Looking Ahead to the EHR Incentive Programs Beyond 2016

cms-twitter-200National Health IT Week was September 26-30, 2016. CMS has been sharing guidance to help providers and industry members participate successfully in ongoing CMS health IT initiatives.

The Centers for Medicare & Medicaid Services (@CMSGov) recently released two proposed rules and a final rule that will affect the future of the Medicare and Medicaid EHR Incentive Programs. These include the:

FY 2017 Hospital Inpatient Prospective Payment Systems (IPPS) for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes final rule.

The FY 2017 Hospital IPPS final rule includes changes that require providers to report four quarters of data for eight of the fifteen Hospital IQR clinical quality measures (CQMs). These changes have been made to reduce reporting burden and align program requirements, and would apply to the 2019 payment determination.

Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) proposed rule.

The MACRA proposed rule establishes the Quality Payment Program (QPP), which is set to begin January 1, 2017. Starting in 2017, Medicare EPs will participate in the QPP instead of the Medicare EHR Incentive Program. (Note: This does not apply to Medicaid-only EPs.)

During 2017, eligible physicians and other clinicians will be able to “pick their pace,” and will have four options for participation in the QPP. By choosing one of these options, physicians will avoid a negative payment adjustment in 2019. For specific details about the participation options, see the CMS blog post: Plans for the Quality Payment Program in 2017: Pick Your Pace.

Calendar Year (CY) 2017 Changes to the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) proposed rule.

The CY 2017 OPPS ASC proposed rule recommends:

  • Eliminating the Clinical Decision Support (CDS) and Computerized Provider Order Entry (CPOE) objectives and measures beginning in 2017; and reducing the thresholds for a subset of the remaining objectives and measures in Modified Stage 2 in 2017 and Stage 3 in 2017 and 2018 for eligible hospitals and critical access hospitals (CAHs) attesting under the Medicare EHR Incentive Program.
  • Requiring new participants (eligible professionals [EPs], eligible hospitals, and CAHs) to attest to Modified Stage 2 by October 1, 2017 to avoid the 2018 Medicare payment adjustment.
  • Revising the EHR reporting period in 2016 to a minimum of 90 consecutive days for all returning participants.
  • Modifying measure calculations for actions outside the EHR reporting period.
  • Allowing certain EPs to apply for a significant hardship exception from the 2018 Medicare payment adjustment if they are: new participants who intend to attest to meaningful use for an EHR reporting period in 2017, or who intend to transition to the Merit-based Incentive Payment System (MIPS) and report on measures specified for the Advancing Care Information Performance Category.

For More Information
To learn more about the future of the EHR Incentive Programs, visit the CMS EHR Incentive Programs website. CMS will continue to update the website to include additional information and resources for EPs, eligible hospitals, and CAHs. Stay tuned!