On April 10, 2015, CMS released a proposed rule that would dramatically change the Medicare and Medicaid (EHR) Incentive Program. The following are the 5 most important proposed changes to the rule and ramifications of these proposed changes
1. Reduced Reporting Period in 2015 – The EHR reporting period that was targeted to be a full year in 2015 would be reduced to a 90-day (not calendar quarter) period based on the calendar year.
2. The Most Difficult Patient Engagement Measures are Relaxed – The Exchange of Secure Messages with patients where the previous threshold for Meaningful Use Stage 2 was 5% is now reduced to just having the capability to exchange secure messages with patients. Essentially, having an EHR Certified to the 2014 Stage 2 standards will get you a passing grade on this measure.
In addition the Patient Action to View, Download, or Transmit Health Information measure where the previous threshold was 5 percent threshold for Stage 2 now only requires that just 1 patient seen by the provider during the EHR reporting period views, downloads, or transmits his or her health information to a third party.
3. Simplify the Attestation Process by Removing Measures that are Redundant, Duplicative, or had already reached a very high performance level (“topped out.”) – CMS identified a set of measures that met the Redundant, Duplicative or Topped Out criteria and now proposes that providers no longer need to attest to those measures. See the table below.
In addition, Stage 1 and Stage 2 providers will attest to the same measures, but by using new exception rules for Stage 1 providers and different thresholds than their Stage 2 counterparts, Stage 1 did not become more difficult.
4. Structural Requirements the Concept of Core and Menu – Because of the restructuring of measures, the concept of core and menu will be deprecated in favor of choices within certain objectives; for example: the Public Health Objective. Now for for Stage 1 providers three current menu objectives would now be required and for Stage 2 one current hospital menu objective would now be a required objective. These objectives are as follows:
- Stage 1 Menu: Perform Medication Reconciliation
- Stage 1 Menu: Patient Specific Educational Resources
- Stage 1 Menu: Public Health Reporting Objectives (multiple options)
- Stage 2 Menu Eligible Hospitals and CAHs Only: Electronic Prescribing
The new reporting structure is outlined in the tables below:
5. 2015 Will Be a Backloaded Year – This proposed rule will have a 2-month comment period and therefore we don’t expect the final rule until the third quarter. After the final rule is published, EHR vendors will need to update their Meaningful Use Report Cards and the measurement period options in their software. While there may be a few 90-day reporting options available, we expect another year where most providers will be reporting on the last quarter of the year.
Wondering what changes are proposed with regard to perhaps the most difficult Stage 2 measure – the Electronic Exchange of PHRs via Direct?? Stay tuned to future blog posts.
Join us for a live discussion of the Meaningful Use Stage 3 Proposed Rule and its impact on practices in a free webinar on April 28: Meaningful Use Stage 3: What the Future Holds.