HIMSS tells CMS: Finalize 90-day reporting now, align requirements for MU and MIPS
In a letter sent to acting CMS Administrator Andy Slavitt on Sept. 1, HIMSS reiterated its desire to see a less prescriptive EHR Incentive Program that works best for providers. Key to making that happen: the quick finalization of a 90-day meaningful use reporting period for 2016.
To keep a focus on the key issues – interoperability and data sharing – that simplified 90-day reporting for eligible professionals, eligible hospitals and critical access hospitals is essential to maintaining meaningful use's flexibility, said HIMSS, responding to CMS' July 14 proposed rule for its Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs.
By the same token, HIMSS Board Chair Michael Zaroukian, MD, and CEO H. Stephen Lieber expressed support for a one-time hardship exception from CMS' 2018 payment adjustment for those EPs who are new participants in the EHR Incentive Program in 2017, as well as those practices transitioning next year to the Merit-Based Incentive Payment System outlined in MACRA.
With so much recent regulatory activity, the letter expressed concern that "changes made to the EHR Incentive Program for 2016 will not be finalized before the start of the year's final possible 90-day reporting period and will create more confusion for providers."
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Because 90-day reporting was for 2015 meaningful use wasn't finalized until after the start of the final period, "many providers were not able to take advantage of the additional flexibilities" – instead, they were forced to rely on hardship exceptions, Zaroukian and Leiber pointed out.
"In order to avoid a repeat in 2016, it is vital that the 90-day reporting period for 2016 be finalized as soon as possible," they wrote. "If the promulgation of this Final Rule is similarly delayed, CMS must be prepared to provide the flexibility for hardship exceptions as was done in 2015."
In addition, HIMSS recommended that CMS further align the reporting requirements for the Medicare and Medicaid EHR Incentive Programs with those of MIPS, to help reduce the need for multiple reports from IT systems.
"Such a change will assist the program simplification CMS is seeking to achieve. One benefit of the MIPS performance category weighted structure is that it relieves providers of the burden of meeting a 3 variety of high measure thresholds that may not add value to their individual practice," wrote Zaroukian and Lieber. "Eliminating measures and adjusting thresholds is a good start toward what should be a much more cohesive convergence between the hospital EHR Incentive Program and the quality and Advancing Care Information components of MIPS in the future."