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
  • All hardship exception determinations will be returned via email from 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.