ED Coding and Reimbursement Alert

Question: Our ED just got a handle on the MIPS and other fairly new programs, and now our office manager heard at a seminar that they are changing. Can you advise?

Codify Subscriber

Answer: If your head is spinning over all the changes CMS has unloaded in the last year, you're in good company. And the overhauls and curtailments keep coming, recent Medicare change-ups suggest.

Background: In 2011, the Medicare and Medicaid EHR Incentive programs were introduced to encourage medical professionals to "adopt, implement, upgrade (AIU), and demonstrate the meaningful use of certified EHR technology (CEHRT)" in order to better serve patients, stressed CMS in a release. Over the years, Meaningful Use (MU), as the programs came to be known, chugged along with mixed reviews, both improving the delivery of care and encouraging data sharing, but also hampering it.

However, recent programs like MACRA's Quality Payment Program (QPP), Patients Over Paperwork, and Meaningful Measures aimed to put patients' needs before unwieldy protocols while reducing providers' hefty administrative burdens in the process. All of these factors - compounded with the agency's MyHealthEData initiative announced in February and federal talk that EHR-mandate changes were coming - produced "Promoting Interoperability" or PI, which is the reworked MU. PI is outlined in the 2019 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long Term Acute Care Hospital (LTCH) Prospective Payment System proposed rule set for publication in the Federal Register on May 7, 2018.

Hints from the agency and other federal health programs over the last year suggest the name change and policies to go with it are not unexpected. "We are renaming the program 'Promoting Interoperability,' to reflect the program's new emphasis on providing healthcare information to patients in an electronic format and sharing information electronically among providers," explained Verma at Health Datapalooza in Washington, D.C., last month.

In addition to Promoting Interoperability, CMS also points out other technical components that it plans to revise in 2019 and beyond. These include:

• Electronic Clinical Quality Measures (eCQMs) 2019. According to the proposal, eligible hospitals and critical access hospitals (CAHs) will need to report only four "self-selected" eCQMs of the 16 options for one quarter of CY 2019. CMS advises that the submission period be the first two months of the new year and end on Feb. 29, 2020, for 2019 measures.
• eCQMs 2020. "We propose to remove eight of the 16 eCQMs consistent with CMS's commitment to producing a smaller set of more meaningful measures and in alignment with the Hospital IQR Program," the agency fact sheet on the proposed rule states.
• Certified EHR Technology (CEHRT). All eligible hospitals and CAHs must utilize 2015 Editions of CEHRT prior to reporting their 2019 data.
• Attestation timeline.  For both 2019 and 2020, both Medicare and Medicaid hospitals under Promoting Interoperability will need to attest for only 90 days of the calendar year.

Measures management: The MyHealthEData initiative release suggested that CMS would scale back quality measures to assist Medicare providers with reporting, and that is exactly what the IPPS proposed rule language suggests. A revamped scoring methodology and two new measures, "Query of the PDMP and Verify Opioid Treatment Agreement related to e-prescribing of opioids (Schedule II controlled substances)" are included in the proposals, the agency guidance notes. Cuts will be made to measures that don't support the electronic exchange of health information between providers and patients, the fact sheet also mentioned.

The Merit-Based Incentive Payment System (MIPS) technology component, Advancing Care Information (ACI), which replaced Meaningful Use for Part B providers in 2017, will also get a name change, according to MLN Connects. "The MIPS Advancing Care Information performance category" will become "the Promoting Interoperability performance category for MIPS eligible clinicians."

Important: Though MU and ACI will now be called Promoting Interoperability, the two programs will remain separate and do not "merge or combine the EHR Incentive Programs and MIPS," MLN Connects says.

Note: Review the IPPS proposal with information about Promoting Interoperability at https://s3.amazonaws.com/public-inspection.federalregister.gov/2018-08705.pdf and the fact sheet at www.cms.gov/Newsroom/MediaReleaseDatabase/Fact-sheets/2018-Fact-sheets-items/2018-04-24.html.