HIMSS Comments on CMS Inpatient Prospective Payment Systems Proposed Rule

HIMSS Comments on CMS Inpatient Prospective Payment Systems Proposed Rule

On June 24, HIMSS offered its public comment letter to the Centers of Medicare and Medicaid Services (CMS) 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 2020 Rates; Proposed Quality Reporting Requirements for Specific Providers; Medicare and Medicaid Promoting Interoperability Programs Proposed Requirements for Eligible Hospitals and Critical Access Hospitals proposed rule. In its letter HIMSS offers its members’ expertise in offering feedback on the Promoting Interoperability Programs, as well as Inpatient Prospective Payment System (IPPS) quality measurement initiatives.

Core to the HIMSS mission is promoting the use of health information and technology to improve the quality of healthcare delivery through effective performance measurement and risk adjusted decision support. All quality measurement and reporting programs launched by government as well as private payers should reinforce the utilization of clinical interventions, which have the most significant impact on improving patient outcomes. HIMSS notes that there is a significant gap in the availability of measures that are meaningful based on the Meaningful Measures Initiative to a multitude of specialties in the acute care space. Once new eCQMs that meet the Meaningful Measures Initiative criteria become available, HIMSS strongly encourages CMS to expand the measure set to target gaps in care and meaningful opportunities to improve care quality outcomes.

HIMSS is encouraged by CMS exploring the adoption of measures associated with battling the opioid addiction crisis that are more outcomes-oriented than measures previously proposed for federal quality reporting programs. However, while the proposed measures fill a significant public health need and are more outcomes-oriented, HIMSS members and several HIMSS collaborative partners have expressed concern about the feasibility and accuracy of the measures. HIMSS supports CMS’s proposal for mandatory reporting of the two new opioid measures starting in calendar year 2022, and would encourage CMS to look for avenues to make these mandatory before that time.

HIMSS is strongly encouraged with CMS proposing to move away from claims-based measurement for CMS programs measuring patient outcomes.

HIMSS is encouraged that CMS is looking to find more ways to facilitate Medicare beneficiary access to transformative technologies that treats serious or life-threatening diseases or conditions for which there are unmet medical needs. HIMSS recommends that if CMS finalizes the add-on payment pathway proposal, the agency should continuously work in tandem with Food and Drug Administration (FDA) to better understand the evolving successes and challenges of this program and how that will affect CMS reimbursement policies for medical device technology.

View the full letter

HIMSS Government Relations

The HIMSS policy team works closely with the U.S. Congress, federal decision makers, state legislatures and governments, and other organizations to recommend policy, and legislative and regulatory solutions to improve health through information and technology.

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