CHA has submitted the attached response to the Centers for Medicare & Medicaid Services (CMS) request for information on the certification of health information technology (HIT). In conjunction with the Office of the National Coordinator, CMS sought input on electronic health records products used for reporting electronic clinical quality measures (eCQMs), specifically requesting feedback on how often to require recertification of HIT modules, the number of eCQMs a certified HIT module should be required to certify to, and ways to improve module testing.
In comments, CHA urged CMS to complete a full and transparent evaluation of the current state of eCQM development in order to inform future rulemaking, and to develop a strategic, long-term, detailed measurement strategy with clear goals for identifying appropriate eCQMs. In response to CMS’ specific questions, CHA urged CMS to require recertification of HIT modules each time a new eCQM is added to a program. CHA also believes that CMS should require certification of all eCQMs used in all CMS programs, and that certification should occur in advance of the measures’ adoption into the program. Finally, CHA stressed the need for a robust testing process for each eCQM.
CHA hosted a members-only call Jan. 13 to discuss the Centers for Medicare & Medicaid Services' Comprehensive Joint Replacement (CJR) model final rule. CHA reviewed key provisions of the final rule and fielded questions from participants during the call, which was recorded in its entirety and is now available for members on CHA’s website. The link also contains presentation slides and additional resources related to CJR.
CHA submitted the attached comment letter to the Centers for Medicare & Medicaid Services (CMS) today in response to CMS’ request for information on core access to care measures and metrics that could be used to assess access in the Medicaid program. CHA encourages CMS to take a thoughtful approach and develop an action plan that would ensure successful implementation of CMS' goals for the program.
More specifically, CHA recommends that CMS develop and implement a National Access Strategy, similar to its approach when developing the National Quality Strategy, and allow multi-stakeholder and multi-agency participation in the process. CHA also urges CMS to look beyond traditional metrics to identify new evidence-based areas for measure development and to identify measurement gaps. CHA recommends that CMS consider environmental factors such as poverty, access to transportation and affordable housing when evaluating a beneficiary’s access to care. These factors can have significant impacts on patient health and health care delivery and should receive consideration. While CHA appreciates CMS’ efforts to create an equitable health care system, CHA requests that CMS recognize the costs of providing health care when it determines whether rates are adequate to ensure access. CMS must ensure that payment rates remain adequate for hospitals that are asked to do more with less.
CHA reminds members to register for its member call on the Comprehensive Care for Joint Replacement model. The call has been rescheduled to a new time: Jan. 13 from 1:30 – 3 p.m. (PT). During this call, CHA will review key provisions of the final rule as well as CHA DataSuite reports distributed today.
To register, please visit www.surveymonkey.com/r/SJXZTZS. Deadline for registration is Jan. 12 at noon (PT). Dial-in information and materials will be sent to registered attendees by close of business Jan. 12.
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The Centers for Medicare & Medicaid Services (CMS), in conjunction with the Office of the National Coordinator (ONC), has issued the attached request for information about the certification of health information technology (HIT). CMS and ONC seek information on electronic health records (EHR) products used for reporting electronic clinical quality measures for EHR incentive programs, the hospital inpatient quality reporting program and the physician quality reporting system. CMS and ONC request feedback on how often to require recertification, the number of clinical quality measures a certified HIT module should be required to certify to, and ways to improve testing of the modules. Comments on the request are due Feb. 1.
CHA has submitted the attached comment letter to the Environmental Protection Agency (EPA) on its proposed rule for management standards for hazardous waste pharmaceuticals. Developed in conjunction with a member workgroup, CHA’s comments are generally supportive of the proposed requirements but express concern with the overlap of state and federal law. CHA urges EPA to develop technical assistance for state agencies, ensuring that both state and federal regulations can be complied with efficiently. In addition, CHA urges EPA to delay the effective date of the final rule to no earlier than one year from its release. CHA believes that state agencies need additional time to understand the opportunities and challenges these new policies present, and develop resources to educate hospitals and health care facilities on compliance. Comments on the proposed rule are due Dec. 24.
CHA has issued the attached detailed summary, prepared by Health Policy Alternatives, Inc., on the Centers for Medicare & Medicaid Services (CMS) final rule implementing the Comprehensive Care for Joint Replacement (CJR) payment model. The summary is in addition to the previously issued executive summary of key provisions. CMS has finalized the start date for this program as April 1, 2016, a slight delay from the proposed start date of Jan. 1, 2016. The model will require participation from inpatient prospective payment system hospitals in three California metropolitan statistical areas: Los Angeles-Long Beach-Anaheim (Orange County and Los Angeles County); Modesto (Stanislaus County); and San Francisco-Oakland-Hayward (Alameda County, Contra Costa County, San Francisco County, San Mateo County and Marin County). A complete list of hospitals CMS believes to be subject to the CJR program is also attached.
CHA has released the attached summary, prepared by Health Policy Alternatives, Inc., detailing the Centers for Medicare & Medicaid Services (CMS) final rule for the calendar (CY) year 2016 home health prospective payment system. The final rule implements payment and policy changes that take effect Jan. 1, 2016. Additionally, CMS finalizes implementation of a home health value-based purchasing model in nine states, not including California. CMS estimates that the final rule will reduce home health payments by a net $380 million, or negative 1.4 percent, in CY 2016.
CMS also responded to comments submitted in response to the proposed rule by stakeholders, including CHA, and made a few modifications to its proposals. Most notably, CMS will phase in the nominal case mix adjustment over three years, rather than two.
CHA has prepared the attached first-glance summary of the Centers for Medicare & Medicaid Services (CMS) final rule implementing the Comprehensive Care for Joint Replacement (CJR) payment model. As noted when the rule was issued, CMS has finalized the start date for this program to April 1, 2016, a slight delay from the proposed start date of Jan. 1, 2016. The model will require participation from inpatient prospective payment system hospitals in three California metropolitan statistical areas, as proposed.
