2018 IPPS Proposed Rule
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2018 IPPS Proposed Rule

CMS Proposes changes to the Hospital Inpatient Quality Reporting (IQR) and Medicare & Medicaid EHR Incentive Programs


In mid-April, CMS issued the FY 2018 IPPS Proposed Rule, which included proposals for the Hospital Inpatient Quality Reporting Program (IQR) and the Medicare and Medicaid EHR Incentive Programs for the 2017 and 2018 reporting periods.

Proposed Changes to eCQM Requirements in the Hospital IQR Program

CMS is proposing to modify the previously finalized eCQM reporting requirements for the CY 2017 reporting period (FY 2019 payment determination). Hospitals would be required to select and submit 6 of the available eCQMs, reduced from 8 eCQMs, as previously finalized. Additionally, CMS proposed that hospitals would submit 2 self-selected calendar year quarters of data, reducing the requirement from the full calendar year, 4 quarters.

CMS is also proposing to modify the previously finalized eCQM reporting requirements for the CY 2018 reporting period (FY 2020 payment determination). Hospitals would be required to select and submit 6 of the available eCQMs, reduced from 8 eCQMs, as previously finalized. Additionally, CMS proposed that hospitals would submit the first three calendar quarters (Q1-Q3) of CY 2018, reducing the requirement from the full calendar year, 4 quarters.

In terms of the previously finalized eCQM validation process, CMS is proposing a few modifications. For hospitals selected to participate in this process, CMS is proposing that it will select 8 cases per quarter for the CY 2017 reporting period (FY 2020 payment determination) and subsequent years. Thus, if the eCQM reporting requirements are finalized as proposed, hospitals participating in eCQM validation would be required to submit 16 cases over two calendar quarters (8 cases x 2 quarters) for the CY 2017 reporting period and 24 cases over three quarters (8 cases x 3 quarters) for the CY 2018 reporting period. Furthermore, CMS has proposed to expand the types of hospitals that could be excluded from the random sample selected for eCQM validation. In the FY 2017 IPPS Final Rule, CMS finalized that hospitals may be 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 proposed that a hospital would also be excluded if it does not have at least 5 discharges for at least one reported eCQM included among their QRDA I file submissions. In regards to the selection of cases, CMS is proposing to exclude any cases from validation with episodes of care longer than 120 days or with a zero denominator for each measure. At this time CMS has not proposed any changes to the medical record submission requirements as finalized in the FY 2017 IPPS Final Rule for FY 2020 payment determination; CMS is proposing to continue these requirements for the FY 2021 payment determination and subsequent years.

CMS is also proposing 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.

Proposed Changes to the Medicare and Medicaid EHR Incentive Programs

In the FY 2018 Proposed Rule, CMS is proposing some modifications to the reporting requirements for eligible hospitals and critical access hospitals (CAHs) participating in the EHR Incentive Program. For the CY 2017 reporting period, CMS has proposed that for new and returning hospitals reporting CQMs electronically to demonstrate meaningful use, the hospitals would be required to report at least 6 of the available eCQMs for 2 self-selected quarters in CY 2017. For the CY 2018 reporting period, CMS has proposed that for new and returning hospitals reporting CQMs electronically to demonstrate meaningful use, the hospitals would be required to report at least 6 of the available eCQMs for the first 3 quarters (Q1-Q3) of CY 2018. This aligns with the proposals for reporting eCQMs in the Hospital IQR program.

In the proposed rule, CMS is proposing some changes for eligible professionals (EPs) participating in the Medicaid EHR Incentive Program. For CY 2017, CMS has proposed to modify the reporting period for EPs reporting CQMs electronically to a minimum of a continuous 90-day period during the calendar year. Additionally, CMS is proposing to align 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 is also proposing that EPs report 6 CQMs with no domain requirement, instead of 9 CQMs across 3 domains, as is currently finalized.

For CY 2018, CMS is proposing to reduce 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. 

Proposed Changes Regarding 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 is also proposing 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 would require that a hospital has its EHR technology certified to all eCQMs that are available to report, but 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 inviting public comment on options for offering flexibility in CY 2018 related to EHR certification requirements. One possible option is allowing hospitals to use technology certified to the 2014 Edition or the 2015 Edition in CY 2018 or another option is allowing a combination of EHR technologies certified to the 2014 Edition and 2015 edition in CY 2018.


By Alexis Donnaruma at 4 May 2017, 11:13 AM
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