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How providers should prepare for the final rule from CMS

The Centers for Medicare and Medicaid (CMS) released a proposed rule for the Physician Fee Schedule in July, with a final rule expected in October or November 2018. Proposed changes relate to the Appropriate Use Criteria (AUC) for Advanced Radiology Procedures, Quality Payment Program for Merit-Based Incentive Payment System (MIPS), Medicaid Promoting Interoperability (formerly known as Meaningful Use) and payment updates.

Even though the rule is not yet final, there are actions that physicians should take now to prepare. Here are six things we recommend:

1. Review the proposed changes. The CMS offers a fact sheet to help summarize the voluminous proposal, which is more than 1,400 pages in length. We are also offering webinars for our clients to help them navigate the proposed changes from a technology perspective.

2. Comment, comment, comment. The CMS welcomes comments and makes it easy to submit them. The deadline is September 10, 2018. Your responses can help shape the final rule.

3. Use 2015 Edition certified electronic health record technology (CEHRT). Providers should continue with plans to upgrade or use 2015 CEHRT for 2019. It is very clear that the CMS will require this, as it was finalized on the hospital side.

4. Go live with AUC solution before Jan. 1, 2020. A clinical decision support mechanism (CDSM) must be in place to meet AUC for advanced radiology procedures. This is critical and must be implemented to receive payment for these services.

5. Prioritize new workflows to meet Promoting Interoperability. Several of the requirements are unlikely to be dropped including those related to Application Programming Interfaces (APIs), receiving C-CDAs, reconciliation of problems, medications and allergies, and updating registry interfaces.

6. Continue with plans to implement proposed measures to be dropped. Several items related to patient participation may be dropped from the final rule. But we recommend continuing to plan for these measures, which include patient-specific education, view, download & transmit, secure messaging and patient-generated health information.

To learn more about proposed changes, clients can listen to a recorded webinar, which includes contact information for solution-specific questions.

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