AHIMA Comments on FY19 Hospital OPPS Proposed Rule
AHIMA submitted comments to the Centers for Medicare and Medicaid Services (CMS) on proposed changes to the Hospital Outpatient Prospective Payment System (OPPS) and Quality Reporting Programs for calendar year 2019, as published in the July 31 issue of the Federal Register.
AHIMA supports leveraging the Conditions of Participation (CoPs), Conditions for Coverage (CfCs), and Requirements for Participation (RfPs) for long-term care facilities to advance electronic exchange of information, but we are skeptical that this would necessarily address information blocking in its entirety. This strategy necessitates standardization of definitions of the electronic information to be exchanged. A transition period or delayed implementation date should be instituted to allow facilities that are less advanced in exchanging electronic health information time to catch up.
We also recommend new or revised CoPs/CfCs/RfPs permit non-electronic forms of sharing medically necessary information in instances where the receiving provider, supplier, or patient/resident cannot receive the information electronically.