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What IT leaders need to know about CMS' proposed changes to its hospital PI program

By Camille BridgerJoseph Leonard

May 21, 2021

    CMS last month released the 2022 Inpatient Prospective Payment System proposed rule, and the proposal includes a number of updates that require IT leaders' attention.

    The hospital Promoting Interoperability (PI) program is one way that CMS promotes meaningful use of certified EHR technology (CEHRT) to exchange electronic health information to support care delivery and empower patients through access to their data. Hospitals must collect and report data to CMS and meet performance requirements on PI measures. Because EHR configuration and workflows are integral to meeting PI requirements, IT leaders must stay up to date on how CMS plans to evolve the program.

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    The proposed 2022 updates IT leaders need to watch

    CMS proposed several changes to the PI program that aim to promote EHR safety and increase access to and exchange of patient health data. Of these updates, there are a few in particular that may involve updating your EHR configuration and workflows. These proposed updates include:

    • New data requirements to increase the availability of and access to data for patients;
    • A new optional measure to promote bi-directional health information exchange (HIE);
    • Increasing the public health reporting requirement to four measures;
    • Changes to eCQM options in 2023 and beyond; and
    • 2015 Edition Cures Update CEHRT functionality, required beginning 2023.

    How IT leaders should start preparing for the 2022 program year and beyond

    IT leaders need to assess whether it's necessary to implement EHR updates in response to PI program changes—and that involves working closely with many key stakeholders, such as EHR vendors, quality leaders, clinical leaders, and more to determine the best approach and timeline.  

    While it's important to focus on preparing for 2022, don't lose sight of proposals for 2023 onward that would require more lead time to implement. That means IT leaders should start planning now by taking these four steps:

    1. Evaluate your EHR's technical capabilities. Hospitals may need to update their EHR to meet proposed changes to PI measures for 2022. For example, this could involve updating your system configuration to provide patients access to their electronic health information. IT leaders should confirm that the EHR can support the proposed policy for making data available as far back as 2016 and going forward indefinitely.


    2. Check whether new EHR interfaces are necessary. Depending on your state public health agency's readiness, hospitals may need to establish additional interfaces. For example, if Electronic Case Reporting is available in your jurisdiction, then IT leaders may need to prioritize this work if CMS finalizes the proposal to require four public health measures.


    3. Prioritize EHR updates that boost your PI score. CMS proposed to increase the minimum required score to 60 points, which means hospitals need to raise the bar on their performance. At the same time, the proposal includes opportunities to earn more points. For example, hospitals can choose to report the new optional bidirectional HIE measure to earn 40 points. This is in place of the two existing measures that typically yield low scores due to factors outside hospitals' control.


    4. Be proactive about future updates that would require more technology changes. Communicate with your EHR vendor about their timeline for implementing the 2015 Cures Update CEHRT functionality in 2023 and roadmap for implementing newly proposed eCQMs.  Also coordinate with your quality department on eCQM strategy to address proposed removals in 2024. If the eCQMs your hospital reports are impacted, you'll need to consider implementing alternate measures.
    We expect CMS to release its final IPPS rule in July or August. In the meantime, public comment on the proposal is due June 28 at 5 PM EST, and we strongly recommend you share your feedback on the proposed updates with CMS. For more detail on the proposed PI changes and considerations for your public comment, see our Policy Primer.

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