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    CMS proposes changes to Promoting Interoperability program in IPPS Rule

    On April 27, 2021, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule for the fiscal year 2022 Inpatient Prospective Payment System (IPPS). The IPPS Proposed Rule contained a number of changes to payment rates and policies for hospitals, including significant modifications to the Promoting Interoperability Program requirements.

    The IPPS Proposed Rule would require hospitals to report on all four measures under the Public Health and Clinical Data Exchange objective, rather than the previous pick-and-choose option. Specifically, hospitals would have to report on Syndromic Surveillance Reporting, Immunization Registry Reporting, Electronic Case Reporting and Electronic Reportable Laboratory Result Reporting. CMS explained that requiring reporting on all four measures “would enable nationwide syndromic surveillance for early warning of emerging outbreaks and threats; automated case and laboratory reporting for fast public health response; and local and national visibility on immunization uptake so [public health agencies] can tailor vaccine distribution strategies.”

    The IPPS Proposed Rule contained numerous other proposed changes to the Promoting Interoperability Program, which were outlined in CMS’ fact sheet for the rule. Additional notable proposed changes include:

    • A continuation of a 90-day EHR reporting period for CY 2023, with an increase to a 180-day period in CY 2024
    • Increasing the minimum required score for objectives and measures from 50 total points (out of 100 points) to 60 points
    • Adding a new Health Information Exchange (HIE) Bi-Directional Exchange measure to the HIE objective as an optional alternative to the existing two measures
    • Maintaining the Electronic Prescribing Objective’s Query of PDMP measure as optional, but increasing the total available bonus points from 5 to 10 points
    • Adding a data availability requirement to the Provide Patients Electronic Access to Their Health Information measure

    CMS is accepting comments on the IPPS Proposed Rule through June 28, 2021. 


    This is for informational purposes only. It is not intended to be legal advice and does not create or imply an attorney-client relationship.

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