Beginning in 2018, the Centers for Medicare and Medicaid Services (CMS) is commencing an annual “Call for Measures” initiative to allow interested parties (i.e., Medicare eligible hospitals and critical access hospitals (CAHs) participating in the Medicare Electronic Health Record (EHR) Incentive Program), to be involved in the planning and ongoing development of program measures with the goal of advancing Meaningful Use of certified EHR technology. For those interested in participating in this opportunity, proposals submitted by June 29, 2018 will be considered for inclusion in calendar year 2019 rulemaking. Measure implementation is required beginning in calendar year 2021 but optional in calendar year 2020.
Regarding the substance of program measure proposals, CMS requests that interested parties submit measures that could be applicable for eligible hospitals and CAHs participating in the Medicare EHR Incentive Program. CMS noted that it is very interested in adding measures to the program that: (1) utilize the 2015 Edition of Certified EHR Technology (CEHRT); (2) increase CEHRT health information exchange and interoperability; (3) continue improving program efficiency, effectiveness, and flexibility; (4) measure patient outcomes; and (5) emphasize patient safety.
As part of the consideration process for new measure proposals, CMS indicated it intends to evaluate: reporting burdens; duplicity on existing and/or previously deleted objectives and measures; and emerging certified health IT functionality or capacity. CMS asks submitters to evaluate and consider these criteria during the submission process.
All proposals must be submitted to CMSCallforMeasuresEHR@ketchum.com by June 29, 2018 using the 2018 Medicare EHR Incentive Program Call for Measures submission form. Importantly, proposals must provide information for every field/section in the application in order to be considered, including an “N/A” where appropriate. Proposals will be reviewed by CMS, and CMS will notify submitters if their measures have been chosen.
For parties interested in submitting proposal(s) for consideration, now is the time to consider, develop, and refine submissions in order to meet the filing deadline.
Please note that eligible hospitals and eligible professionals (EPs) that attest directly to a state for such state’s Medicaid EHR Incentive Program will continue to attest to the measures and objectives as finalized in the 2015 EHR Incentive Programs Final Rule.1 In 2018, all EPs previously participating in the Medicare EHR Incentive Program will report on Quality Payment Program requirements. Medicare EPs will attest to the Advancing Care Information performance category under the Merit-based Incentive Payment System. Medicare eligible hospitals, CAHs, and dual-eligible hospitals will still report on Medicare EHR Incentive Program requirements in 2018.
1 80 Fed. Reg. 62762 through 62955.
This article by firm partner Christine Burke Worthen originally appeared in an email communication to members of the American Health Lawyers Association
