Premier's Draft Comments on FY 2020 Hospital Inpatient PPS and LTCH Proposed Rule

Premier is pleased to share draft comments to CMS in response to the fiscal year (FY) 2020 hospital inpatient prospective payment system (PPS) and long-term care hospital (LTCH) PPS proposed rule.

Highlights of Premier's responses to CMS's requests for information include:

• Measurement of provider efficiency in using EHRs. Premier believes it is premature for CMS to develop measures to assess the efficiency of providers' EHR use. Premier recommends that CMS work with ONC and National Institute of Standards and Technology (NIST) to improve the usability of certified EHRs and identify best practices to ensure the incorporation of EHRs within the clinical workflow. We also urge CMS to accelerate efforts and work with ONC to continue to explore ways to increase provider and end user satisfaction with EHRs.

• Opportunities for bonus points in Promoting Interoperability (PI) scoring. Premier voices support for CMS's proposal to provide bonus points in scoring for the PI program for healthcare providers engaging in activities that pilot approaches for capturing patient-generated health data and attestation to High Priority Practices and/or the Organizational Responsibilities SAFER Guides. Premier also voices support for the ability to earn bonus points though early adoption of a certified FHIR-based application programming interface (API), voluntary submission of the Query of Prescription Drug Monitoring Program measure.

• Public reporting of PI measures. Premier supports public reporting of provider performance on quality measures. However, Premier expresses concern about CMS' proposal to publicly report hospital performance on PI measures in Hospital Compare. PI measures have recently been revised; measure performance should be validated and outcomes data stabilized prior to public reporting. Premier recommends that CMS collect a minimum of two years of reported PI measure data before inclusion in Hospital Compare, and encourages CMS to ensure that measures selected for public display are meaningful and valuable to patients.