Regulations July 2017 q Final 2018 MACRA regulations

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Regulations – July, 2017 q Final 2018 MACRA regulations published q Awaiting final rule

Regulations – July, 2017 q Final 2018 MACRA regulations published q Awaiting final rule of the 2018 Inpatient Prospective Payment System q 2018 Quality Payment Program Proposed Rule (comments – Aug 21, 2017) q 2018 Physician Fee Schedule Proposed Rule (comments – Sept 11, 2017) q 2018 Outpatient Prospective Payment System Proposed Rule (comments – Sept 11, 2017)

QPP Proposed Rule

QPP Proposed Rule

QPP Proposed Rule

QPP Proposed Rule

QPP Proposed Rule

QPP Proposed Rule

Possible comment areas - QPP q Possible naming of FHIR-based standards in final rule

Possible comment areas - QPP q Possible naming of FHIR-based standards in final rule q End-to-end electronic submission q Quality reporting submission mechanisms q The costs and benefits of using standards for reporting

Possible comment areas - QPP q QRDA III – possible new standards (FHIR) q

Possible comment areas - QPP q QRDA III – possible new standards (FHIR) q “… we seek comment for future rulemaking regarding the potential shift to seeking alternatives which might fully replace the QRDA III format in the QPP in future program years…. ” q Comments: q HL 7 strongly believes that the FHIR-based standards and resources developed for quality reporting have reach a level of maturity and readiness in the industry sufficient for CMS to consider naming and incorporating in the final QPP regulation the following elements: q FHIR Measure Report Resource: which defines the report itself, and since it is based on QRDA, it is fully aligned with it. q QI Core Profile: on top of the FHIR Measure Report Resource to capture and represent quality information, and as based on the US Core profile to define measure content q Established a transition period of 12 months during which both the current QRDA III and these two FHIRbased profiles/resources will be acceptable for use. It will be important to ensure that if both sets of standards are allowed to be used during a transition period, that both sets of standards produce the exact same results for the same measures. This should be mitigated by the fact that QI Core maps to QDM-based HQMF standard q Leave the measure on HQMF and CQL and allow reporting using these two FHIR-based standards, in addition to QRDA III q By naming these two elements in the final QPP regulation, CMS will provide the industry with a roadmap for the future of quality reporting standards. This will also help fast-track the final refinement, adoption and use of these standards

Possible comment areas - QPP q End-to-end electronic submission q Quality reporting submission mechanisms

Possible comment areas - QPP q End-to-end electronic submission q Quality reporting submission mechanisms q The costs and benefits of using standards for reporting