Earlier this week, the Centers for Medicare & Medicaid Services (CMS) released the Final Rule for Meaningful Use that includes criteria for the 2015 program year. While InvigorIT Healthcare is analyzing the final rule to determine its impact on our clients, we want to be sure to highlight some of the top takeaways:

  • The number of MU objectives have been reduced from 20 to 10, focusing on those associated with interoperability rather than data input.
  • Thresholds of some of the objectives have been lowered, and those attesting for the first time will be able to take exceptions for certain objectives.
  • Eligible Providers may now report for 90 days instead of a calendar year.
  • Providers have been given more time to comply with new requirements of Meaningful Use Stage 3, scheduled to start in 2018. CMS opened up a 60 day public comment period.
  • The Rule creates a pathway to transition to the Merit-based Incentive Payment System (MIPS), included in the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). A proposed rule is expected mid-2016.
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Overview of Rule Provisions

CMS reviewed and considered more than 2,500 comments on the two proposed rules to create the final policies, with the opportunity for additional comment, for participation in the EHR Incentive Programs.  In recognition of the issues raised, CMMS made significant changes to ease reporting burden for all providers, supporting health information exchange, and improving patient outcomes. For example, the regulations:

  • Shift the paradigm so health IT becomes a tool for care improvement, not an end in itself.
  • Provide simplicity and flexibility so that providers can choose measures that use in their practices and report progress that are most meaningful to their practice.
  • Give providers and state Medicaid agencies more time – 27 months, until January 1, 2018 – to comply with the new requirements and prepare for the next set of system improvements.
  • Give developers more time to create the next advancements in technology that will be easier to use and more appropriate to new models of care and access to data by consumers.
  • Support provider exchange of health information and a more useful interoperable infrastructure for information exchange between providers and with patients
  • Give developers more time to create the next advancements in technology that will be easier to use and more appropriate to new models of care and access to data by consumers.
  • Address health information blocking and interoperability between providers and with patients.

For the EHR Incentive Programs in 2015 through 2017, major provisions include:

  • 10 objectives for eligible professionals including one public health reporting objective, down from 18 total objectives in prior stages.
  • 9 objectives for eligible hospitals and critical access hospitals (CAHs) including one public health reporting objective, down from 20 total objectives in prior stages.
  • Clinical Quality Measures (CQM) reporting for both eligible professionals (EPs) and eligible hospitals/CAHs remains as previously finalized.

CMS evaluated the current programs and identified areas where modifications could be made to align with the long-term vision and goals for Stage 3. CMS restructured the objectives and measures of the EHR Incentive Programs in 2015 through 2017 to align with Stage 3, and modified “patient action” measures in Stage 2 objectives.  These changes recognize the progress providers have made and realign with long term goals.

For Stage 3 of the EHR Incentive Programs in 2017 and subsequent years, major provisions include:

  • 8 objectives for eligible professionals, eligible hospitals, and CAHs:  In Stage 3, more than 60 percent of the proposed measures require interoperability, up from 33 percent in Stage 2.
  • Public health reporting with flexible options for measure selection.
  • CQM reporting aligned with the CMS quality reporting programs.
  • Finalize the use of application program interfaces (APIs) that enable the development of new functionalities to build bridges across systems and provide increased data access. This will help patients have unprecedented access to their own health records, empowering individuals to make key health decisions.