eMeasures News You Can Use – IPPS, MU, IOM and More

Introduction

Encore’s eMeasure Research and Review Board (eMRB) provides direction and common perspective on how eMeasures are applied in a value-based reimbursement environment.  To help keep others informed and share our knowledge of recent activities relevant to eMeasures, eMRB provides this high level monthly recap.

In the update below, covering the month of August, we discuss the legislative activities in Washington, D.C., including the Fiscal Year (FY) 2016 Inpatient Prospective Payment System (IPPS) Final Rule.  We also provide a review of the National Academy of Medicine’s (formerly IOM) Core Metrics Book.  In addition, under our August announcements and events section, we highlight Encore’s latest white paper (Maximizing Legacy Data Migration to a New EHR) and its associated Webinar.  As an added bonus, this month we also include a section covering questions received on value-based programs.

Reading time:  15 minutes

Watch List Update

We’re keeping a pulse on Washington D.C., but there was not too much going on in August

At least not since CMS published the Fiscal Year (FY) 2016 Inpatient Prospective Payment System (IPPS) Final Rule in early August.

So where can you find out more about the IPPS Final Rule?  We published a more detailed InfoAlert posted on our website that gives you a look at our findings.  If you haven’t seen it, you can click on this link to read it (eMRB InfoAlert – Highlights and Impacts of the FY 2016 IPPS Final Rule).

What does it include?  The InfoAlert provides a summary of the FY 2016 IPPS Final Rule and includes highlights and impacts to healthcare organizations.  Focus is on electronic clinical quality measures (eCQM) quality reporting.  The summary and highlights include a description of the legislation, the FY 2016 payment rates, the quality reporting requirements for the hospital inpatient quality reporting (IQR) program and Meaningful Use (MU), and electronic submission strategies to consider for 2016.  It also includes links to the legislation.

But it’s starting to look like September will be the month for…

Could we possibly see the Meaningful Use Final Rules?  It’s beginning to look that way.

What is the buzz just out on the MU Modifications?  On September 3, the pending Meaningful Use final rules were sent to the Office of Management and Budget (OMB) for review.  That includes Meaningful Use Stage 3, Modifications to Meaningful Use in 2015-2017, and the 2015 Edition.

What does that mean?  The OMB typically has 90 days to review a rule, although that can be extended; there is no minimum period for review (FierceEMR).  In the meantime, the final rules that CMS submitted to the OMB are not publically available for review and CMS cannot make any comments regarding what is included or not while the policy is in the rule writing process.

Impact?  The final rules were sent to the OMB for review, however, the OMB review timeline is unknown.  Even if the final rules are released earlier than the typical 90 days, this leaves little time for vendors and organizations to implement necessary changes.  Hopefully the impact to 2015 will be very small in such a late ruling.  But, we shall see…

Where can you view the rules currently under review by the OMB?  Here are the links toMU Stage 3 and Modifications to MU; and 2015 Edition.

You may be wondering what else is left on our Watch List for 2015?

The Watch List is focused on legislation impacting eCQMs for hospitals and physicians.  That includes the Inpatient Quality Reporting (IQR) Program, Meaningful Use (MU), Physician Quality Reporting System (PQRS), and Medicare Shared Savings Program Accountable Care Organizations.

So what else are we waiting for?  Besides the Meaningful Use final rules, that leaves the Physician Fee Schedule Annual Updates final rule sometime in November.

eMeasure Education

We also reviewed the Institute of Medicine’s latest book on Core Metrics titled — Vital Signs:  Core Metrics for Health and Health Care Progress

What is the book?  Vital Signs identifies the need for a standard set of core measures as a tool for improving health in the United States.  This book explains the current use of metrics in health and health care and then proposes a streamlined set of 15 standardized measures, with recommendations for their application at every level and across sectors.  Vital Signs lays the groundwork for the adoption of core measures.

Pending impact?  The book identifies a set of core measures, but does not provide many details except for identifying the U.S. Department of Health & Human Services (HHS) secretary as being responsible for implementing.  Once we see the core measure set being incorporated into the quality programs, it will trigger a change in EHR design.  Therefore, it is on our Watch List.

Did you know that the IOM changed its name?  Effective July 1, 2015, the Institute of Medicine (IOM) was renamed to National Academy of Medicine.  References in this communication use both terms as the transition progresses.

Encore’s analysis is based on the pre-publication copy.  However, the final book is now out and available for download.

Source and Links:

IOM (Institute of Medicine).  April 2015.  Vital signs: Core metrics for health and health care progress. Washington, DC: The National Academies Press.  Links to the report:  IOM Website; or The National Academies Press Final Book; and the Introductory Slide for Report.

Questions on Value-based Programs

Did you know that for the hospital IQR program, just because only 4 eCQMs are required in 2016 does not mean a hospital cannot submit more than that.

Question Asked:

• Is there a maximum number of eCQMs that a hospital can submit for the hospital (IQR) program 2016 reporting year, now that 4 of 28 eCQMs is all that is required?  The submitter wanted to make sure that QualityNet could handle a larger volume.

Here’s the response provided by QualityNet:

• In regards to your question, the final rule states “at least 4 eCQMs”.  Hospitals would be able to submit more than 4 eCQMs via production or test files.  At this time, there are no limitations with the number of eCQMs a provider can submit.

