The Centers for Medicare & Medicaid Services (CMS) issued final rules that make changes to the requirements of the Meaningful Use/EHR Incentive Program that take effect in this current (2015) reporting year. This final rule combines proposals first announced in April 2015 to the Modifications to Meaningful Use in 2015 through 2017 (Modified Stage 2); a Stage 3 rule that is optional in 2017 but required in 2018; and, 2015 Edition EHR Certification Criteria. Separately, CMS has temporarily shut down its Internet website through which providers submitted attestations for MU, announcing it will resume processing attestations in early 2016.
Reporting Period for Hospitals
Starting with this 2015 MU cycle, the reporting period for all providers, including Critical Access Hospitals (CAH) and Eligible Hospitals (EH) is aligned with the calendar year. This means that for an EH or CAH, the current MU reporting period has been extended from September 30, 2015 to December 31, 2015. The reporting period for Eligible Providers (EP) did not change under these rules.
An EH, CAH or EP now has has 60 days from the end of the reporting year to file its attestation for MU. The deadline for all filers to attest to MU in this 2015 reporting year is February 29, 2016. The deadline may be extended to the end of March if providers need more time.
Data Collection Period
CMS has changed the data collection period for the 2015 reporting year to 90 consecutive days for any hospital or provider attesting for MU. An EH or CAH could use data collected for any continuous 90-day period beginning October 1, 2014 through December 31, 2015. EPs would report data from 90 consecutive days collected during its calendar year reporting period.
For 2016 and 2017, the Modified Stage 2 MU Rules call for 12-month data collection for the entire calendar year for all EPs, CAHs, and EHs. However, new participants to the MU program would have a 90-day reporting period. In 2017, providers who choose to start attesting to Stage 3 will have a 90-day reporting period.
Changes to Measures and Objectives
Starting with the 2015 reporting year, the number of measures and objectives EPs have to meet reduces from 18 to 10. The number of objectives for eligible hospitals decreases from 20 to 9. Some of the objectives and measures that are no longer required to be reported are recorded demographics, vital signs, smoking status, structured lab results or imaging results. These changes remove the menu and core structure of Stages 1 and 2, reducing the overall number of objectives to which a provider must attest.
Other significant changes modify the patient action measures in the Stage 2 objective related to patient engagement. CMS reduced the threshold from the Stage 2 Objective for Patient Electronic Access from 5% of eligible patients to showing that a single patient seen by a provider or discharged from a hospital viewed, transmitted or downloaded their PHI from the EHR.
The Modified Stage 2 rule changes the threshold of the Stage 2 Objective for Secure Electronic Messaging. Instead of attesting that a percentage of patients have exchanged secure electronic messages with providers, EPs and hospitals must only attest that they have to capability to do so.
CMS also consolidated all the public health reporting objective into one objective with measure options following the structure of the Stage 3 Public Health Reporting Objective. In addition, the 2015 MU rule changes the eligible hospital (EH) prescribing objective from a “menu” object to a mandatory objective with an exclusion available for some EHs and CAHs.
#The modifications to Stage 2 include alternate exclusions & specifications for providers that were scheduled to demonstrate Stage 1 of Meaningful Use in 2015.
*Alternate exclusion reporting continues in 2016 for CPOE (all providers) and eRX (for EH) only.
2015 Edition CEHRT Rule
The Office of the National Coordinator for Health IT (ONC) made final its new minimum criteria for electronic health technology to be certified as eligible for certification to the EHR incentive program. EHR vendors will have until January 1, 2018, to develop products to meet the standards in the rule. Most of the changes are intended to drive development of products that support interoperability for the exchange of patient information and the support of exchange of sensitive health data by including data segmentation in the privacy criteria.
More to Come Concerning Stage 3
In adopting Stage 3 measures and objectives, CMS issued the standards as a “Final Rule with Comment Period”, leaving open the possibility of changes in the coming months prior to its adoption in 2018. In addition, there are several legislative proposals in Congress to push back or do-away with Stage 3. We will provide a full summary of the requirements in Stage 3 when CMS pronounces its changes as (really) final.