Promoting Interoperability: A Call for Thoughtful Implementation

?? Today, CHIME commented on the Centers for Medicare & Medicaid Services ’ (CMS) hospital inpatient prospective payment system (IPPS) proposed rule for fiscal year (FY) 2025. In our letter, we requested that CMS consider our recommendations on the proposed changes to the Medicare Promoting Interoperability Program. CHIME members remain steadfast in their commitment to being partners with their patients to facilitate greater – and safer – interoperability.

?? Understanding the long-term impacts of these proposed policies is crucial. We urge CMS to avoid inadvertently increasing the burden on hospitals and healthcare systems.

?? Key Recommendations & Concerns:

1. Scoring Threshold: We oppose raising the minimum scoring threshold to 80 points for the EHR Reporting Period in calendar year (CY) 2025. Instead, we recommend 70 points to ensure fairness and feasibility. ??
2. eCQM Reporting Alignment: We appreciate that CMS is moving forward with their ongoing goal to align the eCQM reporting periods and criteria in the Medicare Promoting Interoperability Program with the Hospital Inpatient Quality Reporting (IQR) Program. However, CHIME is concerned that these efforts – while well-intended – are inadvertently causing regulatory burden. Thus, we suggest limiting additions to one new eCQM per reporting period. ??
3. SAFER Guides Updates: In our comment letter in response to last year’s proposed rule, CHIME was strongly supportive of updating the Safety Assurance Factors for EHR Resilience (SAFER) Guides. While we are appreciative that CMS is now updating the SAFER Guides, and believe it is a positive step – we are concerned that the timeline and uncertainty could present challenges for our members. Our members remain staunch champions for promoting safety and the safe use of EHRs.??

?? Our members, being executives and senior healthcare IT leaders – are ready to continue serving as a resource for CMS. We aim to collaborate as partners to promote safety and effective EHR use, advocating for thoughtful and incremental changes. ??

?? We thank CMS for the opportunity to comment and look forward to deepening our collaborative relationship. Together, we can achieve our shared goals and drive meaningful improvements in healthcare.

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