As part of an effort to clear up lingering questions about its program to financially reward meaningful users of certified electronic health record (EHR) technology, the Centers for Medicare and Medicaid Services (CMS) held a session of its Education Series for Providers, this time for hospitals.
But while the session provided much detail around many aspects of the program, the Q&A after it resulted in a few "we'll have to get back to you" answers from CMS representatives.
One of those questions was how long, during year one's 90-day reporting period, must a hospital be meaningfully using a certified EHR. The response from CMS was the agency is "still trying to develop definitive FAQs on that." The CMS representative said the agency was uncertain as to whether the EHR "would need to have an actual certification number on Day 1."
Another area of continued cloudiness was around the emergency department's (ED) inclusion in inpatient metrics, and specifically what type of patient encounter was considered relevant to the total inpatient volume. For example, the ED has many levels of encounters -- in some cases, patients are merely observed and sent home, sometimes given moderate treatment, such as stitches, and occasionally admitted to the hospital. A caller asking for clarification on those ED visits was politely told he's have to wait for answers. "We need to figure out what we need to say in regards to that, and will get guidance out in the next few weeks -- stay tuned," said a CMS representative.
On the more definitive front, CMS's presentation was chock full of facts, figures, and requirements. Moderated by the agency's Diane Maupai, the session covered many important details.
For example, Medicaid hospital payouts will be calculated similarly to those which are part of Medicare. For those facilities, payment is first calculated, then disbursed over three to six years. No annual payment may exceed 50% of the total calculation, and no two-year payment may exceed 90% of it. Hospitals cannot initiate payments after 2016 and payment years must be consecutive after 2016. For Medicare hospitals, payments years must be consecutive throughout the program.
In Stage 1 of meaningful use, payments will be based on the federal fiscal year. The reporting period is 90 days (through affirmation) for first year and one year (through electronic reporting) for the following years.
Future stages of meaningful use will expand upon Stage 1 criteria. For example, Stage 1's menu set will be transitioned into the core set of Stage 2. Administrative transactions will be added and the computerized physician order entry measurement will rise from 10% to 60%. CMS stated it will also reevaluate other measures, most likely raising the thresholds even further in Stage 3.
Addressing one of the most troubling aspects of the final rule for health systems with multiple hospitals under the same provider number (CCN), CMS said it kept the definition of a hospital as "one number equals one payment" for a number of reasons. "CMS considered the issue very carefully and heard from a number of hospital groups, as well as members of Congress. We felt that we could not change our existing policy of treating without clear statutory intent. Our concern is that CMS would be vulnerable to a legal challenge for having inconsistent policies," the organization stated.
Anthony Guerra is the founder and editor of healthsystemCIO.com, a site dedicated to serving the strategic information needs of healthcare CIOs. He can be reached at aguerra@healthsystemCIO.com.
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