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CMS IPPS Final Rule: A Public Health Perspective

by Noam Arzton August 17, 2018

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

by Noam Arzton June 14, 2018

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

by Noam Arzton June 1, 2018

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.

HLN Updates White Paper on IIS/EHR Feature Overlap

by Noam Arzton April 11, 2018

Immunization Information Systems (IIS) have been around for more than twenty years. Their functionality, completeness, and usefulness have all increased over this time. IIS and electronic health record (EHR) systems have always had unique features, as well as some overlapping features, and the deployment of EHRs has enhanced the local immunization capabilities of clinician practices. Several critical clinical features that are considered to be core functions of IIS are beginning to be supported by EHRs.

IIS and EHR Feature Overlap, originally published in 2014, reviews and discusses five such critical features. The paper offers insight into the likelihood and implications of their migration from IIS to EHR, and offers recommendations to both the IIS and EHR communities for how to thoughtfully guide this migration. The proliferation of EHR with funding from the CMS EHR Incentive Programs has in some cases exacerbated the feature overlap. Both IIS and EHR projects should consider wisely investments in these functional areas, considering the potential for overlap as well as the on-hand expertise to develop, support these feature.

TEFCA: A Public Health Perspective (final)

by Noam Arzton February 8, 2018

In January 2018 the Office of the National Coordinator for Health Information Technology (ONC) issued a draft Trusted Exchange Framework and Common Agreement (TEFCA), and related supporting documents, in response to a requirement imposed by Congress in the 21^st Century Cures Act. The Act says that the TEF may include a common method for authenticating users, a common set of rules, enabling policies, and a process for managing non-compliance. Nowhere does the Act instruct ONC to determine an actual technical architecture in this process, though such a step is not precluded either.

The primary document is in two parts: Part 1 is a set of principles that set the foundation for Part 2 which is a set if minimum terms and conditions for trusted exchange. While the principles seem overall quite reasonable, the terms and conditions have many, many technical specifications and standards embedded within them and lay the groundwork for a very specific nationwide implementation. Though the phrase “network of networks” appears nowhere in these documents, Part 2 seems to describe a technical implementation not too unlike the original NwHIN/eHealth Exchange model that was implemented with limited success a number of years ago. It does not appear that this model fits all that well with any of the major market-based strategies that have emerged in the past several years, notably the Commonwell Health Alliance, Carequality, or the Strategic Health Information Exchange Collaborative (SHIEC).