In a September 1st letter to Centers for Medicare and Medicaid Services (CMS) Acting Administrator Andrew Slavitt, HIMSS offered comments in response to the Hospital Outpatient Prospective Payment (OPPS) and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs; Organ Procurement Organization Reporting and Communication; Transplant Outcome Measures and Documentation Requirements; Electronic Health Record (EHR) Incentive Programs; Payment to Certain Off-Campus Outpatient Departments of a Provider; Hospital Value-Based Purchasing (VBP) Program Notice for Proposed Rule Making (NPRM).
HIMSS remains strongly committed to making the EHR Incentive Program less prescriptive and more focused on encouraging and assisting providers in taking advantage of the substantial capabilities established through the development of Meaningful Use, including interoperability, health information exchange, and data sharing. Overall, HIMSS appreciates the CMS proposal to use a 90-day EHR reporting period in 2016 for all eligible professionals (EPs), eligible hospitals (EHs), and critical access hospitals (CAHs). We endorse CMS’ belief that this change would assist health care providers by increasing flexibility in the program.
HIMSS is concerned that changes made to the EHR Incentive Program for 2016 will not be finalized before the start of the year’s final possible 90-day reporting period and will create more confusion for providers. HIMSS asks CMS to be as flexible as possible with all providers in meeting the 2016 EHR Incentive Program reporting requirements, given the late date for these changes in the 2016 calendar year. HIMSS wants as many providers as possible to remain part of the EHR Incentive Program, so finalizing the 90-day reporting period as quickly as possible will reduce the number of providers who must rely on hardship exceptions in 2016. If the promulgation of this Final Rule is similarly delayed, CMS must be prepared to provide the flexibility for hardship exceptions as was done in 2015.
HIMSS recommends that CMS further align the reporting requirements for the Medicare and Medicaid EHR Incentive Programs with the Merit-Based Incentive Payment System (MIPS) in order to limit the need for multiple reports from EHR technology products.