CMS EHR Incentive Program Modifications to Meaningful Use – 2015 to 2017

For those of you who spend time caring for patients, rather than keeping up to date on every proposed regulation that comes out of CMS, here are the highlights of one that directly affects you. On April 15, CMS published a proposed rule that makes dramatic changes in Stage 2 of Meaningful Use (MU). Essentially, Stage 2 as we knew it, no longer exists. The final rule, when it is published later this year, will define a new Stage 2 that will be in effect from 2015 through 2017, and possibly longer. The bad news is that everyone impacted by MU is in a holding pattern waiting for the final rule. Once it is published, we will all have to scramble to meet the new requirements before the end of 2015. The good news is that the proposed attestation period for 2015 will be any continuous 90-day period for all eligible professionals (EPs), as opposed to the full year. The proposed rule also addresses many of the concerns we have raised about the excessive reporting requirements contained in the old Stage 2 specification. If you were planning to skip the MU program this year due to the excessive burden of Stage 2, you may want to reconsider. While the final rule will have changes based on comments submitted on the proposed rule, we expect that, overall, it will be similar to the proposed rule.

Here are some of the Highlights:

EHR Reporting Period in 2015 and 2016

First, CMS proposes to align the definition of an EHR reporting period with the calendar year for all types of providers beginning in 2015 and continuing through 2016  and beyond. Specifically, beginning in 2015, this proposal would change the EHR reporting period for eligible hospitals (EHs) and critical access hospitals (CAHs) from a period based on the fiscal year to one based on the calendar year, and thus aligning it with the reporting period for individual EPs.

Second, for 2015 and 2016, CMS proposes to allow all new participants in the EHR Incentive Program (including new EPs, EHs, and CAHs) to attest to meaningful use for an EHR reporting period of any continuous 90-day period within the calendar year. In addition, for 2015 only, all EPs (regardless of their prior participation in the program) will be able to attest to an EHR reporting period of any continuous 90-day period within the calendar year.  So, if you have not begun reporting for this year, you still have time! However, starting in 2016, all returning participants will need to use an EHR reporting period of a full calendar year (i.e., from January 1, 2016 through December 31, 2016).

Finally, CMS proposes changes to many of the individual objectives and measures for Stage 2 of meaningful use, including the following:

  • Changing the threshold from the Stage 2 Objective for Patient Electronic Access measure number 2[1]  from “5 percent” to “equal to or greater than 1”. CMS acknowledges that external factors beyond EPs control can impact their ability to meet this measure. Practices have been reporting since the start of Stage 2 that convincing 5% of patients to perform the specified action is difficult or impossible.
  • Changing the threshold of the Stage 2 Objective Secure Electronic Messaging[2]  from being a percentage-based measure, to a yes-no measure stating the “functionality fully enabled”. As with the patient electronic access measure, practices report that convincing 5% of patients to perform the specified action is difficult or impossible.
  • Consolidating the four Stage 2 public health reporting objectives  into one objective with multiple measure options following the structure of the Stage 3 Public Health Reporting Objective. This provides EPs with much more flexibility in selecting public health reporting objectives that make sense for their practices and for which the reporting capabilities exist.

Essentially, Stage 2 has been completely re-worked to respond to complaints raised by many, and to align it with what is expected in Stage 3. Stay tuned for announcements regarding final CMS decisions on Stage 2 modifications and on Stage 3 requirements.

Thomson Kuhn
Senior Systems Architect and Senior Associate
American College of Physicians

This post is the personal opinion of the author and does not necessarily reflect the official policy or position of the American College of Physicians (ACP). ACP does not endorse a specific EHR brand or product and ACP makes no representations, warranties, or assurances as to the accuracy or completeness of the information provided herein.

[1] More than 5% of all unique patients view, download or transmit to a third party their health information.

[2] A secure message was sent using the electronic messaging function of CEHRT by more than 5% of unique patients (or their authorized representatives) seen by the EP.


2 responses to "CMS EHR Incentive Program Modifications to Meaningful Use – 2015 to 2017"
  • October 25, 2015
    Susan Jones

    Our providers and administrators have expressed relief that the 2015 requirements are much more doable now. They were frustrated at being judged on how well they motivated patients to access the portal and view, download or transmit. They now feel they can be evaluated on what they do as opposed to what they can motivate their patients to do.

  • November 5, 2015
    Sarah Heiner

    Unfortunately, the requirement for stage 2 to have an eportal of any kind remains a deal breaker for me. No matter how many patients sign up, it still opens a new avenue for miscommunication and malpractice, and requirement for more staff time and expense to monitor. In primary care, with the volume of calls, worries, etc from patient on innumerable mundane issues, it is still just too much and an “unfunded mandate”

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