Last week, the 2019 Inpatient Prospective Payment System (IPPS) Notice of Proposed Rulemaking (NPRM) was released, provoking buzz about how the proposed changes could shape the future of digital health and care.
The initial buzz began in March at the HIMSS18 Global Conference & Exhibition, where Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma shared news of CMS’s plans for a complete overhaul of the meaningful use program, as well as changes to the Advancing Care Information performance category of the Quality Payment Program (QPP). Last week’s CMS announcement emphasized an overall focus on the acceleration of digital health innovation and increased electronic health record (EHR) accessibility.
The follow-up from CMS came with the release of the 2019 IPPS NPRM. It’s a real time investment to digest at 1,883 pages, so here are some key takeaways on the proposal as well as what the future health information and technology landscape might look like.
Nothing signals big changes ahead like a name change, and the Medicare and Medicaid EHR Incentive Programs will now be known as Promoting Interoperability (PI) Programs. According to CMS, the new title better reflects the program’s growing focus on increased accessibility and improved facilitation of data exchange between providers and patients.
One of the most notable changes the proposed rule addresses is the reduction of measures within these programs.
CMS aims to reduce provider burden by narrowing down the number of measures and condensing them into more specific, centralized focus areas. The agency believes this provides a more flexible structure, allowing eligible hospitals to put their focus back on patients, and continues to encourage hospitals to push themselves on the most applicable measures to how they deliver care to patients, instead of increasing thresholds on measures that may not be as applicable.
One substantial change proposed is a new performance-based scoring methodology. Scored out of 100 points, proposed objectives include e-Prescribing, Health Information Exchange (HIE), provider to patient exchange, and public health and clinical data exchange. To satisfy program requirements, eligible hospitals and critical access hospitals (CAHs) must score at least 50/100 in order to be eligible for an incentive payment or avoid a Medicare payment reduction. Failure to report or submitting a ‘no’ response (if no exclusions apply) results in a zero.
CMS believes this will ease provider burden and offer more flexibility.
Time and time again, it’s been proven that once providers implement EHRs, they embrace the change, and they like it – so they keep using it, and they accrue benefits. Whether there’s a reporting period that’s 12 months or 90 days, providers continue to use that technology because they see the value in it. Accruing benefits just adds onto that value.
In order to obtain stakeholder feedback on program participation conditions, CMS posted a request for information (RFI).
It’s not often CMS opens up the conditions of participation and it’s exciting that the growing focus on interoperability prompted it. It also presents bigger questions – for instance, whether it is appropriate to include advancing the electronic exchange of information that supports safe, effective transitions of care between hospitals and community providers as a requirement for participation in Medicare and Medicaid. It would be a truly robust policy lever, ultimately leading to the facilitation of greater data exchange.
Though there won’t be a response in the final rule, CMS plans to consider all feedback as a potential framework in developing future regulatory proposals or sub-regulatory guidance. CMS is seriously considering this idea, and also included a Medicare and Medicaid Conditions of Participation RFI in the nursing home, hospice, and psychiatric hospitals proposed payment rules that were released subsequent to the IPPS rule.
The negative impact of information blocking was a topic of discussion during Administrator Verma’s HIMSS18 announcement and continues to be of major focus as the healthcare community awaits a proposed rule from the Office of the National Coordinator for Health IT (ONC), mandated by Congress as part of the 21st Century Cures Act.
ONC now faces the challenge of properly defining what isn’t information blocking. The agency is working closely on this with all other Department of Health and Human Resources (HHS) agencies and the Office of Inspector General.
Leveraging ONC’s Trusted Exchange Framework and Common Agreement (TEFCA) infrastructure, proposed earlier this year to facilitate more efficient health information exchange. Providers could be assessed on whether they are utilizing and adhering to that voluntary guidance, in order to help rule out information blocking.
The U.S. remains at the forefront of a major public health crisis. According to the CDC, 115 Americans with opioid addiction fatally overdose every day. In the new Promoting Interoperability Program, CMS is proposing to address the opioid epidemic in two measures, which in 2019 would be implemented as optional or bonus measures (earning up to five points) to encourage participation. CMS proposes these measurements be required with the EHR reporting period in 2020.
Wider use of Querying a Prescription Drug Monitoring Program (PDMP) & Verifying the Existence of an Opioid Treatment Agreement would have far-reaching benefits:
Although it’s just a proposal, the aforementioned changes signal a greater recognition of using all available policy levers to advance what the health IT community has long been advocating for– empowering patients with greater access to information and embracing digital innovations that improve patient outcomes and increase the value of patient care. We encourage you to access the proposed rule and explore the proposal in more detail.
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.
Updated July 20, 2018