EHRA to CMS on IPPS rules: Focus 'high-value' measures, keep 90-day reporting

The HIMSS EHR Association tells the Centers for Medicare & Medicaid Services that the Promoting Interoperability Program needs consistency and specificity in its clinical requirements.
By Mike Miliard
01:10 PM

The HIMSS Electronic Health Record Association submitted comments to the Centers for Medicare and Medicaid Services this week about its proposed Inpatient Prospective Payment System rules for acute and long-term care hospitals.

WHY IT MATTERS
In its letter to CMS Administrator Seema Verma about the 2020 IPPS Proposed Rule, the HIMSS EHR Association, which represents more than 30 health IT vendors, said it appreciated the agency's efforts to "facilitate interoperability and to reduce clinician burden by focusing on high-value reporting measures." (HIMSS is the parent company of Healthcare IT News.)

It commented on an array of potential requirements put forth by CMS, such as proposed adoption of two new opioid-related electronic clinical quality measures, prospective rules around integration of patient-generated health data, ways to promote patient safety within the EHR and more.

The association told CMS that it's especially supported of proposed new measures for "high priority clinical areas" such as opioid use.

"New measures provide flexibility to providers and improve clinical process and outcomes, provided that measures are technically feasible and are introduced within attainable timeframes," said EHRA.

On the other hand, "pushing poorly specified measures into the Promoting Interoperability Program leads to wasted time and effort on the part of providers, healthcare organizations, developers and regulators."

With regard to opioids, the technology vendors represented by EHRA said they appreciate having CMS giving developers "sufficient time to implement new opioid-related electronic clinical quality measures, until CY 2021. We continue to encourage reasonable timeframes that do not have to be re-evaluated or pushed to a later date."

The group also supports the continuance of a 90-day reporting period, and asked that it be established permanently, "so that hospitals and developers can appropriately plan in advance, instead of waiting for annual rulemakings."

EHRA also applauded new efforts at "consistency across programs" from CMS, especially with regard to the measures proposed in the Promoting Interoperability Program. In the past, it noted, many such requirements weren't adequately specified in the clinical terms that IT developers needed to "interpret and translate into software code that is implemented in their individual systems."

When Promoting Interoperability rules "move toward measuring clinical concepts, but do not provide the detailed specifications and value sets that are necessary for electronically implementing measures that are evaluating clinical concepts, they are not successful," the group said.

THE LARGER TREND
HIMSS EHR Association was one of the myriad health IT stakeholder groups that offered its feedback to CMS and the Office of the National Coordinator for Health IT on their proposed interoperability rules this past month.

The group noted that it supports the rules' basic goals, but has concerns about their "tremendously broad reach."

Specifically, "we have significant concerns regarding timelines, ambiguous language (and) disincentives for innovation," EHRA noted. It also pointed out that "vague or ambiguous regulatory language can pose tremendous risk to affected stakeholders," and sought that "additional clarifications and examples be made before finalization of the rule."

ON THE RECORD
With regard to added expectations for the Promoting Interoperability Program, the EHR Association noted that it is "concerned that CMS repeatedly changes the expectation for measurement of actions happening outside the reporting period with regulatory guidance and FAQs.

"Changes of this type generate waste for EHR developers and providers to implement trivial measure updates," said the group. "We strongly urge CMS to clearly specify their measures, ensure the specifications are aligned across programs (MIPS, Medicare PI, Medicaid PI, etc.), and keep the specifications consistent to avoid this waste."

Twitter: @MikeMiliardHITN
Email the writer: mike.miliard@himssmedia.com

Healthcare IT News is a publication of HIMSS Media.