The proposed modifications to the Stage 2 rules of meaningful use as well as the Stage 3 regulations were finalized this week by CMS. The agency also announced a 60-day public comment period about Stage 3 of the EHR Incentive Programs, as it relates to the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which established the Merit-based Incentive Payment System (MIPS).
If you are finding the 752-page rule confusing and overly complex, you are probably not alone. Physicians Practice has you covered. Here are the five most important things for eligible providers (EPs) to glean from the announcement:
1. Ease up, 2015
The rule finalized proposed modifications to the Stage 2 rules of meaningful use that eased up requirements for EPs. This includes instituting a 90-day reporting period for 2015; reducing the view, download, and transmit (VDT) requirements from 5 percent of an EP’s patient panel to one single patient; and reducing secure messaging requirements from 5 percent of an EP’s patient panel to showing they have the capability to do so.
2. Changes from 2015-2017
Aside from changing this year, CMS also removed requirements that were redundant for Stage 2, including recording demographics, structured lab results, and more. Overall, from 2015-2017, EPs are responsible for 10 objectives, including one public health reporting objective. This is down from 18 objectives in previous stages. They also made it so first-time meaningful use participants will have a 90-day reporting requirement in 2016 and 2017.
3. Stage 3 stays the same
From the proposed rule to the finalized version, CMS made some changes to the Stage 3 rule and kept other things in place. It kept the timing on Stage 3, voluntary in 2017 and mandatory in 2018, in place. It also kept its focus on interoperability. Of the eight objectives for EPs, eligible hospitals, and critical access hospitals, more than 60 percent require interoperability.
4. Stage 3 is different
Some of the thresholds for Stage 3, such as the VDT, secure messaging, and patient education requirements, were lowered. The VDT and secure messaging requirements went from 25 percent of an EP’s patient panel to 5 percent. It also lowered the threshold on a requirement that asked EPs to incorporate patient-generated health data into the EHR, from 15 percent to 5 percent. However, the fact that the requirement remains shows that CMS is dedicating itself to this kind of “interoperability.” In other words, you start figuring out how to combine a FitBit and your EHR.
5. That’s not all folks
The biggest takeaway is a lot of this might change. As part of the rule, CMS opened up a 60-day comment period, asking for feedback on Stage 3 of the EHR Incentive Program, as it relates to MACRA. The regulation, signed into law earlier this year, institutes MIPS, which is designed to move reimbursement in healthcare from volume to value. CMS is looking to use this comment period to shape the future of the EHR Incentive Program during rulemaking to implement MACRA, which will occur next year. Meaningful use of EHRs will be a part of reimbursement under MIPS. It’s unclear how the regulations will change to accommodate this new arrangement. As Robert Tennant of the MGMA told Physicians Practice, the meaningful use "program continues to be fluid."
For more on the Stage 2 modifications and the Stage 3 rule, click here.