Proposed OPPS/ASC Rule Offers 90-day EHR Reporting - DoctorsManagement Proposed OPPS/ASC Rule Offers 90-day EHR Reporting - DoctorsManagement

Proposed OPPS/ASC Rule Offers 90-day EHR Reporting

By  Grant Huang, CPC, CPMA| July 17, 2016

You would only have to report meaningful use measures from your electronic health record (EHR) for 90 days in 2016 instead of the full year if CMS’ proposed Outpatient Prospective Payment System and Ambulatory Surgical Center (OPPS/ASC) rule for 2017 is finalized.

The meaningful use proposal would apply to all eligible providers, including critical access hospitals (CAHs), and means any contiguous 90-day period between Jan. 1, 2016 and Dec. 31, 2016, could be used for reporting. “We believe it would continue to assist healthcare providers by increasing flexibility in the program,” CMS stated in a fact sheet accompanying the proposed rule, which dropped July 6.

This provision is the biggest in an otherwise uneventful proposed rule for most physician practices. Below is a bullet-point list of other highlights from the 2017 proposed rule.

OPPS and ASC payment rates. CMS proposes to update OPPS payments by 1.55%, and the agency estimates an overall 1.6% payment increase for hospitals paid under OPPS in 2017. For ASCs, the payments are updated annually based on increases to the Consumer Price Index for urban consumers. In 2017, CMS is projecting an overall 1.2% increase in ASC payments.

Ÿ90-day meaningful use reporting period. As mentioned earlier, the reporting period for 2016 is proposed to be any 90-day contiguous period for eligible providers. Additionally, CMS admits in the proposed rule that it would not be “technically feasible” for those eligible providers that have not successfully demonstrated meaningful use yet (i.e. new participants) to attest to the Stage 3 objectives and measures. CMS proposes that these providers attest to modified stage 2 objectives and measures by Oct. 1, 2017.

Ÿ  EHR hardship exceptions. For new providers – again those who have not yet attested to meaningful use – CMS is proposing a new hardship exception that would allow them to be exempt from the 2018 payment adjustment. These providers would be required to transition to meaningful use reporting under the Merit-Based Incentive Payment System (MIPS) in 2017, under the MACRA proposed rule.

New ASC quality measures. The existing Ambulatory Surgical Center Quality Reporting Program (ASCQR) would get seven new quality measures under the 2017 OPPS/ASC proposed rule. There is a new measure for anesthesia and one for cataract surgery. The remaining five have to do with patient satisfaction and experience.

The OPPS/ASC final rule is typically released around the beginning of November.

Grant Huang, CPC, CPMA ( The author is Director of Content at DoctorsManagement.