MU stage 3, modification rules finalized: 12 things to know

On Tuesday, CMS released the final rules for the Medicaid and Medicare EHR Incentive Programs and for the 2015 Edition Health IT Certification Criteria. The rules for the meaningful use program include a 60 day comment period, while the 2015 Edition rules are final.

Here are 12 things to know about the final rules.

Meaningful use
1. The final rule published in the Federal Register combines the proposals previously made for meaningful use's 2015-2017 modification period and stage 3 of the EHR incentive program into one rule. The rule finalizes requirements for the meaningful use program for 2015 through 2017 and for 2018 and beyond.

2. Much of the realigning and rulemaking is centered on recent changes to the Medicare Access and CHIP Reauthorization Act of 2015, which was enacted April 16. Part of this act ended the meaningful use payment adjustment for eligible professionals at the end of calendar year 2018, and another section of the act required the establishment of a Merit-Based Incentive Payment System, which would incorporate meaningful use. The newly released MU final rules, then, seek to align reporting under MU to better prepare Medicare-eligible professionals for their transition to the Merit-Based Incentive Payment System.

“The enactment of MACRA has altered the EHR Incentive Programs such that the existing Medicare payment adjustment for EPs…will end in CY 2018 and be incorporated under MIPS beginning in CY 2019. It is our intent to issue a notice of proposed rulemaking for MIPS by mid-2016. This final rule with comment period synchronizes reporting under the EHR Incentive Programs to end the separate stages of meaningful use, which we believe will prepare Medicare EPs for the transition to MIPS,” according to the final rule.

3. The final rule aligns the reporting period for Medicaid and Medicare EHR Incentive Programs with the calendar year, a provision that was included in the proposed rules. Additionally, the final rule adopts a 90-day reporting period for all providers in 2015 and for new participants in 2016 and 2017. Providers beginning their attestations in 2018 will report on a full calendar year, with the exception of a handful of Medicaid providers. 

4. Attesting to stage 3 will be optional in 2017 and will become mandatory in 2018, as initially proposed. CMS is allowing an optional 90-day reporting period for providers selecting to demonstrate stage 3 reporting requirements in 2017. 

5. The proposed rules sought to remove certain objectives and measures from stages 1 and 2 of meaningful use that were redundant, duplicative or topped out. The final rule finalizes these proposed changes for stage 3 and changes certain objectives and measures for stage 2, but not limited to, the following:

  • All public health reporting objectives will be consolidated into one objective and will more closely resemble MU3's public health reporting objective
  • The eligible hospital electronic prescribing objective will become a required objective that offers an exclusion for eligible hospitals and critical access hospitals in 2015 and 2016

6. Providers may continue to use 2014 Edition Certified EHR Technology to attest to meaningful use until 2018, when they will have to use 2015 Edition technology. 

7. Stage 3 is intended to be the final stage of MU. Building off the rules from stage 1 and stage 2, certain manual measures will no longer be accepted. Stage 3, according to the rule, “leverages the structure identified in the stage 1 and stage 2 final rules…Measures in the stage 1 and stage 2 final rules that included paper-based workflows, chart abstraction or other manual actions have been removed or transitioned to an electronic format utilizing EHR functionality for stage 3.”

8. CMS expects the provisions of the final rule will have an annual effect of $100 million or more on the economy. The agency expects to spend approximately $14.2 billion on transfer payments to Medicare and Medicaid providers between 2015 and 2017.

2015 Edition Health IT Certification Criteria
9. The latest criteria for 2015 CEHRT is intended to facilitate greater interoperability between health information systems and enable health information exchanges through new certification criteria, standards and implementation specifications.

10. The 2015 Edition EHR definitions differ from the 2014 in the following ways (note: this is not an exhaustive list): 

  • It does not include privacy and security capabilities and certification criteria
  • It only includes capabilities to record and export clinical quality measure data
  • It includes smoking status, sexual orientation and gender identity as demographic criteria
  • It requires an "application access" certification — API — to support electronic data exchange

11. Part of the goals for the new edition is to allow 2015 CEHRT to reside outside of meaningful use, which has been the case. "This is…consistent with our approach in this final rule to make the ONC Health IT Certification Program more open and accessible to other types of health IT beyond EHR technology and for health IT that supports care and practice settings beyond those included in the EHR Incentive Programs," according to the final rule. 

12. ONC estimates the final rule may have an economic effect greater than $100 million in at least one year.

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