In a rule released late in the afternoon on April 24, the Centers for Medicare & Medicaid Services (CMS) has made clear its intention to overhaul the meaningful use program.
In a press release, the federal agency said that it will be proposing to re-name the meaningful use program to “Promoting Interoperability.” CMS said the goals of the new program will be to: make it more flexible and less burdensome; emphasize measures that require the exchange of health information between providers and patients, and incentivize providers to make it easier for patients to obtain their medical records electronically.
The meaningful use (Medicare and Medicaid EHR Incentive Programs) program has been around since 2011 with the intent to encourage eligible providers to demonstrate meaningful use of certified EHR (electronic health record) technology. Seven years later, with nearly all hospitals and most physician practices having implemented a certified EHR, CMS is proposing a shakeup of the initiative with a rethinking of industry priorities.
Broadly, the proposed rule issued today proposes updates to Medicare payment policies and rates under the Inpatient Prospective Payment System (IPPS) and the Long-Term Care Hospital (LTCH) Prospective Payment System (PPS). According to CMS, the policies in the IPPS and LTCH PPS proposed rule “would further advance the agency’s priority of creating a patient-driven healthcare system by achieving greater price transparency and interoperability—essential components of value-based care— while also significantly reducing the burden for hospitals so they can operate with better flexibility and patients have the information they need to become active healthcare consumers.”
The proposed policies begin implementing core pieces of the government-wide MyHealthEData initiative through several steps to strengthen interoperability or the sharing of healthcare data between providers, CMS officials stated. “We seek to ensure the healthcare system puts patients first,” CMS Administrator Seema Verma said in a statement. “Today’s proposed rule demonstrates our commitment to patient access to high quality care while removing outdated and redundant regulations on providers. We envision a system that rewards value over volume and where patients reap the benefits through more choices and better health outcomes. Secretary Azar has made such a value-based transformation in our healthcare system a top priority for HHS, and CMS is taking important, concrete steps toward achieving it.”
According to CMS, the rule applies to about 3,300 acute care hospitals and 420 long-term care hospitals, and would take effect Oct. 1
As far as “Promoting Interoperability” mandates go, the proposed rule reaffirms the requirement for providers to use the 2015 Edition of certified electronic health record technology (CEHRT) in 2019 as part of demonstrating meaningful use to qualify for incentive payments and avoid reductions to Medicare payments. This updated technology includes the use of application programming interfaces (APIs).
CMS is also proposing that EHR reporting periods in 2019 and 2020 for new and returning participants would be a minimum of any continuous 90-day period within each of the calendar years 2019 and 2020.
In the proposed rule, CMS is also requesting stakeholder feedback through a request for information (RFI) on the possibility of revising Conditions of Participation to revive interoperability as a way to increase electronic sharing of data by hospitals. CMS has said that “In responding to the RFI, commenters should provide clear and concise proposals that include data and specific examples. If the proposals involve novel legal questions, analysis regarding CMS’ authority is welcome.”
What’s more, CMS is aiming to “remove unnecessary, redundant, and process-driven quality measures from a number of quality reporting and pay-for-performance programs.” Specifically, the proposed rule would eliminate a significant number of measures acute care hospitals are currently required to report and remove duplicative measures across the five hospital quality and value-based purchasing programs, the agency said.
“This would result in the removal of a total of 19 measures from the programs and would de-duplicate another 21 measures while still maintaining meaningful measures of hospital quality and patient safety. Additionally, CMS is proposing a variety of other changes to reduce the number of hours providers spend on paperwork. CMS is proposing this new flexibility so that hospitals can spend more time providing care to their patients thereby improving the quality of care their patients receive,” the press release stated, adding that it is adopting one claims-based readmissions measure.
In regard to eligible hospitals and CAHs (critical access hospitals) that report clinical quality measures (CQMs) electronically, the reporting period for the new program would be one, self‑selected calendar quarter of CY 2019 data, reporting on at least four self-selected CQMs from the set of 16. In addition, beginning with the 2020 reporting period, CMS is proposing to remove eight of the 16 CQMs, which the agency said is consistent with its commitment to producing a smaller set of more meaningful measures and in alignment with the Hospital IQR Program.
CMS’ fact sheet with charts on how data reporting across the five hospital quality and value-based purchasing programs will be less burdensome can be read here.
Regarding transparency, CMS noted that although hospitals are already required under guidelines developed by CMS to either make publicly available a list of their standard charges, or their policies for allowing the public to view a list of those charges upon request, CMS is updating its guidelines to specifically require that hospitals post this information. The agency is also seeking comment on what price transparency information stakeholders would find most useful and how best to help hospitals create patient-friendly interfaces to make it easier for consumers to access relevant health care data so they can more readily compare providers.
What’s more, CMS is also proposing a new scoring methodology as well as proposals for new measures including: “query of the PDMP (prescription drug monitoring program),” and “verify opioid treatment agreement,” related to e-prescribing of opioids that align with the overall agency initiative on the treatment of opioid and substance use disorders. CMS also proposes to remove certain measures which do not emphasize interoperability and the electronic exchange of health information.
In sum, CMS said that this results in the elimination of 25 total measures across the five programs with well over 2 million burden hours reduced for hospital providers impacted by the IPPS proposed rule, saving them $75 million.
The deadline for submitting comments on the proposed rule and the RFI is June 25, 2018. The proposed rule and the RFI can be downloaded from the Federal Register at: https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-08705.pdf
Healthcare Informatics will continue to update readers with further developments from this story.