EHRA Reiterates Key Recommendations for Program Alignment and Practicality in Comments on HOPPS

As we generally do with proposed regulations that impact EHR developers and their customers, the Electronic Health Record Association (EHRA) carefully reviewed and collectively commented on CMS’s proposed rule on the Hospital Outpatient Prospective Payment Systems (HOPPS) and EHR Incentive Program on September 1. Our comments, submitted on September 1 and available here, are based on the collective experiences of more than 30 EHRA member companies who service the vast majority of hospitals and ambulatory care providers using EHRs across the United States.

We put forth two key positions. The first centers around advocating for program alignment across Medicare and Medicaid requirements, as well as the EHR incentive programs with the Merit-Based Incentive Payment System (MIPS). The second states strongly that changes to the EHR incentive program at this late date relative to the current or next reporting period lead to costly and negative repercussions. We strongly recommend that CMS make every effort to incorporate the comments received up to and including this comment cycle in future rulemaking, in order to set appropriate and achievable requirements and deadlines to reduce the need for mid-year revisions.

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EHR Association Responds to CMS’ MACRA/MIPS Proposals

Recognizing the complexity of the MACRA legislation, the Association expressed appreciation that CMS considered a variety of comments from a diverse set of stakeholders in developing the proposed rule.  In their detailed comments, they emphasize that some of the complexities in the proposed rule will lead to many significant changes and implications for eligible clinicians.  EHRA urged CMS to take every possible step to dramatically simplify requirements in the final rule and to develop provider-focused communications to reduce complexity.

Briefing Congress on the Importance of Interoperability

On June 7, 2016, the EHR Association sponsored a briefing for Congressional staff engaged in crafting proposed legislation that addresses interoperability.  EHRA member company, Allscripts, invited their client Stephen Nuckolls, CEO of Coastal Carolina Health Care (New Bern, North Carolina, U.S.A.), to participate as a panelist, along with four other healthcare provider organization executives. Their blog post shares some of his comments at the briefing, which covered successes and areas for improvement with health information technology.

Data Re-Use – Usability, Patient Safety, and Organizational Policy

With the accelerated adoption of electronic health records (EHRs), there is growing recognition of the benefits associated with the use of these technologies – reduced medical errors, faster access to complete information, more efficient communications among busy clinicians, and increasing patient engagement in their healthcare decisions. At the same time, there is a dialog taking place among all stakeholders on the issues related to busy clinicians taking advantage of data re-use capabilities to avoid re-entering identical information as they create their encounter documentation.

The EHR Association strongly believes that data re-use tools are critically important for clinicians, provide clear benefit for patients and, when used appropriately, enable accurate legal and financial recording workflows for providers.

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MACRA and Alternative Payment Models – What You Need to Know

When it comes to alternative payment models (APMs), organizations often ask “is it better to be a Medicare Shared Savings Program (MSSP) Track 1 Accountable Care Organization (ACO) or a Patient-Centered Medical Home (PCMH)?”

Typically, the answer depends on a few factors:  organizational goals, level of readiness to adopt new delivery models, and the mix of public and private payer incentive programs.

Going forward, however, the newest factor that organizations must consider is how they want to be scored under the incentive programs created by the Medicare Access and CHIP Reauthorization Act (MACRA).  As the Centers for Medicare and Medicaid Services (CMS) prepares to release the proposed rule for MACRA, the agency has made it clear that not all organizations participating in APMs will be considered “eligible” for purposes of the law’s APM incentive program.  The statute requires that eligible APMs, those which qualify for the APM bonus payment, have the following characteristics:

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