Understanding the Modifications & Changes
CMS recently released a final rule that specifies criteria that eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs) must meet in order to continue to participate in the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. The final rule’s provisions encompass EHR Incentive Programs in 2015 through 2017 (Modified Stage 2) as well as Stage 3 in 2018 and beyond.
The EHR Incentive Programs in 2015 through 2017 (Modified Stage 2) reflect changes to the objectives and measures of Stages 1 and 2 to align with Stage 3, which focuses on the advanced use of EHRs. The changes also aim to reduce the complexity of the program and work toward a shift to a single set of sustainable objectives and measures in 2018. Redundant, duplicative, or topped out measures have been removed.
Starting in 2015, all providers will be required to attest to a single set of objectives and measures. Since this change may occur after providers have already started to work toward meaningful use in 2015, there are alternate exclusions and specifications within individual objectives for providers who were previously scheduled to be in Stage 1 of the EHR Incentive Programs.
To allow CMS and providers time to implement these modifications, the EHR reporting period in 2015 is any continuous 90 days period within the calendar year. All providers will have until February 29, 2016 to attest.
The bullet points below are the key modifications for the EHR Incentive programs in 2015 through 2017:
Requirements for EHR
Reporting Periods in 2015 Through 2017
Starting in 2015, the EHR reporting period for EPs, eligible hospitals, and CAHs will be based on the calendar year. This allows more time for hospitals and CAHs to implement certified EHR technology, and aligns the EHR Incentive Programs with reporting periods in other CMS quality reporting programs.
In 2015, all providers are required to use technology certified to the 2014 Edition. In 2016 and 2017, providers can choose to use technology certified to the 2014 Edition or the 2015 Edition.
In 2015 only, the EHR reporting period for EPs, eligible hospitals, and CAHs is any continuous 90-day period within the calendar year. EPs may select an EHR reporting period for any continuous 90 days from January 1, 2015 through December 31, 2015. Eligible hospitals and CAHs may select an EHR reporting period of any continuous 90-day period from October 1, 2014 to December 31, 2015. This is intended to accommodate the shift from reporting based on the federal fiscal year to the calendar year for eligible hospitals and CAHs.
Beginning with 2016, the EHR reporting period must be completed within January 1 and December 31 of the calendar year. EPs eligible hospitals, and CAHs that are new participants in the program would have an EHR reporting period of any continuous 90-day period between January 1, 2016 and December 31, 2016. However, for all returning participants, the EHR reporting period would be a full calendar year from January 1, 2016 through December 31, 2016.
In 2017, the EHR reporting period would be one full calendar year for all providers except new participants and/or providers who choose to implement Stage 3, who are allowed a 90-day reporting period.
Alternate Exclusions & Specifications
There are several alternate exclusions and specifications for certain measures that are intended to help providers previously scheduled to be in Stage 1 that may not otherwise be able to meet the criteria in 2015 and 2016 because they require the implementation of certified EHR technology beyond the functions that were required for Stage 1.
These provisions include:
- Allowing providers who were previously scheduled to be in a Stage 1 reporting period for 2015 to use a lower threshold for certain measures. For 2016, all providers previously scheduled to be in Stage 1 may claim an alternate exclusion for the CPOE objective measure 2 (laboratory orders) and measure 3 (radiology orders). For 2016, eligible hospitals and CAHs previously scheduled to be in Stage 1 may claim an alternate exclusion for the eRx objective.
- Allowing providers to exclude modified Stage 2 measures in 2015 for which there is no Stage 1 equivalent.
Modification to Patient Engagement Objectives
There are two objectives for EPs and one objective for eligible hospitals and CAHs with measures requiring a provider to track patient action. These measures have been modified to help providers successfully meet these objectives.
- Stage 2 Patient Electronic Access, Measure 2: For an EHR reporting period in 2015 and 2016, instead of the 5 percent threshold, this measure requires that at least 1 patient seen by the EP during the EHR reporting period, or discharged from the inpatient or emergency department (POS 21 or 23) of an eligible hospital or CAH (or patient-authorized representative), views, downloads or transmits to a third party his or her information during the EHR reporting period.
- Stage 2 EP Secure Electronic Messaging: The 5 percent threshold has been changed to the capability for patients to send and receive a secure electronic message with the EP was fully enabled during the EHR reporting period.
To see the full set of revisions and changes to the Meaningful Use requirements – please click the following link: http://www.cdc.gov/ehrmeaningfuluse/docs/cms_stage_3_mu_overview_2015_2017.pdf