KENTUCKY REGIONAL EXTENSION CENTER

Hospital Deadlines Approaching: IPPS Proposed Rule Comment Period & Hardship Exception Application

Jun 13, 2018

Now is the Time to Provide Your Feedback on Changes to the Promoting Interoperability Program Released in the FY 2019 IPPS Proposed Rule

Comment Period Closes June 25th

On April 24th, the Centers for Medicare & Medicaid Services (CMS) issued the FY 2019 Inpatient Prospective Payment System (IPPS) proposed rule. Effective immediately, CMS renamed the EHR Incentive Programs to the Promoting Interoperability (PI) Programs for Eligible Hospitals and Critical Access Hospitals. Within the rule, CMS has proposed to overhaul the hospital program to focus on interoperability, improving flexibility, relieving burden, and placing emphasis on measures that require the electronic exchange of health information. The proposed rule reiterates the requirement for hospitals to use 2015 Edition of CEHRT in 2019, proposes a new scoring methodology, as well as proposals for adding new measures and removing others.

Proposal Highlights

• No proposed changes to 2018 program requirements
• 2015 Edition CEHRT proposed to be required in 2019
• Some Stage 3 measures proposed to be eliminated and new measures introduced
• 90-day reporting period proposed for program years 2019 and 2020
• Performance-based scoring method proposed to replace the current all or nothing threshold requirements
• No proposed changes to eCQM reporting requirements in 2019

Submit a Formal Comment HERE by June 25th. Comments on the FY 2019 IPPS proposed rule are due by 11:59 p.m. ET Monday, June 25, 2018.

Comments may be submitted in several ways:

• Regular mail
• Express or overnight mail
• By hand or courier
• Electronically via the Federal Register

Please review the proposed rule for specific instructions on each method and submit comments by only one method.

Suggestions for Consideration

• Requesting a reduction in the number of points needed to avoid penalties
• Suggesting that more time is needed to implement proposed new measures
• Asking for clarifications of proposed new measures (e.g., opioid treatment agreements)
• Recommending allowance to report any two public health measures, rather than requiring Syndromic Surveillance and a second measure

Medicare Eligible Hospitals: Submit a Hardship Exception Application by July 1, 2018

As a result of the American Recovery and Reinvestment Act of 2009, the Centers for Medicare & Medicaid Services mandates that payment adjustments be applied to Medicare eligible hospitals and critical access hospitals (CAHs) that are not meaningful users of certified electronic health record technology under the EHR Incentive Programs (now called the Promoting Interoperability (PI) Programs).

Eligible hospitals and CAHs may be exempt from Medicare penalties if they can show that demonstrating meaningful use would result in a significant hardship. To be considered for an exemption and avoid a payment adjustment, health care providers must complete a hardship exception application and provide proof of hardship.

If approved, the hardship exception is valid for only one payment year.

Hardship Exception Application Details

• The deadline for eligible hospitals to submit application is July 1, 2018
• The completed application and all support documentation must be attached to an email and sent to ehrhardship@cms.hhs.gov
• All hardship exception determinations will be returned via email from ehrhardship@cms.hhs.gov to the email address provided on the application

You can access the hardship application HERE.

Contact us at Kentucky REC with your questions. Our team of experts is here to help: 859-323-3090.

Updates on Meaningful Use (Promoting Interoperability) for Eligible Professionals

May 2, 2018

FY2019 IPPS/LTCH PPS Proposed Rule Released
CMS released the Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and Long Term Care Hospital Prospective Payment System proposed rule on April 24, 2018. CMS is proposing to overhaul the program to: make the program 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. CMS is currently seeking public comments. The deadline for submitting comments on the proposed rule and the RFI is no later than June 25 2018, at 11:59 PM ET.

CMS Re-naming the Meaningful Use Program
With the goal of focusing attention on data sharing and greater flexibility, CMS is renaming the Meaningful Use Program (formerly known as Medicare and Medicaid Electronic Health Record Incentive Programs) to Medicare and Medicaid Promoting Interoperability Program. (This includes renaming ACI under MIPS.)

A fact sheet on the proposed rule (CMS-1694-P), is available here.
To view the proposed rule (CMS-1694-P), please visit here.

Now is the Time to Schedule a Meeting with Your Health IT Advisor
Contact your Health IT advisor and provide Meaningful Use reports run using a 90-day reporting period in 2018. A Meaningful Use gap analysis and action plan will then be completed and discussed in detail with you. It is essential to begin reviewing your 2018 MU reports and monitor your progress on a regular basis. This will allow time to reassess workflows within the practice.

2018 Meaningful Use Facts

The EHR Meaningful Use Objective reporting period for all participants is a minimum of any continuous 90 days from January 1 through December 31, 2018.

The Clinical Quality Measures are expected to be reported electronically under the following reporting periods:

• First-time Meaningful Users – Any continuous 90 days in 2018
• Returning Meaningful Users – 2018 Full Calendar Year

Health care providers are required to electronically report clinical quality measures (eCQMs), which use data from EHRs and/or health information technology systems to measure health care quality. This is required beginning in January 2018. To report eCQMs successfully, health care providers must adhere to the requirements identified by the CMS quality program in which they intend to participate.

You will have the choice in attesting to either:

A: Modified Stage 2 – Providers may attest to objectives and measures using EHR technology certified to the 2014 Edition, 2015 Edition, or a combination of the two

OR

B: Stage 3 – Providers may attest to objectives and measures using EHR technology using a combination of 2014 and 2015 Edition or 2015 Edition

2018 Resources

• Find Specification Sheets for Modified Stage 2 here
• Find Specification Sheets for Stage 3 here
• Find eCQM table here
• Find CMS Frequently Asked Questions here
• Find KY Medicaid website here
• Find Kentucky Health Information Exchange website here
• Find CMS EHR Incentive website here

For answers to your questions about Promoting Interoperability (Meaningful Use), contact our experts at 859-323-3090 or Kentucky REC