The Centers for Medicare & Medicaid Services (CMS) has issued a final rule that affirms a 90-day reporting for hospitals attesting to the meaningful use program in 2018.
Overall, the final rule—the FY 2018 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long Term Acute Care Hospital (LTCH) Prospective Payment System Final Rule—updates Medicare payment and polices when patients are discharged from hospitals from October 1, 2017, to September 30, 2018. “The final rule relieves regulatory burdens for providers; supports the patient-doctor relationship in healthcare; and promotes transparency, flexibility, and innovation in the delivery of care,” according to a CMS fact sheet of the rule.
For 2018, CMS is finalizing the modification to the electronic health record (EHR) reporting periods for new and returning participants attesting to CMS or their state Medicaid agency from the full year to a minimum of any continuous 90-day period during the calendar year.
What’s also of major significance, with this rule CMS is now not requiring hospitals to meet meaningful use Stage 3 objectives and measures until 2019, a year later then originally planned. Indeed, hospitals and critical access hospitals will have the option to report modified stage 2 for the 2018 reporting period. This represents a change of course from the MU timeline that federal officials had previously outlined.
Also, CMS is finalizing the addition of a new exception from the Medicare payment adjustments for eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs) that demonstrate through an application process that compliance with the requirement for being a meaningful EHR user is not possible because their certified EHR technology has been decertified under ONC’s (the Office of the National Coordinator for Health IT) Health IT Certification Program.
Further, CMS is adopting final policies to allow healthcare providers to use either 2014 Edition CEHRT (certified EHR technology), 2015 Edition CEHRT, or a combination of 2014 Edition and 2015 Edition CEHRT, for an EHR reporting period in 2018. CMS officials noted that this policy is based on the ongoing monitoring of progress on the deployment and implementation status of EHR technology certified to the 2015 Edition, as well as feedback by stakeholders expressing the need for more time and resources are needed for the transition process.
The combination of a continuous 90-day MU reporting period along with giving providers another year before they have to switch to 2015 CEHRT will likely make most stakeholders happy in the short term. The American Hospital Association (AHA) said in a statement, “[W]e appreciate the agency allowing hospitals and critical access hospitals to report meaningful use modified Stage 2 in 2018, as well as implementation of a 90-day meaningful use reporting period in fiscal year 2018.”
Added the College of Healthcare Information Management Executives (CHIME), "CMS took into account that both hospitals and vendors need more time to prepare for 2015 certified EHRs. By no longer requiring these new systems be in place by the start of 2018, a huge weight has been lifted off our collective shoulders.”
Mari Savickis, vice president, federal affairs at CHIME further tells Healthcare Informatics how important it was that CMS listened to stakeholders and implemented some of these changes. She says that CHIME pushed very hard in particular for the changes to CEHRT because so many of its members (some 70 percent) had not received their 2015 CEHRT, or if they did it was not yet fully installed because they received it so late.
Says Savickis, “The stories from the field depicted a state of non-readiness that was not for lack of trying. Most of our members had inked the agreements for 2015 CEHRT with their vendors, but given all of the changes the vendors needed to make to accommodate Stage 3—which is a very complex build— the vendors have been struggling to keep up. This added time will provide a safer and better glide-path as we shift to the next stage. Further, it aligns with what CMS plans to do for the Medicare clinicians.”
Indeed, recently, on the physician practice front, as proposed in the Quality Payment Program rule for 2018 that CMS recently released, the use of 2014 Edition CEHRT would continue to be allowed to meet MIPS requirements, while the use of 2015 edition CEHRT would be encouraged, but not required.
Additionally in the rule, CMS finalized a reduction in the electronic clinical quality measure reporting requirement for the 2017 Hospital Inpatient Quality Reporting program. Hospitals will be required to report on at least four self-selected eCQMs for a reporting period of one self-selected quarter of CQM data in CY 2017 as opposed to the earlier adopted number of eight in 2017 and 2018.
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