May 5, 2021
On April 27, 2021, the Centers for Medicare & Medicaid Services (CMS) issued the proposed rule for fiscal year (FY) 2022 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long Term Care Hospital (LTCH). Please see additional details below.
CMS has specifically proposed the following changes to the Medicare Promoting Interoperability Program for eligible hospitals and critical access hospitals:
- Continue the EHR reporting period of a minimum of any continuous 90-day period for new and returning eligible hospitals and CAHs for CY 2023 and to increase the EHR reporting period to a minimum of any continuous 180-day period for new and returning eligible hospitals and CAHs for CY 2024;
- Maintain the Electronic Prescribing Objective’s Query of PDMP measure as optional while increasing its available bonus from 5 points to 10 points;
- Modify technical specifications of the Provide Patients Electronic Access to Their Health Information measure to include establishing a data availability requirement;
- Add a new Health Information Exchange (HIE) Bi-Directional Exchange measure as a yes/no attestation, beginning in CY 2022 to the HIE objective as an optional alternative to the two existing measures;
- Require reporting “yes” on four of the existing Public Health and Clinical Data Exchange Objective measures (Syndromic Surveillance Reporting, Immunization Registry Reporting, Electronic Case Reporting, and Electronic Reportable Laboratory Result Reporting) or requesting applicable exclusion(s);
- Attest to having completed an annual assessment of all nine guides in the SAFER Guides measure, under the Protect Patient Health Information objective;
- Remove attestation statements 2 and 3 from the Promoting Interoperability Program’s prevention of information blocking attestation requirement;
- Increase the minimum required score for the objectives and measures from 50 points to 60 points (out of 100 points) to be considered a meaningful EHR user; and
- Adopt two new eCQMs to the Medicare Promoting Interoperability Program’s eCQM measure set beginning with the reporting period in CY 2023, in addition to removing four eCQMs from the measure set beginning with the reporting period in CY 2024 (in alignment with proposals for the Hospital IQR Program).
Questions? Contact the experts at Kentucky REC for all your hospital Promoting Interoperability questions. We’re here to help: 859-323-3090.
Jul 19, 2021
SAVE THE DATE! DECEMBER 2, 2021 – Kentucky REC Annual Conference
In Person with a Virtual Option – Lexington Kentucky, Location to be Determined
During our day together, we’ll discuss quality initiatives, HIPAA, Telehealth, and more to ensure that clinicians, hospital administrators, and clinic staff are well prepared for the challenges of modern healthcare.
Details, Agenda, and Registration Coming Soon!
Questions? Contact us at Kentucky REC or call us at 859-323-3090.
Jun 8, 2021
Applications for the 2021 MIPS Promoting Interoperability Performance Category Hardship Exception and Extreme and Uncontrollable Circumstances Exceptions are Now Open
From CMS:
Applications are now open for the MIPS Promoting Interoperability Performance Category Hardship Exception and Extreme and Uncontrollable Circumstances Exception for the 2021 Performance Year. Those interested must submit their applications to CMS by December 31, 2021.
Who is Eligible for a Promoting Interoperability Hardship Exception?
MIPS eligible clinicians, groups, and virtual groups may submit a MIPS Promoting Interoperability Performance Category Hardship Exception Application whether they’re reporting traditional MIPS or the APM Performance Pathway. Exceptions are granted if they:
• Are a small practice
• Have decertified EHR technology
• Have insufficient Internet connectivity
• Face extreme and uncontrollable circumstances such as disaster, practice closure, severe financial distress or vendor issues, or
• Lack control over the availability of CEHRT
NOTE: If you’re already exempt from submitting Promoting Interoperability data, you don’t need to apply.
For APM Participants
MIPS eligible clinicians and groups with MIPS eligible clinicians participating in a MIPS APM can apply for Promoting Interoperability hardship exceptions and qualify for automatic reweighting just like other MIPS eligible clinicians. If you’re participating as an APM entity, you will receive the APM Entity’s score, but will be excluded from the calculation when CMS creates an average Promoting Interoperability score for the APM Entity.
Who is Eligible for an Extreme and Uncontrollable Circumstances Exception?
MIPS eligible clinicians, groups, and virtual groups may submit an application to reweight any or all MIPS performance categories if they’ve been affected by extreme and uncontrollable circumstances extending beyond the Promoting Interoperability performance category. These circumstances must:
• Cause you to be unable to collect information necessary to submit for a MIPS performance category
• Cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the quality performance category for 3 months), and/or
• Impact your normal process, affecting your performance on cost measures and other administrative claims measures
NOTE: For the 2021 Performance Year we will continue to use our extreme and uncontrollable circumstances policy to allow clinicians, groups, virtual groups, and APM Entities to submit an application requesting reweighting of performance categories due to the current COVID-19 public health emergency.
For APM Entities
APM entities participating in MIPS APMs are also able to submit an Extreme and Uncontrollable Circumstances Exception Application that includes differences from the existing policy for individual, groups, and virtual groups.
