OPPS Fee Schedule has MU Changes
Key Takeaway: CMS announces a 90-day Meaningful Use reporting period for 2016, and fewer measures and lower thresholds for 2017 and 2018!
Why it Matters: Listening to repeated cries for hospitals and CIOs, CMS has proposed sweeping changes to Meaningful Use program for both 2016, 2017 and 2018 in the hospital OPPS proposed rule. CHIME has advocated tirelessly for changes calling on CMS and working with members of Congress to make the program more flexible. CHIME recently spear-headed a letter signed by 30 plus organizations requesting CMS shorten the reporting period in 2016 to 90 days.
While this is a proposed rule, we expect most changes on Meaningful Use to be finalized. Comments on the rule are due September 6th and CHIME plans on commenting. Go here for our new CIO fact sheet outlining the proposed changes. Below is a recap of the changes CMS has proposed.
- 90-day reporting period for 2016
- Reduction of numerous thresholds in Stage 3 to Modified Stage 2 levels for 2017 and 2018
- CDS and CPOE removed for Modified Stage 2 and Stage 3
- VDT measure threshold reduction for Modified Stage 2 and Stage 3 to one patient
Physician Fee Schedule for 2017 – tech items included
Key Takeaway: CMS proposed several changes for clinicians involving health IT under the PFS for 2017.
Why it Matters: The rule contains a handful of health IT items which are recapped below:
- Appropriate Use Criteria (AUC) for Advanced Diagnostic Imaging Services: Protecting Access to Medicare Act of 2014 (PAMA) requires CMS to create a program to promote use of AUC for advanced diagnostic imaging. Last year’s PFS outlined CMS’ initial plans. For 2017 they have proposed requirements and processes for specification of qualified clinical decision support mechanisms (CDSMs) under the Medicare AUC program; the initial list of priority clinical areas; and exceptions to the requirement that ordering professionals consult specified applicable AUC when ordering applicable imaging services. For more details, see the rule starting page 525.
Shared Savings: CMS proposed changes to better align with the QPP proposal which includes MIPS and APMs. They also proposed changes involving calculating who is using CERHT. Under the current Shared Savings Program rules, ACOs must report on and are held accountable for certain measures that make up the quality reporting standard. One of these measures, ACO #11, assesses the degree of CEHRT use by primary care physicians participating in the ACO and performance on this measure is weighted twice that of any other measure for scoring purposes. CMS has proposed to change the specifications of the EHR measure to assess the ACO on the degree of CEHRT use by all providers and suppliers designated as ECs under the QPP proposed rule that are participating in the ACOs rather than narrowly focusing on the degree of use of CEHRT of only the primary care physicians participating in the ACO. See starting page 676.
Key Takeaway: ONC publishes C-CDA tool
Why it Matters: ONC has released what they are calling a CCD-A Scorecard in beta version through a cooperative agreement with HL7. The Standards Implementation & Testing Environment (SITE) Scorecard or SITE C-CDA Scorecard is a benchmarking tool designed to enable health care providers, health IT implementers, and health IT developers compare how the C-CDAs created by their health IT stack up against the HL7 C-CDA implementation guide and HL7 best practices. It includes three layers of review: 1) 2014 Edition and 2015 CEHRT; 2) HL7 C-CDA implementation guide specifications (for C-CDA 2.1 in the beta version, and R1.1 later); and 3) authoritative implementation “best practices” published by HL7 for C-CDA. The scorecard produces a categorized report with C-CDA section grades and tips related to areas for improvement. For questions contact ONC TechLab.
In unrelated news, an article was recently published in the Journal of the American Medical Informatics Association (JAMIA) detailing the results of study on the interoperability of C-CDAs. The authors, “identified errors and permissible heterogeneity in C-CDA documents that will limit semantic interoperability. Our findings also point to several practical opportunities to improve C-CDA document quality and exchange in the coming years.”
ONC Plans for Measuring Interoperability