Here’s another question regarding clarification on Meaningful Use penalties…

Question Asked: 

• If a hospital is not a meaningful EHR user due to its failure to meet the meaningful use measures, does that mean their Medicare reimbursements might be withheld?

eMRB’s response:

• The MU penalty is a downward payment adjustment for not being a meaningful EHR user and it is tied to the inpatient prospective payment system (IPPS) payment rate for eligible hospitals.  Hospitals will receive a reduced update to the IPPS standardized amount.  This is best explained in the Payment Adjustment tip sheet where it states:  the potential reductions in Medicare reimbursement beginning with FY 2015 would have a negative impact on providers that fail to meaningfully use certified EHR technology for the applicable reporting period.

Source:  The Payment Adjustments & Hardship Exceptions for Eligible Hospitals and CAHs, Last Updated: August 2014, provides a description of the Medicare reimbursement implications.

Announcements and Events

August Communications

In addition to the InfoAlert covering highlights and impacts of the FY 2016 IPPS Final Rule, eMRB posted the first monthly edition of eMeasures News You Can Use on August 19.  Below is a description and link for that news.

eMeasures News You Can Use:  eMeasures News You Can Use – IPPS, ICD-10, MU and More

• It covers:  The 2015 Watch List with legislative updates from Washington D.C.; Program Education on the Medicare Shared Savings Program Accountable Care Organizations final rule; and Announcements and Events highlighting the eCQM Point of View (POV) paper.

Webinar Announcements

Coming up in September are several Webinars of interest to eMeasure enthusiasts.  Below is a list with links where you can register or download the slides.

• September 2:  FY 2016 IPPS/LTCH Final Rule
  • This presentation provided participants with details regarding the Fiscal Year (FY) 2016 Inpatient Prospective Payment System (IPPS)/Long Term Care Hospital (LTCH) Final Rule and its impact on the hospital IQR Program.
  • Download slides post Webinar and access recording when available

• September 18:  Hospital Inpatient and LTCH PPS FY 2016 Final Rule
  • If you missed the one on September 2, you can attend this MLN Connects Webinar.
  • This Webinar will provide an overview of the major provisions in the final rule.  The call will also provide details on the quality initiatives included in the final rule.  A question and answer session will follow the presentation.
  • Register and / or download slides posted prior to the Webinar

• September 11:  CMS 2015 QRDA Submissions for Eligible Hospitals/Critical Access Hospitals
  • This presentation will provide an overview of several topics related to the eCQM submission process, including: an overview of 2015 Submission Changes; CMS updates for Hospital Quality Reporting (HQR) 7.0 and 8.0; and Quality Reporting Document Architecture (QRDA) Base Specification Errata updates.
  • Register and / or download slides posted prior to the Webinar

• September 24:  Medicare Quality Reporting Programs: 2017 Payment Adjustments
  • This MLN Connects® National Provider Call will provide guidance and instructions on how individual EPs and group practices can avoid the 2017 Physician Quality Reporting System negative payment adjustment, satisfy the CQM component of the Medicare EHR Incentive Program, earn an incentive based on performance, and avoid the automatic 2017 downward payment adjustment under the Value-Based Payment Modifier.
  • Register and / or download slides posted prior to the Webinar

And did you catch Encore’s Webinar on August 17?  If not, you can still view it On Demand…

• On August 17, Randy Thomas conducted a webinar on Data Migration and Jon Morris moderated the session.  HIMSS Media and Healthcare IT News were co-hosts.
• Webinar Title: You CAN Take It With You: Boost EHR Value With Data Migration
• Attendee objectives: Understand how data profiling can be used to evaluate the reliability, accuracy and consistency in your legacy EHR(s); and learn how to organize your data into categories that define eligibility for migration.
• The Webinar is one hour in length and is still available On Demand.  Here’s a link where you can Register for it.
• You might also be interested in the white paper on that subject.  It’s titled:  Maximizing Legacy Data Migration to a New EHR and authored by Joy Ales, MHA, BSN, RN, Sr. Consultant, Encore, A Quintiles Company.

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Acronyms

Accountable Care Organizations (ACO); Calendar Year (CY), January – December; Centers for Medicare and Medicaid Services (CMS); Electronic Clinical Quality Measures (eCQMs); Fiscal Year (FY), October – September; Inpatient Prospective Payment System (IPPS); Inpatient Quality Reporting program (IQR); Institute of Medicine (IOM); Medicare Shared Savings Program (MSSP);Meaningful Use (MU); Office of Management and Budget (OMB); Physician Quality Reporting System(PQRS); U.S. Department of Health & Human Services (HHS).

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To read previous versions of the eMeasures News You Can Use, you can locate them on Encore’s Website under the Press Room.

Points of view and interpretation were relevant at time of authorship; however, they are subject to change over time.

eMRB

Encore’s eMeasure Research and Review Board is made up of Encore’s industry thought leaders and eMeasure experts who are responsible for understanding the current state and future direction of quality and value-based programs for Encore’s business.

eMeasure Research and Review Board
Encore, A Quintiles Company
[email protected]
www.EncoreHealthResources.com