS) Notice of Proposed Rule Making (NPRM) regarding Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2019 Rates; Proposed Quality Reporting Requirements for Specific Providers; Proposed Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs (Promoting Interoperability Programs) Requirements for Eligible Hospitals, Critical Access Hospitals, and Eligible Professionals; Medicare Cost Reporting Requirements; and Physician Certification and Recertification of Claims. In this letter, HIMSS leverages its members’ expertise to offer feedback on feedback on the Promoting Interoperability Programs, as well as Inpatient Prospective Payment System (IPPS) quality measurement initiatives, and we look forward to continued dialogue with CMS on these topics.

HIMSS is committed to assisting CMS in supporting the shift to value-based care delivery and facilitating greater data exchange across the healthcare community through the Promoting Interoperability Programs. HIMSS wants to continue to help CMS leverage information and technology to support the demonstration of innovative care delivery models for coordinating smarter, safer, and more efficient high-quality care, while ensuring that individuals remain at the center of all our efforts.

HIMSS reinforced the importance of adopting the 2015 Edition criteria as a significant part of our commitment supporting healthcare transformation beginning January 1, 2019. HIMSS noted that the benefits of requiring the use of the 2015 Edition cannot be overstated, with its focus on greater interoperability for clinical health purposes—opening up the certification program to other types of health information and technology, addressing health disparities, and including a new streamlined approach to privacy and security.

HIMSS is very supportive of the inclusion of opioid-related measures in the e-Prescribing Objective of the Promoting Interoperability Programs. However, HIMSS does recommend CMS consider utilizing opioid measures that have a stronger focus on outcomes.

HIMSS supports a shift that enhances the value proposition of participating providers and ensures that electronic clinical quality measures are feasible, actionable, and meaningful for all eligible providers, to drive improvement in care outcomes. HIMSS supports CMS moving the quality reporting program forward in the least burdensome manner possible, while maintaining a parsimonious set of the most meaningful quality measures and continuing to incentivize improvement in the quality of care provided to patients.


Read the full letter.