The CMS released a Notice of Proposed Rule Making (NPRM) on March 20, which outlines the requirements for Stage 3 Meaningful Use for eligible professionals (EPs), eligible hospitals, and critical access hospitals in the EHR Incentive Programs. The CMS believes that the provisions in the rule will provide more flexibility to EPs by:
- Establishing a single, aligned reporting period for all providers based on the calendar year
- Allowing providers the option to start Stage 3 of meaningful use in either 2017 or 2018 (required in 2018), which gives providers an extra year to begin participation in the program than under current regulation
- Simplifying meaningful use objectives and measures and reporting requirements by allowing flexible measures under health information exchange, consumer engagement, and public health reporting that would fit their own patient population or practice
- Reducing the overall number of objectives to eight to focus on advanced use of EHRs
- Removing measures that are redundant or received wide-spread adoption
- Aligning clinical quality measure reporting with other CMS programs
The reaction from the medical community has been mixed, with some citing their appreciation that the CMS is attempting to align the requirements of the incentive program and provide greater flexibility. However, there continues to be concern that the requirements are too arduous, the timelines are too aggressive, and much of the ability to meet the requirements is based on patient use of their electronic health records. The Endocrine Society will be submitting comments on the NPRM, which is expected to be finalized this fall.
In a separate Proposed Rule released on April 10, the CMS outlined modifications to the Meaningful Use program in 2015 through 2017. This proposed rule would change the EHR Incentive Program reporting period in 2015 to a 90-day period aligned with the calendar year. In addition, this proposed rule would modify the patient action measures in the Stage 2 objectives related to patient engagement by reducing the requirement for patients to use technology to electronically download, view and transmit their medical records from 5% of EPs’ patients to just one patient. Finally, it would streamline the program by removing reporting requirements on measures that have become redundant, duplicative, or topped out through advancements in EHR function and provider performance for Stage 1 and Stage 2 of the program. The proposals are expected to be finalized as soon as this summer.
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