Changes in EHR In the Performance Year 2019 For Providers & Hospitals Pramod is a US Healthcare Specialist who seeks to augment the efficiency of healthcare administration by integrating regulatory changes into EHR systems without affecting its existing behavior. He has extensive hands-on experience in helping multiple EHR applications become MU Stage 2 and Stage 3 compliant. His responsibilities include the development of test plans and strategies for the investigation of potential solutions to looming healthcare problems.
Transcript
Changes in EHR In the Performance Year 2019For Providers & Hospitals
Pramod is a US Healthcare Specialist who seeks to augment the efficiency of healthcare administration by integrating regulatory changes into EHR systems without affecting its existing behavior. He has extensive hands-on experience in helping multiple EHR applications become MU Stage 2 and Stage 3 compliant. His responsibilities include the development of test plans and strategies for the investigation of potential solutions to looming healthcare problems.
2019 Quality Payment Program (QPP) Changes Eligibility MIPS Promoting Interoperability Performance Category in 2019 MIPS Cost Performance Category in 2019 MIPS Quality Performance Category in 2019 MIPS Improvement Activities Performance Category In 2019 MIPS Bonuses In 2019 2019 EHR Eligible Hospital Payment Adjustment CMS Exception Process Payment Adjustment With Respect to Meaningful Use Criteria
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In 2018, practices could choose to use certified EHRs using 2014 or 2015 edition criteria or not. In 2019, all practices are mandatorily required to use Certified EHR Technology (CEHRT) to receive a score, in the ‘Promoting Interoperability Performance’ category. The bonus associated with the usage of 2015 edition of CEHRT in 2018 has been eliminated in 2019.
The CMS has released a new list of MIPS eligible clinicians who can participate in QPP (Quality Program Payment Overview). This list comprises of physical therapists, clinical psychologists, qualified speech therapists, occupational therapists, audiologists and registered dietitians).
The table below shows the changes for 2019.
Clinicians are part of the MIPS track of the Quality Payment Program if they:
Furnish covered professional services for more than 200 Medicare beneficiaries a year
Bill more than $90,000 a year in allowed charges for covered professional services under the Medicare Physician Fee Schedule (PFS)
Provide more than 200 covered professional services under the Physician Fee Schedule
NOTE: The third criteria being the change in 2019.
CMS has come up with modifications to the measures and objectives submission format for the performance year 2019. Some of the measures are combined while the number of objectives are reduced with two new measures added to them, as follows:
Verify Opioid Treatment Agreement
Query of Prescription Drug Monitoring Program
However, these measures are optional for the 2019 performance year.
Base measure scoring methodologies have been removed for 2019 performance year as well. All practices need to show data with number 1 in numerator from at least any one of the measures from each of the four objectives to get a score above zero. Security Risk Analysis is now no longer considered as a Promoting Interoperability measure in 2019. The consolidated number of potential points in Promoting Interoperability category has been reduced from 165 points in 2018 to 110 points in 2019.
The cost performance category will weigh in at 15 points for the 2019 performance period, compared to the 10 points in 2018.
In the 2018 performance year, cost performance category included two measures:
Total Per Capita Costs for All Attributed Beneficiaries (TPCC)
Medicare Spending Per Beneficiary (MSPB)
And in the 2019 performance year, the cost performance category will include the following measures:
Total Per Capita Costs for All Attributed Beneficiaries (TPCC)
Medicare Spending Per Beneficiary (MSPB)
Eight episode-based cost measures
The minimum case number for procedural type measures is 10, while it is 20 for Acute Inpatient medical condition type. If the minimum case numbers mentioned above do not meet requirements for any of the 10 measures, then cost performance category is weighted as 0 percent.
There are six improvement activities that are added, five of which are modified and one removed from the list of MIPS Improvement Activities Performance Category.
Eligible hospitals that are not using 2015 Edition CEHRT will be subjected to a payment adjustment starting October 1, 2018. This payment adjustment is applied as a reduction to the applicable percentage increase to the Inpatient Prospective Payment System (IPPS) payment rate. This reduces the update to the IPPS standardized amount for these hospitals.
CMS has eliminated the 5% bonus for small practices which is applied to the total MIPS score in 2019. However, small practices (15 and fewer clinicians) will now receive a six-point bonus added to their quality scores.
MIPS Improvement Activities Performance Category in 2019
2019 EHR Eligible Hospital Payment Adjustment
MIPS Bonuses in 2019
NOTE: 2019 payment adjustments will be based on 2017 reporting period.
The Quality category will drop from 50% to 45% of the final MIPS score in 2019. Small group practices may report via the claims reporting process in 2019. This mechanism was limited to clinicians reporting as individuals. Also, the CMS has removed the measures which have very high performance. They have added 10 new quality measures and removed a total of 26 topped-out measures in 2019.
MIPS Quality Performance Category in 2019
In order to avoid the payment adjustment, eligible hospitals can apply for hardship exceptions claiming that there were extreme and uncontrollable circumstances that prevented them from being compliant to meaningful use. Hardship exceptions are granted on a case-by-case basis, only if the CMS finds that requiring an eligible hospital to be using the 2015 Edition CEHRT, would result in a significant hardship for the hospital. Hospitals and CAHs are required to submit the applications on or before July 1st of the year before the applicable payment adjustment year. For the FY 2019 payment adjustment, for instance, the deadline was July 1, 2018.
The following are the categories where eligible hospitals can apply for hardship exceptions:
Hospitals have to demonstrate that they are compliant to meaningful use every year according to the timelines defined by CMS in order to avoid negative Medicare payments adjustments. For example, an eligible hospital that demonstrates meaningful use for the first time in 2013 will avoid the negative payment adjustment in FY 2015, but will need to demonstrate meaningful use again in 2015 in order to avoid the negative payment adjustment in FY 2017.
The CMS Exception Process
Payment Adjustment with respect to Meaningful Use criteria
New eligible hospitals:Eligible hospitals with new CMS Certification Numbers (CCNs) that do not have the time to become meaningful EHR users can apply for an exception for one full cost reporting period.
Infrastructure:Eligible hospitals should demonstrate that they are in a remote location lacking sufficient internet access or the provision to obtain necessary infrastructure (e.g., lack of broadband).
Unforeseen Circumstances:This may include a natural disaster or other unforeseeable natural calamities or geographical barriers.
EHR Vendor Issues: This includes hospitals that were unable to implement meaningful use due to EHR certification delays or the eligible hospital’s EHR vendor’s failure to obtain certification.
