CMS Promoting Interoperability Proposed Changes

Formerly known as Meaningful Use, the CMS Promoting Interoperability (PI) Program’s goal is to facilitate greater transparency and easier exchange of information of patient health records. CMS annually adjusts the reporting requirements (via the IPPS ruling) to consistently improve access (in conjunction with the Interoperability and Patient Access ruling) and best reflect the current healthcare landscape. The most recent proposed rule affecting hospitals and critical access hospitals (CAHs) was released in April of 2022 and impacts reporting for Calendar Year 2023 (CY2023/Program Year 2023) and beyond.

The proposed changes to the hospital/CAH Promoting Interoperability Program are designed to encourage expanded and improved demonstration of “meaningful use” of electronic health record systems (EHRs). In addition to the new and modified reporting categories, The Centers for Medicare & Medicaid Services have also proposed that some of the PI data reported by hospitals and CAHs will be available to the public beginning in calendar year 2023.

Changes to PI Objectives

Several objectives would have their point designations modified for CY 2023:

The Prescription Drug Monitoring Program (PDMP) measure would become mandatory under the proposed changes. This query under the Electronic Prescribing Objective would also expand to include drugs from Schedules II, III, and IV. Available points for this measure would be 10.

CMS is proposing an optional alternative to the current 3-measure Health Information Exchange (HIE) Objective. Eligible hospitals and CAHs could elect to a yes/no attestation for Enabling Exchange within the Trusted Exchange Framework and Common Agreement (TEFCA) measure instead. We’ll be talking more about The Sequoia Project, an ONC appointed Recognized Coordinating Entity (RCE) and ways to meet this measure with software you may already have in upcoming blog posts.

CY 2023 would also see changes to the Public Health and Clinical Data Exchange Objective under the proposed changes. Active engagement options under this Objective would decrease from three to two, and submission of the level of active engagement would also be required for the EHR reporting period. A new Antimicrobial Use and Resistance (AUR) Surveillance measure would be required, as well.

Changes to Electronic Clinical Quality Measures (eCQMs)

The proposed changes to eCQM reporting would roll out across calendar years 2023 and 2024 and are tied to the proposals for the Hospital Inpatient Quality Reporting (IQR) Program. CMS intends to increase the number of eCQMs to be reported to 6 in CY 2024. Additionally, CMS is proposing to remove the zero denominator declaration from the IQR Program in CY 2023. It is unclear if this option would also be removed for the PI eCQM attestation in CY 2023. We’ll be looking for this confirmation in the final rule later this year.

While these proposed rules have yet to take effect, hospitals and CAHs who submit data for these categories should be aware of what could change for 2023. Mavin Healthcare Experts has years of experience helping healthcare providers just like you meet and exceed your CMS program and organizational participation goals. We encourage you to book a free discovery call to discuss how we can leverage our expertise to maximize your measure results now and in the future!