MU stage 3 is out: 9 things to know

On March 20, CMS released its proposed rule for meaningful use stage 3, which is open for public comment through May 29.

Here are nine things to know about stage 3 of meaningful use.

1. Stage 3 is expected to be the final stage of the Federal EHR Incentive Program, incorporating elements of the two prior stages into its requirements. However, future changes and objectives to meaningful use may be a requirement. According to the rule, "we understand that multiple technological and clinical care standard changes associated with EHR technology may result in the need to consider changes to the objectives and measures of meaningful use under the EHR Incentive Programs. Accordingly, we note that, as circumstances warrant, we would consider addressing such changes in future rulemaking."

2. The rule proposes transitioning the industry to a single stage of meaningful use in 2018, meaning all providers would attest to stage 3 regardless of their current stage. Attestation to stage 3 in 2017 is optional and required in 2018.

"The incorporation of the requirements into one stage for all providers is intended to respond to stakeholder input regarding the complexity of the program, the success of certain measures which are part of the meaningful use program to date and the need to set a long-term sustainable foundation based on a consolidated set of key advanced use objectives for the Medicare and Medicad EHR Incentive Programs," according to the proposed rule.

3. Stage 3 aims to reduce program complexity and simplify reporting requirements by establishing a distinct sets of objectives and measures for eligible professionals, hospitals and critical access hospitals to meet the definition of meaningful use. The new definitions would be optional for providers choosing to attest in 2017 and would become required starting in 2018, again regardless of providers' prior participation in the incentive programs.

4. The stage 3 proposed role would allow all providers to report on a calendar year period starting in calendar year 2017, a move CMS hopes helps align the EHR reporting period with reporting periods for other quality reporting programs, like the Hospital Inpatient Quality Reporting and Physician Quality Reporting System programs.

5. Additionally, the proposed rule seek to eliminate the 90-day EHR reporting period for new Medicare meaningful EHR users for their first year starting in 2017, instead requiring single EHR reporting period of a full calendar year for all providers across all settings. All providers would be required to attest based on a full year of data for a single set of meaningful use objectives and measures. Hospitals can opt to start doing so in 2017, and it would become mandatory in 2018.

6. CMS proposes removing "topped out" measures — measures no longer useful in gauging performance — to reduce the reporting burden on providers for measures already achieving widespread adoption.

7. Eligible professionals, hospitals and critical access hospitals are required to report Clinical Quality Measures to qualify for the federal program, and CMS proposes having them report CQMs through "a single, aligned mechanism for multiple CMS programs." By including CQMs in annual Medicare payment rules (Physician Fee Schedule and IPPS rules), CMS would be able to annually capture changes and updates.

8. The stage 3 proposed rule includes a change in the EHR reporting period year and the payment adjustment year for critical access hospitals. The EHR reporting period would no longer align with the payment adjustment year. The deadline for CAHs would be the last day in February, like it is for eligible professionals. CAHs then have two months to attest to meaningful use to avoid a payment adjustment.

9. While the proposed rule does not estimate total costs and benefits to the healthcare industry, it does indicate an estimated "annual effect on the economy of $100 million or more."

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