Health IT Policy Update – April 20, 2015
90-Day Reporting Period, Changes to VDT Requirement Included in MU Modifications Proposed Rule
Key Takeaway: A Centers for Medicare and Medicaid Services’ (CMS) proposed rule was published in the Federal Register last week. The rule would shorten the EHR reporting period in 2015 to 90 days and loosen requirements for patient access to electronic health information, among other program modifications.
Why It Matters: Health IT executives should plan to report for any continuous 90-day period in 2015 from Oct.1, 2014 through Dec. 31, 2015, in keeping with CMS’ intention to move hospitals to a calendar year reporting period. Executives should also study the rule for a host of changes proposed to Stage 2 that will likely impact clinical workflows.
A CMS rule published last week would give providers an additional quarter to attest to meaningful use (MU) in 2015, by moving eligible hospitals (EHs) and critical access hospitals (CAHs) to calendar year reporting periods; it would allow providers to report over any continuous 90 day period in 2015; and it would change a handful of measures and objectives in preparation for Stage 3 requirements scheduled to begin in 2017. Other notable provisions include:
- Patient Electronic Access measure - 5 percent threshold for ‘View, Download and Transmit’ adjusted to “equal to or greater than one patient.”
- Secure Electronic Messaging measure (for Eligible Providers) – previously a threshold measure, changed to yes/no measure stating if the functionality is fully enabled.
- Public Health Reporting measures – consolidated to align with the proposed Stage 3 rule, providers must report on 2 of 5, and 3 of 6 for hospitals.
- Eliminates reporting of measures considered “topped out” or redundant, but in the process also makes all optional (called “menu”) requirements mandatory.
- For stage 1 attesters, this makes medication reconciliation, patient education, and public health reporting required.
- For stage 2 attesters, this moves e-prescribing from an optional measure to mandatory.
- In 2015, CQMs can continue to be reported either electronically or through attestation for any 90-day period.
- In 2016 and after, CQM data can be reported either electronically or through attestation, but must cover the entire calendar year.
The proposed rule has a 60-day comment period that closes on June 15, 2015. CMS announced their intentions to finalize this rule by mid-August 2015.
CHIME and AMDIS will submit comments on this proposed rule. To share you initial thoughts on the proposed program modifications please contact the CHIME Public Policy team.
ONC Releases Revised Guide on Privacy and Security of Electronic Health Information
Key Takeaway: Last week the Office of the National Coordinator for Health IT (ONC) published an updated guide on how providers and IT professionals can manage the privacy and security of electronic health records.
Why It Matters: Health IT executives should look to ONC’s guide for best practices and step-wise advice to update privacy and security practices surrounding electronic health information. The guide serves as an update to a 2011 edition, but is intended to bring new, practical information about privacy and security to small provider settings.
The guide includes seven steps providers should take to implement a security management process, a requirement under the Health Insurance Portability and Accountability Act (HIPAA) Security Rule that is defined as implementing policies and procedures to identify and prevent data security risks.
The guide includes definitions for a patient's right to access health information; what a security breach is; and what providers must do to inform patients when a breach occurs.
Hospital Data Exchange Rates Increasing says ONC
Key Takeaway: The percentage of hospitals electronically exchanging health information with health-care providers outside their IT network has steadily increased since the establishment of the federal State Health Information Exchange Program, according to a data brief released by the ONC last week.
Why it Matters: According to the ONC brief, as of 2014, 76 percent of all hospitals had exchanged some clinical data with another healthcare provider or hospital. The data indicates that an increasing amount of providers are exchanging information with partners outside their own organization, which is a pre-requisite step towards interoperability.