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78 in the cy 2019 physician fee schedule final rule

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78In the CY 2019 Physician Fee Schedule final rule, CMS finalized proposals to simplify and revise the scoringmethodology for this category by eliminating the base, performance, and bonus scores, and by establishinga new scoring methodology focused on clinician performance at the individual measure level. Changes alsoinclude a streamlined set of measures focusing on those that are most important to clinicians and patients,thus better aligning with those finalized for hospitals.Hospitals and hospital organizations, prior to the FY 2019 rulemaking cycle, noted that the scoringmethodology under the Medicare Promoting Interoperability Program for eligible hospitals and CAHs,formerly known as the Medicare EHR Incentive Program, was burdensome. The program used a pass-failscoring methodology that did not provide partial credit or reward improvement for health IT usage. Themajority of hospitals were able to meet the current health IT and quality measure requirements of theMedicare Promoting Interoperability Programs. However, CMS received feedback from hospitals andhospital associations that, while some measures have helped to drive improvement in quality of care, othersare less meaningful and detract from the ability to provide optimal care to patients.Stakeholders have further suggested, through inquiries and listening sessions, that the requirement to meetall of the health IT measures has been administratively burdensome, particularly those measures thatrequire direct patient action. These stakeholders believe that there is a critical need for interoperability and
Strategy on Reducing Regulatory and Administrative BurdenRelating to the Use of Health IT and EHRs, Feb. 2020ONC38have expressed a desire to use certified health IT to further patient outcomes, but believe the currentprogram structure constrains their ability to implement more interoperable environments and deliver qualitycare. In addition, a small but important minority of hospitals indicated they struggle with both the largenumber of measures that must be reported and a scoring model that requires participants to either meet allprogram requirements or be subject to the full penalty provided by statute. Often the hospitals that face thehighest hurdles in participation are those that are most resource challenged, such as small and ruralhospitals. A more incremental or progressive system would alleviate program participation burden for thesehospitals.A significant number of physicians and hospitals also identified the approach to measuring health IT use asnot only limiting, but often without direct value in improving the quality of patient care or lowering healthcare costs. For example, in a 2017 letter to HHS, the American College of Surgeons stated that “MIPSmeasures lack meaning for surgeons and surgical patients.”79Unfortunately, the current standardizedapproach to health IT measurement, with all health care providers reporting on the same set of measureswithin EHR reporting programs, does not adequately incentivize or reward potentially more innovative usesof health IT that could significantly impact patient care and improve overall quality.

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Term
Spring
Professor
NoProfessor
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Electronic health record

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