The proposed PI program requirements for 2020 remain largely the same compared with existing requirements, with just a couple slight modifications. The proposal removes many of the existing electronic clinical quality measures (eCQMs) available for reporting under the PI and IQR programs starting in 2020, and adds two new opioid-related eCQMs for 2021. With so few proposed changes, stakeholders get some relief from recent major program updates. We suggest stakeholders take advantage of this opportunity to provide public comment, particularly feedback on the future of the PI program.
Promoting Interoperability (PI) Toolkit
Medicare hospital PI
The proposed 2020 hospital PI measures remain largely unchanged compared with the current program year. Hospitals are still required to complete a Security Risk Analysis during the calendar year and comply with the measure requirements of the Provider to Patient Exchange, Health Information Exchange, and Public Health and Clinical Data Exchange objectives. The proposed changes mainly affect the optional measures within the Electronic Prescribing objective. CMS intends to maintain the Query of Prescription Drug Monitoring Program measure as optional in 2020 and, beginning as early as 2019, convert it to a "yes/no" attestation. Additionally, the Verify Opioid Treatment Agreement measure is proposed to be eliminated in 2020 but would still be available for those hospitals able to report it in 2019.
The EHR reporting period remains a minimum of any continuous 90-day period for 2020 and 2021, and there is no change to the performance-based scoring methodology. Hospitals must still meet the 50-point requirement across PI measures to be considered a "meaningful user" in 2020. In addition, hospitals are required to use 2015 Edition CEHRT.
In the proposal, CMS continues to align eCQM reporting requirements under both the PI and IQR programs, both of which require electronic submission of eCQM data. Hospitals that successfully submit eCQMs for the IQR program through electronic reporting will also receive automatic credit toward the PI program's CQM reporting requirement.
The proposal maintains the requirement that hospitals report data for four eCQMs from one self-selected calendar quarter for 2020 through 2022. However, starting in 2020, CMS intends to eliminate eight existing eCQMs and, in 2021, propose two new eCQMs. Additionally, in 2022, CMS proposes a requirement for hospitals to report the Safe Use of Opioids-Concurrent Prescribing measure, along with three other measures selected from the set of available eCQMs, for a total of four eCQMs.
Public comment on the 2020 IPPS proposal is due to CMS by 5 p.m. Eastern on June 24, 2019 via regulations.gov. The proposal requests feedback on the near-term PI and eCQM policies, as well as input on the long-term development of the PI program.
Stakeholders may wish to consider the following for their comment on near-term policies:
- Support for a 90-day PI reporting period for 2020 and 2021;
- Retaining both opioid-related measures as optional in 2021;
- Allowing reporting of four self-selected eCQMs from 2020 through 2022; and
- Providing more time for hospitals to adopt new technology and measures.
CMS devotes a large portion of the proposal to the long-term future considerations for the PI program. Stakeholders should review and respond to questions CMS poses about potential future updates to the program. These updates may include:
- New measures for opioid use disorder prevention and treatment;
- Metrics to engage vendors and clinicians to improve efficiency of EHR use;
- Posting Medicare PI Program Data on the Hospital Compare website;
- Updates to the Provider to Patient Exchange objective;
- Incorporation of patient-generated health data into EHRs using CEHRT;
- Activities that promote the EHR safety; and
- Measure requiring the use of an open application programming interface (API), including reporting of such a measure as an alternative to the patient access measure.
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