7 major EHR provisions in the PPS final rule
CMS offers providers more flexibility in federal requirements for records systems.
7 major EHR provisions in the PPS final rule
CMS offers providers more flexibility in federal requirements for records systems.
EHR provisions in the final FY 2018 Inpatient Prospective Payment System rule
In the recently released final rule governing the Fiscal Year 2018 Inpatient Prospective Payment System, several provisions addressed changes in the Electronic Health Record Incentive Program for next year.
In general, providers got some breaks that relax the toughest parts of the originally proposed regulations that the Centers for Medicare and Medicaid Services put out for comment, but generally, the agency is keeping up the pressure on providers to continue to make progress in implementing EHRs and getting benefits out of them.
Here is a compilation of some of the most important provisions in the rule, with comments on how they will affect providers in the months ahead.
Requirements for electronic clinical quality measures are eased
In the final rule, CMS offers a modified, reduced policy for Electronic Clinical Quality Measures (eCQMs). Hospitals will be required to select and submit four of the available eCQMs included in the Hospital Inpatient Quality Reporting Program. The original proposal from CMS was to have hospitals report on eight eCQMs.
The reporting period for Calendar Year 2017 will impact Fiscal Year 2019 payments; the Calendar Year 2018 reporting period will help determine FY 2020 payments for hospitals. Hospitals can select one quarter of data, of their choice, to submit to CMS.
Providers get more flexibility to use certified EHR technology
CMS also modified eCQM certification requirements, giving considerable flexibility to hospitals. Facilities will be able to use either:
* The 2014 edition of Certified EHR Technology (CEHRT).
* The 2015 edition of CEHRT.
* A combination of both the 2014 and 2015 editions of CEHRT.
This enables healthcare organizations to continue to use 2014 edition of certified EHR technology in 2018. That flexibility is one of the most important concessions in the final rule, according to advocacy staff of the College of Healthcare Information Management Executives.
Stage 3 of Meaningful Use is pushed back a year
Under the final rule, healthcare organizations will not be required to meet Stage 3 in 2018, delaying that requirement for one year.
CQM electronic reporting policies are aligned with EHR incentive programs
CMS is taking several steps to align reporting policies from various programs, thus easing the burden on providers who report eCQMs. In brief, EHR technology used by providers will need to have EHR technology certified to report all 15 eCQMs that are available to report in the Hospital IQR program; for 2018, hospitals will be required to use the most recent version of the eCQM electronic specifications; and EHR technology certified to all 15 eCQMs would not need to be recertified each time it is updated to a more recent version of the eCQMs.
Providers won’t be penalized if EHR technology is decertified
Hospitals and eligible professionals will be exempted from a payment adjustment if the HHS Secretary determines that compliance with the requirement for being a meaningful EHR user is not possible because the certified EHR technology has been decertified under the Office of the National Coordinator for Health Information Technology’s Health IT Certification Program. That could be important, as the Office of Inspector General at HHS recently warned electronic health record vendors that it will not tolerate representations that their software has certain functionality if their products actually can’t do it.
The rule details the impact of EHRs, quality data on payment rates
For hospitals in Fiscal Year 2018, the market basket rate of increase in inpatient rates under the prospective pricing system is 2.7 percent. But those rates will be affected depending on EHR and quality data factors.
Hospitals that don’t submit quality data would see a reduction of .675 percent in rates, whether or not the facility is a meaningful user of an EHR.
Hospitals that are not meaningful users of an EHR would be penalized 2.025 percent on their rate, whether or not quality data is submitted.
Hospitals will receive an update of 1.35 percent if they submit quality data and are meaningful users of EHRs. Other adjustments to IPPS rates can be found on page 724 of the final rule; the beginning of the discussion on IPPS rates begins on page 720.
Long-term care hospitals get EHR encouragement
The final rule notes that HHS has several initiatives to encourage adoption of HIT and promote nationwide health information exchange. Even though long-term care hospitals are among those that are ineligible for payments through the EHR incentive programs, CMS believes that “the use of certified EHRs…can effectively and efficiently help providers improve internal care delivery practices, support the exchange of important information across care partners and during transitions of care, and enable the reporting of electronically specified clinical quality measures.