CMS Finalizes Hospital Outpatient Prospective Payment System (OPPS) Changes

Today, the Centers for Medicare & Medicaid Services (CMS) finalized updated payment rates and policy changes in the Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System for calendar year (CY) 2017. The Final Rule includes changes to the Medicare EHR Incentive Program for eligible hospitals and critical access hospitals attesting to CMS, including hospitals that are eligible to participate in both the Medicare and Medicaid EHR Incentive Programs (dual-eligible hospitals). These changes include eliminating the Clinical Decision Support (CDS) and Computerized Order Entry (CPOE) objectives and measures beginning in 2017. CMS is reducing a subset of thresholds for the remaining objectives and measures for Modified Stage 2 and Stage 3. Additional changes include allowing all returning participants in the EHR Incentive Programs to report on a 90-day EHR reporting period in 2016 and 2017. CMS is also finalizing an application process for a one-time significant hardship exception to the Medicare EHR Incentive Program for certain eligible professionals in 2017 who are also transitioning to MIPS. These additions both increase flexibility, lower the reporting burden for providers, and focus on the exchange of health information and using technology to support patient care.

Changes Specific to the Electronic Health Record (EHR) Incentive Program

• 90-Day EHR Reporting Period in 2016 and 2017
  CMS finalized a 90-day EHR reporting period in 2016 and 2017 for all returning EPs, eligible hospitals and CAHs that have previously demonstrated meaningful use in the Medicare and Medicaid EHR Incentive Programs. CMS is extending the 90-day EHR reporting period to include 2017 secondary to stakeholder comments indicating concerns with implementing API functionalities for Stage 3, program and systems changes in 2017 as well as to allow eligible clinicians time to MIPS for Medicare eligible clinicians, and to continue preparation of Stage 3 and the 2015 Edition. The EHR reporting period will be any continuous 90-day period between January 1st and December 31st in CY 2016 and CY 2017.
• Removal of the Clinical Decision Support (CDS) and Computerized Provider Order Entry (CPOE) Objectives and Measures and Reduction of a Subset of the Remaining Objectives and Measures for EHs
  CMS finalized the elimination of the Clinical Decision Support (CDS) and Computerized Provider Order Entry (CPOE) objectives and measures for eligible hospitals and CAHs attesting under the Medicare EHR Incentive Program for Modified Stage 2 and Stage 3 for 2017 and subsequent years. CMS will also reduce the thresholds of a subset of the remaining objectives and measures in Modified Stage 2 for 2017 and in Stage 3 for 2017 and 2018 for eligible hospitals and CAHs attesting under the Medicare EHR Incentive Program. This pertains to all eligible hospitals and CAHs that attest to meaningful use under Medicare, including hospitals that are eligible to participate in both the Medicare and Medicaid EHR Incentive Programs (dual-eligible hospitals). These changes would not apply to Medicaid-only hospitals and CAHs that attest under their State Medicaid Agency, however, they do apply to hospitals that are participating in the Medicaid EHR Incentive Program by attesting to CMS.
• New Participants in 2017
  EPs, eligible hospitals, and CAHs that have not successfully demonstrated meaningful use in a prior year would be required to attest to Modified Stage 2 objectives and measures by October 1, 2017. Returning EPs, eligible hospitals, and CAHs will report to different systems in 2017 and therefore would not be affected by this proposal.
• Significant Hardship Exception for New Participants Transitioning to MIPS in 2017
  Certain EPs, who are new participants in the EHR Incentive Program in 2017 and are transitioning to MIPS in 2017 can apply for a significant hardship exception from the 2018 payment adjustment as authorized under section 1848(a)(7)(B) of the Act using a CMS developed hardship exception application process specific to this policy.
• Modifications to Measure Calculations for Actions Outside of the EHR Reporting Period
  CMS is finalizing changes to the policy for measure calculations such that, for all meaningful use measures, unless otherwise specified, beginning in CY 2017 actions included in the numerator must occur within the EHR reporting period if that period is a full calendar year, or if it is less than a full calendar year, within the calendar year in which the EHR reporting period occurs.

For additional information:
Press Release
Final Rule on Federal Registry
Contact the Kentucky REC for additional questions!