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CynergisTek is alerting you to a number of changes the Centers for Medicare & Medicaid Services (CMS) is proposing to the requirements of the EHR Incentive Program that would apply to the program in either 2017 or 2018. The changes to the EHR Incentive Program, which would primarily apply to hospitals, are contained in a proposed rule, Medicare Program: Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long Term Care Hospital Prospective Payment System and Proposed Policy Changes and Fiscal Year 2018 Rates, which is due to be published in the Federal Register on April 28th. The publication of the proposed rule in the Federal Register will start the customary 60-day public comment period which would be scheduled to end June 27, 2017.

Changes for 2017 Program Year

CMS is proposing to change the data collection period for Critical Access Hospitals (CAH) and Eligible Hospitals (EH) reporting of clinical quality measures (CQM) data in calendar year 2017 to be two self-selected quarters. The EH or CAH would report on any 6 self-selected available CQMs. EPs would report on data collected over a 90, continuous day period while the CQMs reported would be those set by the rules governed through the MIPS program.

For the EH or CAH attesting to use of a certified EHR technology (CEHRT) to the 2015 Edition Standards for CEHRT set by ONC, they are reminded to include within the scope of the required risk analysis required by the HIPAA Security Rule an assessment of the certified API enabled as part of the CEHRT. For 2017, use of CEHRT certified to the 2015 Edition Standards for CEHRT is optional.

Changes for 2018 Program Year

The 21st Century Cures Act provides that HHS set standards for the decertification of a EHR that had previously been recognized as meeting the requirements for CEHRT. CMS is establishing a process for EHs and CAHs whose EHR is decertified during a program year to apply for a waiver to avoid the penalty for failing to demonstrate use of a certified EHR.

CMS is using this proposed rule to affirm it will move forward with implementing the controversial Stage 3 requirements for the EHR Incentive Programs in 2018. Among the changes required in Stage 3 is that EHs, CAHs and EPs use CEHRT and meet the 2015 Edition Standards set by ONC. Many providers and EHR vendors say that they have not had enough time to develop and safely implement the upgrades to the EHR technology required by Stage 3. While moving ahead with adoption of Stage 3, the agency says it will consider “flexibility” to adopting the 2105 CEHRT in 2018 if its monitoring of the industry trends finds low availability of the upgraded EHR technology or problems in the installation or implementation of these systems.

Data Collection Period

CMS is proposing the data collection period 90 consecutive days for any hospital or provider attesting for EHR Incentive Program and to make that requirement permanent beginning with the 2018 program year.

Conclusion

The proposed rule making issued by CMS for changes to the 2017-18 EHR Incentive Program is just that; a proposal. There is no firm date by which CMS would adopt a final rule. CMS could also make modifications to the rule making when it is adopted in its final form. The Stage 3 standards implementation in 2018 has long been opposed by many in the industry and their patrons in Congress. There is uncertainty if CMS will be allowed to implement Stage 3 in its present form.

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