- HIMSS recently stated its support for CMS efforts to require adoption of 2015 edition certified EHR technology (CEHRT) by 2019, as well as the federal agency’s proposed policies surrounding the implementation of a Promoting Interoperability performance category.
This feedback came in response to the CMS proposed rule for Year 3 of the Quality Payment Program (QPP), released along with the proposed 2019 Physician Fee Schedule in July.
While some associations — including MGMA — have expressed concern that mandating 2015 edition CEHRT adoption by 2019 could be a significant financial burden on some providers, HIMSS believes widespread use of the technology is necessary to advancing interoperability and healthcare delivery improvement.
“HIMSS would like to reinforce the importance of adopting the 2015 Edition criteria as a significant part of our commitment supporting healthcare transformation beginning January 1, 2019,” stated HIMSS in the letter.
“Within QPP, use of 2015 Edition CEHRT in 2019 should apply to eligible clinician (EC) reporting under the Promoting Interoperability Programs, as well as to capture electronic clinical quality measures (eCQMs),” the association continued.
HIMSS stated promoting use of 2015 edition CEHRT is also crucial for facilitating health data exchange and access. The technology includes functionality related to enhanced data export, transitions of care, and application programming interface (API) use.
“Overall, the 2015 Edition helps propel forward reforms to our healthcare delivery system and strengthen the ability of providers to share and exchange health information,” stated HIMSS. “The API component of the 2015 Edition is of particular importance as the healthcare market continues to evolve.”
API functionality included in 2015 edition CEHRT allows third parties to easily access individual data requests, as well as requests for larger data sets.
“Health IT developers are also to be required to make the full documentation of their API information, as well as their syntax and programming information, publicly available,” noted HIMSS. “Requiring greater use of APIs and increasing their interaction with EHRs will increase engagement possibilities, improve user experience, and provide innumerable benefits to all healthcare stakeholders.”
HIMSS also affirmed its commitment to supporting CMS in facilitating increased health data exchange across the industry through the Promoting Interoperability programs.
The new Promoting Interoperability performance category of the Merit-Based Incentive Payment System (MIPS) replaces the advancing care information (ACI) category. The performance category aligns with the Medicare Promoting Interoperability (PI) program that recently replaced meaningful use.
“In addition, HIMSS wants to continue to help CMS leverage information and technology to support the demonstration of innovative care delivery models for coordinating smarter, safer, and more efficient high-quality care, while ensuring that individuals remain at the center of all our efforts,” the association wrote.
HIMSS also recommended CMS ensure the Promoting Interoperability performance category maintain an emphasis on public health measures.
“The current proposal from CMS requiring reporting on two measures under this objective is directionally appropriate given the importance of public health and the critical contribution that it makes to care delivery,” stated the association.
Contrary to the advice of stakeholders including AMA, the American Academy of Physicians (AAFP), and over 40 other medical associations and provider groups, HIMSS advocated for CMS policies requiring eligible clinicians to report clinical quality measures for a full calendar year.
“While some stakeholders have advocated for a 90-day reporting period for quality measures, ambulatory clinical quality measures are patient-level measures that evaluate the care given during the measurement period, and often require more than one encounter for either provider attribution or the measure scoring itself,” maintained HIMSS.
“Given these constraints, a full-year of reporting will produce more accurate scores, which is essential for any pay-for-performance program,” the association added.
Overall, HIMSS supports policies in the proposed rule that encourage providers to leverage health IT to improve care quality, enhance patient experience, contain cost, improve patient access to care, and optimize the effectiveness of public payment.