Health IT groups were generally supportive of revised information technology provisions proposed in the CMS' annual update to the inpatient prospective payment system, but urged the agency to slow potential requirements related to integrating outside programs with electronic health record systems. The public comment period for the CMS' IPPS proposal, which the agency released in April, closed Monday.
Now the CMS is tasked with sifting through more than 2,000 comments from providers, vendors and trade groups offering feedback on the agency's plan to update inpatient hospital reimbursements for federal fiscal 2020.
The EHR Association expressed support for keeping the reporting period for the use of EHRs to any continuous 90-day period, a provision hospital groups were successful in lobbying for in a previous IPPS update, and encouraged the agency to go one step further—instituting the time frame as a permanent fixture.
"We encourage CMS to allow this 90-day reporting period permanently, so that hospitals and developers can appropriately plan in advance, instead of waiting for annual rulemakings," according to a letter from the EHR Association to the agency.
Health IT groups also voiced support for a proposal to delay requiring hospitals to integrate prescription drug monitoring programs into their EHRs by 2020.
The CMS in April had proposed continuing to offer the "Query of PDMP" measure as an optional bonus item instead of a mandatory one, citing feedback providers had offered the agency regarding implementation challenges associated with PDMP integration. Healthcare groups had said mandating PDMP integration in 2020 would be premature and lead to increased burden on providers.
"We agree with stakeholders that PDMPs are still maturing in their development and use," reads the CMS' proposed rule. "We believe that additional time is needed to evaluate the changing PDMP landscape prior to requiring a Query of PDMP measure, or introducing requirements related to EHR-PDMP integration."
In comments to the agency, EHR maker Cerner Corp. agreed with the proposal, arguing that this measure should not be required until state PDMPs adhere to a standard for querying PDMP registries. But Cerner emphasized that despite arguably immature PDMP infrastructure, the CMS should continue to offer PDMP measures as optional in 2020, rather than removing them altogether.
"We have heard from a number of our hospital clients that removal of this measure would have resulted in a feeling of wasted efforts by many hospitals," the company wrote.
Lahey Hospital & Medical Center in Burlington, Mass., similarly offered support for the optional PDMP provision, and suggested the CMS keep the "Query of PDMP" measure as attestation-based, rather than performance-based, until PDMP integration has "matured."
The College of Healthcare Information Management Executives said the CMS should hold off on setting a mandatory implementation timeframe for EHR integration with PDMPs, noting existing challenges with varying state-by-state regulations, infrastructure and fees.
"We support the use of state PDMPs, but the integration of PDMPs into a health information exchange or providers' EHR is still developing," the group wrote in a letter to the CMS.
The IPPS proposal also hinted at new areas of interest the CMS is considering in its Promoting Interoperability Programs, formerly known as meaningful use. In its proposed rule, the CMS sought public comment on requiring the use of open application programming interfaces, or APIs, a technology the CMS and the Office of the National Coordinator for Health Information Technology are also considering as part of their companion interoperability and information-blocking proposals.
Cerner and the EHR Association both supported a suggestion for the CMS to offer bonus points to early adopters of APIs.
However, CHIME urged the CMS to be cautious of using APIs to connect third-party apps with EHRs, and recommended the agency work closely with the ONC and the Federal Trade Commission to establish security and privacy safeguards, while also educating patients on the risks of sharing data with third-party apps.
"We are very worried that patients are unaware of how their data is being used once it is released," CHIME wrote in a letter to the agency. "Our members are concerned that one bad actor could destroy consumer and patient trust in healthcare apps, dismantling efforts to further interoperability and improve patient access to their information."