On Monday, September 10, 2018, HIMSS submitted a letter to the Centers for Medicare and Medicaid Services (CMS) with its response to the Medicare Program Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2019; Medicare Shared Savings Program Requirements; Quality Payment Program; and Medicaid Promoting Interoperability Program. In its letter, HIMSS leverages the expertise of its membership in offering feedback on the Physician Fee Schedule (PFS), Quality Payment Program (QPP), and telehealth services.
Overall, 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.
Our organization supports the actions proposed in the rule to reduce the burden on clinicians by expanding the current policy on recording patient history and previous exam details in clinical notes. As HIMSS noted in a joint letter with the Association of Medical Directors of Information Systems (AMDIS) in June 2018, it is critical to include Evaluation and Management (E/M) documentation requirements as part of any discussion around minimizing the clinician burden as E/M documentation requirements and coding concerns are a significant source of burden.
HIMSS also notes that the proposed rule takes an important step forward in connected health. Our organization offers its appreciation to CMS for the incorporation of evidence-based chronic care remote patient monitoring (RPM) Current Procedural Terminology codes, inter-professional consultation codes, virtual check-in and remote evaluation of pre-recorded patient information. HIMSS believes this set of policies offers great opportunities for the modernization of Medicare physician payment, and the innovative and appropriate utilization of technology in care delivery.
In addition, HIMSS endorses the requirement on the use of 2015 Certified Electronic Health Record Technology (CEHRT) beginning in 2019 because of 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.
Moreover, HIMSS is supportive of the inclusion of opioid-related measures in the e-Prescribing Objective of the Quality Payment Program’s Promoting Interoperability Programs performance category. HIMSS notes that it realizes that CMS will likely finalize its proposed draft opioid measure bonus point structure in 2019 to align with the Final 2019 Inpatient Prospective Payment System Regulation, but it emphasizes and reinforces to CMS the importance of the move to outcomes-focused measures in this area.