Last week, the Centers for Medicare and Medicaid Services (CMS) sent the long-awaited final rule that modifies the requirements of the Meaningful Use program Stages 1 and 2 for 2015-2017, as well as the rule implementing Stage 3, to the Office of Management and Budget (OMB) for review.
Providers had expressed concern that the proposed Stage 3 rule was overly ambitious and burdensome. Stage 3 is slated to commence in 2017. Ultimately, CMS’s goal with the modifications would be to simplify the process and make the program more sustainable. While the two rules were combined when delivered to OMB, it is still unclear if the rules will be finalized as a single rule or two separate ones. The key changes include:
- The Stage 1 and 2 modifications for 2015-2017 would change the Medicare and Medicaid Electronic Health Record (EHR) Incentive Program EHR reporting period in 2015 to a 90-day period aligned with the calendar year and also aligns the reporting period in 2016 with the calendar year. Currently, the program is based on a federal fiscal year for eligible hospitals.
- The proposed rule modifications would streamline reporting requirements by reducing and simplifying the number of objectives required for Stage 2 attestation - the process through which an organization has successfully demonstrated meaningful use - to eight objectives and a few public health measures. The objective is to ease reporting burdens under Stage 2 and bridge transition to Stage 3 reporting.
- For the Stage 3 rules, all eligible professionals and eligible hospitals beginning in 2018 would report on Stage 3 of the meaningful use program regardless of their previous participation. Providers would have the option to move to Stage 3 starting in 2017.
- In addition, the proposed Stage 3 rule would "change the EHR reporting period so that all providers would report under a full calendar year timeline," except for those attesting to the Medicaid meaningful use program for the first time.
- The proposed rule also would raise the threshold for several program requirements and would require eligible professionals to fulfill two of three options for ensuring patient engagement.
CMS reports that it expects to open attestation for 2015 Meaningful Use by January 4, 2016. Industry groups, however, have been waiting for the rule altering the program and have pushed to extend reporting into the first quarter of 2016 given the limited timeframe to meet the start date (October 3) for the last 90-day reporting period.