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Expert: Steve Mok, PharmD, MBA, BCPS, BCIDP  |  Interested in submitting a different question? Ask your question here!

  • What is the Medicare Promoting Interoperability Program?

    Centers for Medicare and Medicaid Services (CMS) Medicare Promoting Interoperability Program had its roots from what was commonly known as the Meaningful Use program from the 2010s. The goal of this updated incentive program is to move beyond existing requirements of meaningful use to focus on interoperability and improving patient access to information. The program scope is eligible hospitals and critical access hospitals. There are four scored objectives: .

    • Electronic prescribing 
    • Health information exchange 
    • Provider to patient exchange  
    • Public health and clinical data exchange 

    In 2024, NHSN AUR reporting will become a measure until public health data and clinical data exchange objective. 

  •  When do I need to have a reporting solution in place to meet the requirements?

    AUR reporting to NHSN will be required under the Public Health and Clinical Data Exchange objective. Hospitals must attest active engagement with the AUR submission using an ONC-certified technology in the calendar year 2024.  

    Hospitals are expected to attest to their active engagement in the program during the calendar year 2024 in early 2025, similar to how you would file a tax return for the previous calendar year after the New Year.  As an example, attestation of participation in the Promoting Interoperability program during calendar year 2023 timeline is listed below.  The timeline for reporting year 2024 has not been released yet but we would expect it to look very similar to 2023. 

    Reporting solutions to meet AUR requirements

  • Do I have to submit both AU and AR data to NHSN?
    Hospitals must submit both AU and AR data to satisfy the AUR reporting requirements of the Promoting Interoperability program. There is no partial credit. Hospitals that do not have an electronic laboratory information system may apply to CMS for an exclusion. Hospitals that do not meet the mandatory reporting requirements risk significant payment penalties defined in the inpatient prospective payment system rules (IPPS).  Additionally, hospitals may apply for a hardship exception if they have significant challenges in their operating conditions (e.g. cyberattack) during the year, however, keep in mind that CMS has a limit of “5 in a lifetime” hardship exceptions so you should discuss the merit of using up one of these exceptions with your executives. 
  • What are the requirements for submitting AUR?
    Because the data submission must be via a CDA format and the counting logic of days of therapy, days present, and antimicrobial resistance events are complex, the program requires that hospitals submit the data using a certified technology.  To qualify for the Promoting Interoperability program credit, AUR reports must be submitted to the NHSN by a vendor certified for AUR reporting by the ONC and listed on the Certified Health IT Product List (CHPL).  
  • What is the risk of not fulfilling the reporting requirements?
    Hospitals that do not meet the mandatory reporting requirements risk significant payment penalties defined in the inpatient prospective payment system rules (IPPS). 
  • How much is the penalty for not participating?

    While specific potential downward payment adjustments in 2025 haven’t been published for the 2024 program year, failure to comply with required elements of Promoting Interoperability has historically resulted in a significant reduction of Medicare payments. Historically, hospitals faced a 75% reduction in the annual rate increase approved under the IPPS, and critical access hospitals risked a 1% reduction in Medicare payment reimbursements.

    For the 2023 program year, acute care hospitals that do not meet the requirements of the program will receive only a 0.625% increase in their reimbursements in 2024 instead of 3.1% increase for compliant hospitals.

  • Does the Medicare Promoting Interoperability Program apply to pediatric hospitals (Medicaid) or is it specific to Medicare patients?
    The financial impact of the program is mostly for services provided to Medicare beneficiaries. Pediatric hospitals may not experience a significant adverse financial impact from non-compliance.  However, keep in mind that the Joint Commission updated its Antimicrobial Stewardship standards in 2023, and Element of Performance 16 requires that hospitals keep track of their antimicrobial use using standardized metrics or active AU submission to NHSN. In addition, we encourage you to discuss with quality and finance departments because many of your 3rd party payors may tie their reimbursements or incentives to adherence to Medicare programs.
  • What are other benefits of submitting this data?
    One significant benefit of submitting antimicrobial use data from your hospital is the provision of standardized antimicrobial administration ratio (SAAR). At a high level, SAAR benchmarks your antimicrobial use against other hospitals submitting AU data to NHSN, using advanced statistical methodology to account for the hospital’s unique characteristics, such as location, hospital size, types of patients served, the proportion of beds dedicated to intensive care, etc. Pharmacists can leverage SAARs to better understand how their observed antimicrobial use differs from the predicted usage and identify areas of strength and improvements.
  • What if I don’t have an onsite microbiology lab?

    Third-party or reference labs can often send microbiology results electronically to hospitals or vendors using standardized interfaces. One of the primary goals of the Promoting Interoperability program is to encourage the electronic transfer of such information. As such, hospitals should engage with their IT department, electronic health records provider, and the reference lab to post lab results back into the EHR.

    However, as an interim measure, you may consider working with your AUR Reporting vendor to establish a direct connection with the reference lab to obtain the microbiology results. The team at Wolters Kluwer has experience working with reference labs to successfully obtain microbiology results directly.

  • How much time and effort is required to submit AUR?
    Using an ONC-certified solution such as Sentri7, pharmacists can confidently submit AUR data with a few simple clicks and know that the data will be securely sent to NHSN on your behalf. As submission requirements become more complex and reporting requirements change (such as new antimicrobials, eligible organisms, and resistance phenotypes), turning to a trusted partner frees the pharmacists up from the tasks of reporting and instead allows that time for AMS improvement efforts that make a difference at the bedside.
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