On August 2nd CMS issued the FY 2018 IPPS Final Rule which finalized modifications to the Hospital Inpatient Quality Reporting Program (IQR) and the Medicare and Medicaid EHR Incentive Programs for the 2017 and 2018 reporting periods.
Finalized Modifications to eCQM Requirements in the Hospital IQR Program
CMS finalized modifications to the previously finalized eCQM reporting requirements for the CY 2017 reporting period (FY 2019 payment determination). Hospitals will be required to select and submit 4 of the available eCQMs, reduced from 8 eCQMs, as previously finalized in the FY 2017 IPPS Final Rule and reduced from 6 eCQMs as proposed in the FY 2018 IPPS Proposed Rule. Additionally, CMS finalized that hospitals will be required to submit 1 self-selected quarter of data, reducing the requirement from the full calendar year, 4 quarters, as previously finalized and reducing the requirement from 2 self-selected quarters, as previously proposed. This reduction in both measures and reporting quarters will help reduce burden on hospitals and allow them to focus more on system upgrades, data mapping and staff training related to eCQMs.
CMS also finalized modifications to the previously finalized eCQM reporting requirements for the CY 2018 reporting period (FY 2020 payment determination). Hospitals are required to select and submit 4 of the available eCQMs, reduced from 8 eCQMs, as previously finalized in the FY 2017 IPPS Final Rule and reduced from 6 eCQMs as proposed in the FY 2018 IPPS Proposed Rule. CMS finalized that hospitals will be required to submit 1 self-selected calendar year quarters of data, reducing the requirement from the full calendar year, 4 quarters, as previously finalized and reducing the requirement from the first 3 quarters of CY 2018, as previously proposed. These finalized reporting requirements align with those of CY 2017 reporting.
For hospitals selected to participate in the eCQM validation process, CMS finalized that it will select 8 cases per quarter for the CY 2017 reporting period (FY 2020 payment determination) and subsequent years. Furthermore, CMS has expanded the types of hospitals that can be excluded from the random sample selected for eCQM validation. In the FY 2017 IPPS Final Rule, CMS finalized that hospitals are excluded from the random sample of 200 hospitals if also selected for chart-abstracted measure validation or had been granted a Hospital IQR Program Extraordinary Circumstances Exemption. In the FY 2018 IPPS Proposed Rule, CMS has finalized an additional exclusion in which a hospital is excluded if it does not have at least 5 discharges for at least one reported eCQM included among their QRDA I file submissions. In regard to the selection of cases, CMS has finalized that it will exclude any cases from validation with episodes of care longer than 120 days or with a zero denominator for each measure. CMS did not make any changes to the medical record submission requirements as finalized in the FY 2017 IPPS Final Rule for FY 2020 payment determination. Furthermore, CMS has finalized to continue these requirements for the FY 2021 payment determination and subsequent years. Hospitals will continue to be required to submit data by 30 calendar days following the medical records request date listed on the CDAC request form, provide sufficient patient level information necessary to match the requested medical record to the original eCQM data record, and submit records in PDF file format through QualityNet. CMS will continue to require submission of at least 75% of sampled cases in a timely and complete manner and the accuracy of eCQM data submitted for validation will not affect a hospital’s validation score. CMS intends for the accuracy of eCQM data validation to affect validation scores in the future and will propose any changes related to this in future rulemaking.
CMS finalized the voluntary reporting of a new hybrid measure for the CY 2018 reporting period. Hospitals can voluntarily report the Hybrid Hospital-Wide Readmission measure which uses both claims and EHR data in CY 2018.
Finalized Modifications to the Medicare and Medicaid EHR Incentive Programs
In the FY 2018 Final Rule, CMS finalized some modifications to the reporting requirements for eligible hospitals and critical access hospitals (CAHs) participating in the EHR Incentive Program. For both the CY 2017 and CY 2018 reporting periods, CMS finalized that for new and returning hospitals reporting CQMs electronically to demonstrate meaningful use, the hospitals are required to report at least 4 of the available eCQMs for 1 self-selected quarter. This aligns with the finalized requirements for reporting eCQMs in the Hospital IQR program.
In the final rule, CMS finalized some changes for eligible professionals (EPs) participating in the Medicaid EHR Incentive Program. For CY 2017, CMS has reduced the reporting period for EPs reporting CQMs electronically or by attestation to a minimum of a continuous 90-day period during the calendar year. Additionally, CMS has aligned the CQMs available to EPs participating in the Medicaid EHR Incentive Program with those available to eligible clinicians participating in the Merit-based Incentive Payment System (MIPS). CMS also finalized that EPs can report 6 CQMs with no domain requirement, instead of 9 CQMs across 3 domains, as was previously finalized.
For CY 2018, CMS finalized reducing the EHR reporting periods for new and returning participants attesting to the Medicare or Medicaid EHR Incentive Program from a full year to a minimum of any continuous 90-day period during the calendar year.
Finalized Modifications to EHR Certification
For participants in the Medicare EHR Incentive Program, CMS is proposing to add a new exception from the Medicare payment adjustments for EPs beginning with the CY 2018 payment year, for eligible hospitals beginning with beginning with the FY 2019 payment year, and for CAHs beginning with the FY 2018 payment year. For those whose certified EHR technology has been decertified under ONC’s Health IT Certification Program, they can apply through an application process that being a meaningful EHR user is not possible for this reason.
CMS also finalized changes related to the certification requirements for eCQM reporting for both the Hospital IQR Program and the Medicare EHR Incentive Program for CY 2017 and CY 2018 reporting periods. CMS now requires that a hospital has its EHR technology certified to all eCQMs that are available to report, but does not require that the certified EHR technology (CEHRT) be recertified each time it is updated to a more recent version of the eCQM specifications.
Lastly, CMS is now offering flexibility in CY 2018 related to EHR certification requirements. Eligible hospitals, CAHs and EPs now have the option to use technology certified to the 2014 Edition, the 2015 Edition or a combination of both for CY 18 reporting. A hospital or provider utilizing 2015 Edition CEHRT could attest to Stage 3 or Modified Stage 2 objectives and measures, while a hospital or provider utilizing 2014 Edition CEHRT must attest to Modified Stage 2 objectives and measures. For those utilizing
a combination of 2015 Edition and 2014 Edition CEHRT, they could attest to Stage 3 or Modified Stage 2 objective and measures, but to attest to Stage 3, their CEHRT must support certain functions that are only available as part of 2015 CEHRT.
By Alexis Donnaruma at 4 Aug 2017, 16:50 PM