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CMS IPPS Final Rule: A Public Health Perspective

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CMS IPPS Final Rule: A Public Health Perspective

On August 2, 2018 the Centers for Medicare and Medicaid Services (CMS) released the 2019 Inpatient Prospective Payment System Final Rule to Quality Payment Program. We earlier rele ...

On August 2, 2018 the Centers for Medicare and Medicaid Services (CMS) released the 2019 Inpatient Prospective Payment System Final Rule to Quality Payment Program. We earlier released thoughts on the Proposed Rule as well as our formal comments.

The Final Rule affirmed most of CMS’ proposed changes, with some notable exceptions:

  • Required public health measures were reduced from three (Stage 3 requirement) to just two, but Syndromic Surveillance will not be a requirement for hospitals covered under the rule.
  • While CMS continued to be unclear about its plans for the removal of public health measures altogether for CY2022 and beyond, they did express some openness to consider continuing public health measures and to study the issue over the next few years.

It is clear from the comments discussed in the final rule that comments submitted supporting public health requirements were received, noted, and had a positive impact on the final rule. Kudos to public health advocates for their strong voice!

HLN Submits Comments to CMS on IPPS NPRM

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HLN Submits Comments to CMS on IPPS NPRM

On June 14, 2018 HLN submitted the following comments on the Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rulemakin ...

On June 14, 2018 HLN submitted the following comments on the Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rulemaking (NPRM) to Quality Payment Program based on our earlier comments:


HLN Consulting, LLC is pleased to submit the following comments on the recently-released CMS IPPS NPRM, CMS–1694–P. HLN is a leading public health informatics consulting company. With that in mind, we read documents like the NPRM through a public health lens, and confine our comments to that important context.

Thoughts on the CMS IPPS NPRM: A Public Health Perspective

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Thoughts on the CMS IPPS NPRM: A Public Health Perspective

I have seen several pretty good summaries of the recently release Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rule ...

I have seen several pretty good summaries of the recently release Centers for Medicare and Medicaid Services (CMS) 2019 Inpatient Prospective Payment System Notice of Proposed Rulemaking (NPRM) to Quality Payment Program (one from AMIA, one from CDC). Here are just a few additional tidbits I picked out of the NPRM.

Of course, this document is written like stereo instructions so I welcome any corrections or comments to my interpretation of what’s in the rule. I put page numbers (from final FBO version referenced above which has just been released) where relevant in parenthesis.

HITAC USCDI Task Force Delivers its Recommendations

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HITAC USCDI Task Force Delivers its Recommendations

On April 18, 2018 the HHS Health Information Technology Advisory Committee (HITAC) US Core Data for Interoperability Task Force delivered its recommendations on the draft US Core D ...

On April 18, 2018 the HHS Health Information Technology Advisory Committee (HITAC) US Core Data for Interoperability Task Force delivered its recommendations on the draft US Core Data for Interoperability (USCDI) and Proposed Expansion Process which had been published for public comment back in January 2018. HITAC promptly accepted the Task Force’s recommendations.

The Task Force focused almost exclusively on the process for identifying the USCDI rather than the proposed USCDI data itself. I especially appreciated their introduction of some key concepts related to how USCDI should be organized and understood. It has always bothered me that the current Common Clinical Data Set (CCDS) upon which the current draft USCDI is based contains a variety of types of data at different levels of analysis: for instance, a single discreet data element (like date of birth or sex) sits alongside more complex data constructs (like address, which contains many discreet data elements within it) which sit alongside even more complex data types (like immunizations or procedures). The Task Force introduces a notion of hierarchy to make this more sensible: data classes (high level topic like “demographics”), data objects (a single item within a class, like “address” within the class “demographics”), and data object attributes (a specific data element within a data object, like “zip code” within “address”).

From a process standpoint, the Task Force recommended an expanded set of steps which has an emphasis on more stakeholder participation and less ONC pronouncement. This includes a recommendation for patient input as well. These are welcomed additions and I certainly hope they will be operationalized by ONC.

HLN-authored White Paper published by NYeC: The Case for Payer Participation in Health Information Exchange

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HLN-authored White Paper published by NYeC: The Case for Payer Participation in Health Information Exchange

The New York eHealth Collaborative (NYeC) recently published a new white paper authored by Dr. Noam Arzt, President of HLN, titled The Case for Payer Participation in Health Inform ...

The New York eHealth Collaborative (NYeC) recently published a new white paper authored by Dr. Noam Arzt, President of HLN, titled The Case for Payer Participation in Health Information Exchange.

Health information exchanges (HIEs) are collaborative efforts that focus on health data exchange on a community, regional, or statewide basis. HIEs are quite diverse; their services have yet to be fully leveraged by the payer community. HIE is an important tool in improving the quality of patient care and outcomes, increasing accuracy and speed of diagnosis, eliminating unnecessary or duplicative tests and procedures, and reducing healthcare expenditures. Payers who participate in HIEs can experience greater oversight and can be better equipped to manage and coordinate patient care.