• APM Entities are required to request reweighting for all performance categories
• Additionally, at least 75% of an APM Entity’s MIPS eligible clinicians must qualify for reweighting in the Promoting Interoperability performance category
• Data submission for an APM entity will not override performance category reweighting
• Users must have the Security Official role for their organization to submit an application on behalf of an APM Entity
How do I Apply?
In order to apply you must create a HCQIS Access Roles and Profile (HARP) account to submit an Extreme and Uncontrollable Circumstances Application. For more information on how to obtain a HARP account, refer to the Register for a HARP Account document in the QPP Access User Guide, found by entering “access user guide” in the Resource Library.
• You must have the Security Official role to submit an application on behalf of an entire APPM Entity. For more information on how to obtain a Security Official role, refer to the Connect to an Organization document in the QPP Access User Guide, found by entering “access user guide” in the Resource Library.
Once you sign into QPP with your HARP credentials, click ‘Exceptions Application’ on the left-hand navigation and then select ‘Extreme and Uncontrollable Circumstances’ or ‘Promoting Interoperability Hardship.’
How do I know if I’m Approved?
If you submit an application for either exception, you’ll be notified by email if your request was approved or denied. If approved, this will also be added to your eligibility profile on the QPP Participation Status Tool.
For More Information
Visit the MIPS Promoting Interoperability Performance Category Hardship Exception and Extreme and Uncontrollable Circumstances Exception QPP webpages for more information and link to the application.
Download the 2021 MIPS Promoting Interoperability Hardship Exception Application Guide and the 2021 Extreme and Uncontrollable Circumstances Exception Application Guide now available on the QPP Resource Library.
Questions?
Contact the Quality Payment Program at 1-866-288-8292 or by e-mail at: QPP@cms.hhs.gov. Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.
Contact the experts at Kentucky REC for all your QPP, MIPS, and APM questions. We’re here to help: 859-323-3090.
Apr 23, 2021
Webinar – Key Aspects to an Effective HIPAA Compliance Program in a Virtual World
Thursday, May 27, 2021 12:00 PM ET
Our experts will discuss what comprises an effective HIPAA Compliance Program and how to adapt to the current Healthcare environment during and after the national emergency.
We will highlight the importance of and requirements for staying HIPAA compliant in terms of Privacy and Security. We’ll go over the definitions of safeguards including Administrative, Technical and Physical and will break down an effective compliance program into 6 basic categories including:
- Security Risk Analysis
- Policies and Procedures – Administrative, Physical and Technical
- HIPAA Training & Education
- Business Associate Tracking
- Incident Tracking
- Mitigation Planning
Our team will also discuss the current threats posed to the healthcare environment including recent breach reports, ransomware attacks, and other hot topics surrounding HIPAA security.
Call 859-323-3090 or email Kentucky REC HIPAA Privacy and Security experts with your questions, or if you want to talk to an advisor to schedule a Security Risk Analysis with us this year.
Mar 29, 2021
We are in the midst of the final year of the Medicaid EHR Incentive Program: PY2021. The August 31, 2021 deadline is much earlier than all previous years. Along with the early deadline, the required responses to COVID-19 have made it difficult for many practices to achieve Promoting Interoperability. Therefore it is crucial to know exactly what is required, and the important objectives that need your attention.
We plan to have a guest speaker from a Kentucky practice who will share their best practices, and guidance on what has helped them be successful this past year. Besides the guest speaker, topics will include: program requirements, stage 3 measures, and important next steps. We are here to assist all eligible providers earn this final year’s incentive money.
Let us help you be prepared and successful when tackling Stage 3. Register now to learn more.
Webinar: KY Medicaid Promoting Interoperability (MU) for EPs: Preparing for PY2021
Tuesday, April 27, 2021 12:00 pm ET
Contact us at Kentucky REC with your questions about Promoting Interoperability. Our team of experts is here to help: 859-323-3090.
“This effort was made possible by Grant Number PON2 746 2000001660 from KY CHFS and US DHHS. The project described was supported by Grant Number PON2 746 2000001660 from KY CHFS and US DHHS.”
Join our partners at KHIE (Kentucky Health Information Exchange) for the 2021 virtual eHealth Summit, as they share the transformation of Health Information Technology (HIT) and KHIE technological enhancements over the past year. As the pandemic exposed new challenges in HIT, KHIE responded by implementing new features and services such as Patient Alert Query Service, Direct Data Entry for labs providing COVID-19 test results, Electronic Case Reporting for reportable diseases, the new Image Exchange, and much more.
Keynote Speaker – 9 am: Dr. Alicia Farlese will provide insight on the state of HIT from a national perspective, with particular emphasis on federal HIT policy changes, and their impact on Kentucky healthcare providers. Dr. Farlese, DNP, RN-BC, is a retired Captain/O-6 and previous senior leader in national health IT policy and programs at the US Department of Health and Human Services, contributing to many health IT regulations, such as the 21st Century Cures Act.
