CMS released the proposed rule updating the Inpatient Prospective Payment System (IPPS) and the Long-Term Care Hospital (LTCH) Prospective Payment System (PPS) which mainly focuses on fostering interoperability, mitigating clinician’s burden, allowing more flexibility in reporting and lowering overall healthcare cost. Following are the key highlights based on CMS’s goals:
Promoting Interoperability
- One stop solution for incorporating all the patient’s EHR data from multiple providers in a single portal in order to allow patients to take informed health decisions by giving them more control to their own health information
- Starting 2019, the patient’s would be able to access their health information on the day they are discharged from the hospital
- The new phase of interoperability applies to Medicare fee-for-service, Medicare Advantage, as well as Medicaid
- MyHealthEdata Initiative – Empower the patients to not only access their EHR data electronically but also share the data across healthcare systems
- Medicare’s Blue Button 2.0 – Tool to share claims data with the patients & information of previous prescriptions, procedures & treatments in a secure format to avoid duplicate tests & procedures for smooth transition of care
EHR Requirements for Clinicians and Hospital
- Beginning with 2019 calendar year, the clinicians as well as hospitals are required to upgrade to 2015 CEHRT capable of providing access of data to patients in a secure & utilizable way.
- Adopt the use of APIs for patients to collect & share their health information electronically from a single application or software.
- Common Clinical Data Set and patient data export from Eligible Hospitals, included as a 2015 Certification criterion, are considered to be critical to achieve interoperability
Reporting Requirements for Hospitals
- EHR reporting periods in 2019 and 2020 for new and returning participants would be a minimum of any continuous 90-day period
- Removal of 7 eCQMs from the Hospital IQR Program starting 2020 reporting period
- Hospitals to continue with the reporting of 1 self-selected calendar quarter of discharge data for 4 eCQMs in the Hospital IQR Program measure set in 2019 reporting period.
- Removal of 19 Measures & de-duplication of 21 Measures across the 5 Hospital Quality and VBP Programs to reduce cost & burden associated with regulatory requirements of redundant & process-driven measures
- Shift from threshold based scoring to performance based scoring logic to provide increased flexibility as proposed in the Promoting Interoperability Program.
Reduced Cost & Paperwork
- Elimination of overall 25 Measures is estimated to save $75 Million and over 2 Million hours of extra work for hospitals
- Streamline documentation and billing requirements for clinicians to spend more time with patients at the point of care
- Reduce the incidence of unnecessary and duplicative medical tests which can occur as a result of clinicians not sharing data.
Price Transparency for Hospital
- Mandate hospitals to make their standard list of prices available publicly or on request via internet in order to encourage price transparency
- Reduce the challenges for patients due to unawareness of out-of-network bills or facility fees so that they are well informed about their obligations.
Takeaway from the Proposed Rule
- CMS plans to re-design the initiative to emphasize on interoperability and reduce burden on clinicians and hospitals by focusing on measures that require effective use of CEHRT.
- Underline the importance of Patient Engagement to improve the patients role in managing their own care
- Opportunity for ISVs to develop innovative patient portals based on patient’s needs and identify optimal ways to utilize claims data resulting in improved patient care
- Smooth Transition of Care from one hospital to another and reduce the overall cost of healthcare
- Opportunity for third party intermediaries to bring together different technology solutions into a consolidated solution for
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- Comprehensive reporting and tracking of improvement activities.
- Simpler and efficient reporting that assists providers to spend less time on compliance and more time on the point of care.