On April 10, 2015, CMS released a proposed rule that would dramatically change the Medicare and Medicaid (EHR) Incentive Program, and affect CMS Meaningful Use. The following are the five 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. An EP’s Meaningful Use Stage 1 reporting period is always 90 days.
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, Meaningful Use Stage 1 and Stage 2 providers will attest to the same measures, but by using new exception rules for Meaningful Use Stage 1 providers, and different thresholds from their Stage 2 counterparts, Stage 1 did not become more difficult.
4. Stage 1 & 2 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, three current menu objectives would now be required for Stage 1 providers — 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.
Watch a free on-demand webinar: Meaningful Use Stage 3: What the Future Holds.
CMS Meaningful Use defined: The EHR Incentive Programs were designed to allow eligible providers and hospitals to use certified EHR technology in a meaningful way, in order to improve the quality and efficiency of patient care. In order to obtain incentive payment, providers are required to show that they are using their technology by meeting thresholds for objectives, phased out into three consecutive stages. Requirements increase to a higher level with each stage, allowing providers to gradually increase their EHR use, though requirements for Meaningful Use Stage 2 have been since relaxed.
Definition: Meaningful Use Measures
Meaningful use measures, or meaningful use criteria, are its rules that determine whether or not a healthcare provider may receive federal funds from the Medicare EHR incentive Program, the Medicaid EHR Incentive Program, or both.