CMS Finalizes Hospital Outpatient Prospective Payment System (OPPS) Changes to Better Support Hospitals and Physicians and Improve Patient Care
Today, the Centers for Medicare & Medicaid Services (CMS) finalized updated payment rates and policy changes in the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System for calendar year (CY) 2017. These finalized policy changes will improve the quality of care Medicare patients receive by better supporting their physicians and other health care providers and reflect a broader Administration-wide strategy to create a health care system that results in better care, smarter spending, and healthier people.
Improving Patient Care through Technology
CMS is supporting physicians and other providers through today’s rule by increasing flexibility for eligible professionals, eligible hospitals and critical access hospitals that participate in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. On October 14, 2016 CMS released the final rule on the new Quality Payment Program for clinicians (CMS-5517-FC), which includes provisions establishing the Merit-Based Incentive Payment System (MIPS), a new program for certain Medicare-enrolled practitioners with a focus on: quality; improvement activities; cost; and use of certified EHR technology to support interoperability and advanced quality objectives. For more information, please visit: http://www.hhs.gov/about/news/2016/10/14/hhs-finalizes-streamlined-medicare-payment-system-rewards-clinicians-quality-patient-care.html.
Today, CMS is making changes under the Medicare EHR Incentive Program for eligible hospitals and critical access hospitals attesting to CMS, including hospitals that are eligible to participate in both the Medicare and Medicaid EHR Incentive Programs (dual-eligible hospitals), by eliminating the Clinical Decision Support (CDS) and Computerized Order Entry (CPOE) objectives and measures beginning in 2017. CMS is reducing a subset of thresholds for the remaining objectives and measures for Modified Stage 2 and Stage 3. Additional changes include allowing all returning participants in the EHR Incentive Programs to report on a 90-day EHR reporting period in 2016 and 2017. CMS is also finalizing an application process for a one-time significant hardship exception to the Medicare EHR Incentive Program for certain eligible professionals in 2017 who are also transitioning to MIPS. These additions both increase flexibility, lower the reporting burden for providers, and focus on the exchange of health information and using technology to support patient care.
Changes Specific to the Electronic Health Record (EHR) Incentive Program
- 90-Day EHR Reporting Period in 2016 and 2017
We proposed to change the EHR reporting period in 2016 to any continuous 90-day period within CY 2016 for all returning EPs, eligible hospitals and CAHs that have previously demonstrated meaningful use in the Medicare and Medicaid EHR Incentive Programs. We are finalizing a 90-day EHR reporting period in 2016 and 2017 for all returning EPs, eligible hospitals and CAHs that have previously demonstrated meaningful use in the Medicare and Medicaid EHR Incentive Programs. We are extending the 90-day EHR reporting period to include 2017 secondary to stakeholder comments indicating concerns with implementing API functionalities for Stage 3, program and systems changes in 2017 as well as to allow eligible clinicians time to MIPS for Medicare eligible clinicians, and to continue preparation of Stage 3 and the 2015 Edition. The EHR reporting period will be any continuous 90-day period between January 1st and December 31st in CY 2016 and CY 2017.
- Removal of the Clinical Decision Support (CDS) and Computerized Provider Order Entry (CPOE) Objectives and Measures and Reduction of a Subset of the Remaining Objectives and Measures for EHs
We proposed to eliminate the Clinical Decision Support (CDS) and Computerized Provider Order Entry (CPOE) objectives and measures for eligible hospitals and CAHs attesting under the Medicare EHR Incentive Program for Modified Stage 2 and Stage 3 for 2017 and subsequent years. We also proposed to reduce the thresholds of a subset of the remaining objectives and measures in Modified Stage 2 for 2017 and in Stage 3 for 2017 and 2018 for eligible hospitals and CAHs attesting under the Medicare EHR Incentive Program. We are finalizing these proposed changes to the objectives and measures for all eligible hospitals and CAHs that attest to meaningful use under Medicare, and are including hospitals that are eligible to participate in both the Medicare and Medicaid EHR Incentive Programs (dual-eligible hospitals). These changes would not apply to Medicaid-only hospitals and CAHs that attest under their State Medicaid Agency, however, they do apply to hospitals that are participating in the Medicaid EHR Incentive Program by attesting to CMS.
- New Participants in 2017
After the publication of the 2015 EHR Incentive Programs Final Rule, CMS determined that, due to cost and time limitation concerns related specifically to 2015 Edition CEHRT updates in the EHR Incentive Program Registration and Attestation System, it is not technically feasible for EPs, eligible hospitals, and CAHs that have not successfully demonstrated meaningful use in a prior year (new participants) to attest to the Stage 3 objectives and measures in 2017 in the EHR Incentive Program Registration and Attestation System. Therefore, we are finalizing proposals that EPs, eligible hospitals, and CAHs that have not successfully demonstrated meaningful use in a prior year would be required to attest to Modified Stage 2 objectives and measures by October 1, 2017. Returning EPs, eligible hospitals, and CAHs will report to different systems in 2017 and therefore would not be affected by this proposal.
- Significant Hardship Exception for New Participants Transitioning to MIPS in 2017
We are finalizing proposals that certain EPs, who are new participants in the EHR Incentive Program in 2017 and are transitioning to MIPS in 2017 can apply for a significant hardship exception from the 2018 payment adjustment as authorized under section 1848(a)(7)(B) of the Act using a CMS developed hardship exception application process specific to this policy.
- Modifications to Measure Calculations for Actions Outside of the EHR Reporting Period
We are finalizing changes to the policy for measure calculations such that, for all meaningful use measures, unless otherwise specified, beginning in CY 2017 actions included in the numerator must occur within the EHR reporting period if that period is a full calendar year, or if it is less than a full calendar year, within the calendar year in which the EHR reporting period occurs.
For more information:
The OPPS/ ASC Final Rule with comment period and the IFC are available on the Federal Register at https://www.federalregister.gov/public-inspection.
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