The 2019 Promoting Interoperability (PI, formerly Meaningful Use, or MU) requirements have been set in stone in the 2019 Inpatient Prospective Payment System (IPPS) final rule. IT leaders must now determine how best to implement and optimize the technology that their hospitals need to comply with the PI requirements—including a new scoring methodology. There is now a required PI score of at least 50 points to successfully demonstrate PI and avoid future penalties (see our 2019 Medicare Hospital PI Penalty Estimator).
For several years, CMS delayed the 2015 Edition Certified EHR Technology (CEHRT) mandate in response to hospital and industry feedback. Successful participation in PI next year will require that hospitals use only 2015 Edition CEHRT.
In the MU Overhaul, CMS eliminated multiple measures that hospitals would have otherwise had to report under the original Stage 3 MU requirements. This means hospitals no longer need to implement many functionalities that support those eliminated measures (e.g., Patient Education; Secure Messaging; View, Download, and Transmit [VDT]; and Patient-Generated Health Information Capture).
What's left to do to prepare for PI?
If we consider the minimum requirements for 2019 PI reporting, we are left with the CEHRT functionalities included in the table below.
Hospitals must implement these functionalities for 2019 PI reporting. Of note, PI requires that hospitals continue to provide patients with the ability to access their health information online. Specifically, the Patient Electronic Access measure still requires hospitals to fully enable the VDT capabilities and the certified API (i.e., Application Access functionalities as part of the Base EHR).
When do we need the 2015 Edition CEHRT functionalities implemented?
Hospitals don't need to have the 2015 Edition CEHRT live on January 1, 2019, which is welcome news for many organizations that have not completed their implementation. This is because CMS officially reduced the PI reporting period to a minimum of any continuous 90 days in 2019. Hospitals have more time to test and implement the required functionalities. Also, they can take this extra time to refine workflows to improve provider adoption, protect patients’ safety and privacy, and inflect performance.
To hear more about the overhaul to MU, join our webconference on Thursday, August 30, 2018 at 1 pm (ET). We will provide an overview of the new PI program and address your questions.
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