On April 24, 2018, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule for the Hospital Inpatient Prospective Payment Systems (IPPS) for Acute Care Hospitals and Long Term Care Hospital Prospective Payment System (LTCH PPS) and Proposed Policy Changes and Fiscal Year 2019 Rates. The proposed rule would make updates to the payment rates for Medicare Part A services under the Inpatient Prospective Payment System, as well as rates for LTCHs paid under Medicare.
Under the proposed rule, the net increase of IPPS payments will be 3.4 percent, due in part to a 21.93 percent upward adjustment to disproportionate share hospital (DSH) payments for uncompensated care. CMS projects that LTCH PPS payments would decrease by approximately 0.1 percent in FY 2019, reflecting the continued phase-in of a dual payment rate system, which was recently extended through FY 2019 by the Bipartisan Budget Act of 2018.
Of particular note, the proposed rule includes policies that would require hospitals to post standard charges online and that would modify the electronic health record (EHR) incentive program to emphasize interoperability. For each of these policies, CMS has included in the proposed rule Requests for Information (RFIs) on possible future changes. These proposals reflect the emphasis that the Administration is placing on price transparency and interoperability of EHRs.
In addition, the proposed rule includes policies that would eliminate a number of measures that hospitals must report as part of Medicare’s five hospital quality and value programs.
The proposed rule is scheduled to be published in the Federal Register on May 7, 2018. Comments are due to CMS by June 25, 2018.
Select key provisions of the proposed rule are highlighted below.
Movement towards transparency
The proposed rule would require hospitals to make their standard charges available online in a machine-readable format, with updates occurring at least annually. Hospitals will retain the option to publish their chargemaster directly, or elect another form. Hospitals currently are required to make standard charges available to the public, although the format is not specified.
In its RFI on transparency, CMS solicits comments on a number of other potential regulatory actions, including:
Medicare and Medicaid electronic health record incentive programs
The proposed rule reiterates that all eligible hospitals and critical access hospitals (CAHs) must use the 2015 Edition of Certified Electronic Health Record Technology (CEHRT) beginning with an EHR reporting period in calendar year 2019. An EHR reporting period is defined as any continuous 90-day period in calendar years 2019 and 2020.
In addition, the proposed rule would make significant changes to electronic health record (EHR) incentive programs, emphasizing interoperability of EHR systems rather than adoption of EHR systems within a provider’s organization. As part of this shift, the rule renames the Meaningful Use program “Promoting Interoperability.”
Noting that quality measures are often reported through other channels, the rule proposes to eliminate half of the EHR incentive program’s clinical quality measurements, while proposing a new scoring methodology that captures performance in areas such as health information exchange, and patient access to electronic health information. Instead of a “pass/fail” approach to scoring.
Request for information on interoperability
The proposed rule contains a request for information (RFI) on interoperability, with particular interest in proposals to revise Medicare conditions of participation or other health and safety standards to further promote interoperability. The RFI outlines several examples of possible interoperability-related conditions, including policies that would require:
Meaningful measures and burden reduction
Under the proposed rule, acute care hospitals would be required to report on fewer measures across each of the 5 quality and value-based purchasing programs. The proposed policies are summarized below.
In addition to the changes in the quality reporting programs described above, CMS also proposes several other strategies for reducing the administrative burden of hospitals, including policies that would:
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