In April 2015, the Department of Health and Human Services, Centers for Medicare and Medicaid Services (CMS) issued a proposed rule with meaningful use (MU) changes for 2015 through 2017. The proposal followed a CMS proposal for MU Stage 3, announced March 2015, that would govern MU in 2017 and after.
The proposal offered in April would go into effect for the 2015 reporting year and align Stage 1 and Stage 2 objectives and measures of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program. Criteria to meet MU modified Stage 2 thresholds will be easier to meet under the proposal, but penalties for MU will increase until 2018 when MU is rolled into the Merit Based Payment System (MIPS), along with the Physician Quality Reporting System, and the Electronic Prescribing (eRX) Incentive Program.
Critical proposals for American Academy of Family Physician members to know include:
Proposed changes to individual objectives and measures for Stage 2 of MU include:
In order to best explain the proposed MU changes, here is a year-by-year breakdown of the rule proposals.
There are two potential cohorts, depending on the first year the physician attested to MU.
For those who first attested from 2011 thru 2013, your reporting period will be 90 days, and you will have to meet the modified Stage 2 measures. You are not allowed to use any of the alternative measures or exclusions.
For those who first attested from 2014 thru 2015, your reporting period will also be 90 days, and you will also have to meet the modified Stage 2 measures. However, since you were scheduled to attest to Stage 1, you can use any of the alternative measures or exclusions.
Everyone is required to meet the modified Stage 2 measure, and you are not allowed to use any of the alternative measures and exclusions.
For those who first attested from 2011 to 2015, your reporting period is a full calendar year.
For those who are attesting for the first time in 2016, your reporting period is 90 days.
Regardless of your first attestation year, everyone has a reporting period of a full calendar year. Everyone has the option to either meet the modified Stage 2 measures (without using any of the alternative measures or exclusions); or meet the Stage 3 measures.
Everyone will be required to meet Stage 3 measures and report for a full calendar year.
CMS has identified the following list of objectives and measures from MU Stage 1 and Stage 2 as redundant, duplicative, or topped out. Many of these objectives and measures may be valuable, and CMS encourages their continued use, but under the proposal, they will not require reporting.
Objectives and Measures for Eligible Professional
Record Vital Signs
Record Smoking Status
Structured Lab Results
Family Health History
Objectives and Measures for Eligible Hospital/CAH
Structured Lab Results
The proposed structure for MU for 2015 through 2017 include nine required objectives for EPs using Stage 2, and eight required objectives for EHs and CAHs using Stage 2, with alternate exclusions and specifications for Stage 1 providers in 2015.
The current stage structure, retained objectives, and proposed structure is as follows:
Current Stage 1 Structure
13 core objectives
5 of 9 menu objectives, including 1 public health objective
6 core objectives
3 menu objectives
2 public health objectives
9 core objectives
1 public health objective (2 measure options)
11 core objectives
5 of 10 menu objectives, including 1 public health objective
5 core objectives
3 public health objectives
8 core objectives
1 public health objective (3 measure options)
Current Stage 2 Structure
17 core objectives, including public health objectives
3 of 6 menu objectives
0 menu objectives
4 public health objectives
16 core objectives including public health objectives
7 core objectives
1 menu objective
1. Protect Electronic Health Information
2. Clinical Decision Support
3. Computerized Provider Order Entry (CPOE)
4. Electronic Prescribing (eRx)
5. Summary of Care
6. Patient Education
7. Medication Reconciliation
8. Patient Electronic Access
9. Secure Electronic Messaging
In addition to reporting the objectives above, EPs must also report on either 1 or 2 public health reporting measures. Providers scheduled to be in Stage 1 must choose 1 of the possible 5 measures below. Providers scheduled for Stage 2 must choose 2 of the possible 5 measures below.
CMS's EHR Medicare and Medicaid Incentive Program provides incentive payments to expedite and encourage EPs, eligible hospitals (EHs), and critical access hospitals (CAHs) to adopt, implement, or upgrade certified-EHR technology, and to demonstrate the "meaningful use" of certified-EHR technology.
EPs, EHs, and CAHs must demonstrate MU by meeting certain requirements. Those who fail to meet those requirements under the program will forfeit their incentive payment. However, starting in 2015, providers failing to meet criteria under the program face downward payment adjustments.
The program was designed to consist of three stages of MU, with each stage consisting of increasing requirements. Providers advance through each stage.
Stage 1 was intended to establish requirements for the electronic capture of clinical data, including providing patients with electronic copies of their health information.
Stage 2 focused on the data captured in Stage 1 being exchanged among health care providers and patients in order to improve coordination of care. Stage 2 also implemented a set of clinical quality measures (CQMs) for all providers to report in 2014, regardless of which stage they were in.
Stage 3 focuses on the advanced use of EHR technology to promote improved patient outcomes by increasing interoperability of health data and sharing among providers.
Acumen Physician Solutions. Meaningful use in 2015-2017: Only 9 objectives? http://www.acumenmd.com/blog/meaningful-use-in-2015-2017-only-9-objectives/(www.acumenmd.com). Accessed May 29, 2015.
Centers for Medicare and Medicaid Services. Federal register: Medicare and Medicaid programs; electronic health record incentive program—modifications to meaningful use in 2015 through 2017; proposed rule. Department of Health and Human Services. 2015. DHHS80(72)42CFR(495). http://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/Modifications_MU_Rule.pdf(www.cms.gov). Accessed May 29, 2015.
Healthcare Information and Management Systems Society (HIMSS). New CMS NPRM offers significant meaningful use flexibility in 2015 through 2017 program years. http://www.himss.org/News/NewsDetail.aspx?ItemNumber=41714(www.himss.org). Accessed May 26, 2015.
Hinshaw Health Law Alert. CMS issues proposed Stage 3 meaningful use standards. http://www.hinshawlaw.com/assets/htmldocuments/Articles/HealthLawAlert_LongBranded_04062015.pdf(www.hinshawlaw.com). Accessed May 27, 2015.
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