On Tuesday, April 24th, the Centers for Medicare & Medicaid Services (CMS) released a new 1,883-page proposed rule that will rename and rebrand Meaningful Use as Promoting Interoperability. The proposed rule is currently open for public opinion, and no policies will be enacted until the final rule is released in August. We wanted to share with you, our readers, some initial details of this proposed rule and how your organization may be affected.
- Meaningful Use Program will be renamed the “Promoting Interoperability Program.”
- The pass/fail approach will be eliminated, but failure to meet specific criteria will constitute an overall failure.
- CMS is proposing a 100-point scoring system with 50 points needed to be successful in 2019.
- The new system would consist of four objectives and eight measures. The risk assessment would be required, but not scored.
- Hospitals MUST report on all required measures.
- The Care Coordination objective and anything related to it has been removed in the new proposal.
- There will be a 90-day reporting period for 2019 and 2020.
Within the new rule, CMS is proposing to do away with one of the things that provider organizations have complained a lot about: the meaningful use patient data access objective (view, download and transmit). By doing this, CMS is not saying that allowing patients to view, download and transmit their information is unimportant.
They are, however, signaling that they think it’s more critical that hospitals participate in the program, without objectives that routinely cost them a percentage point or two in reimbursement. In essence, CMS is proposing to make things easier for hospitals.
A new scoring methodology, set to begin in 2019, is also among CMS’s proposed changes to the new rule. Through the discretion offered by Congress in the Bipartisan Budget Act of 2018, CMS is removing the escalator clause in the HITECH Act that required them to make the program harder over time. The new scoring methodology reduces the burden on healthcare organizations and provides greater flexibility while focusing on increased interoperability and patient access.
The proposed scoring changes include:
- Fewer measures – from 16 down to six
- Fewer objectives – from six down to four
- The four objectives would be comprised of ePrescribing, Health Information Exchange, Provider to Patient Exchange, and Public Health & Clinical Data Exchange
- Scoring would occur at the individual measure level and be based on a hospital’s performance
- A hospitals aggregate performance on the measures would constitute its score
- There would be a possible 100 points total available, and at least 50 points need to be successful in 2019 to avert a penalty
CMS stated, “Our vision is for every eligible hospital and CAH (critical access hospital) to perform at 100 percent for all of the objectives and associated measures… We believe that the 50-point minimum Promoting Interoperability score provides the necessary benchmark to encourage progress in interoperability and also allows us to continue to adjust this benchmark as eligible hospitals and CAHs progress in health IT.”
The new scoring would apply to Medicare-only and dual eligible hospitals. It would not apply to Medicaid-only hospitals. It would, however, be optional for states to apply the new methodology to Medicaid providers via their State Medicaid HIT Plans. CMS is also considering whether they should extend similar flexibilities to Medicaid eligible professionals.
And, if CMS does not adopt the newly proposed scoring system, they note it’s the agency’s intent to remain with the existing Stage 3 requirements (except for adding two new opioid measures). Hospitals’ scores would be based upon numerators and denominators for each measure (except for public health measures that have “yes/no”).
We would love to hear from our readers with their thoughts on the proposed rule. Tell us what you think by commenting on our social media posts.
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