In addition to being a non-hospital based physician, enrolling, registering and having a certified EHR, you must also be a meaningful user of that EHR to obtain the incentive payment. CMS has decided to split the program into three stages. With each stage, the criteria for being a meaningful user will increase. Below is a table explaining what stage will apply to you based on when you begin participating in the program.

First Payment Year

Payment Year

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

2021

2011

Stage 1

Stage 1

Stage 1

Stage 1 or 2

Stage 2

TBD

TBD

TBD

TBD

TBD

TBD

2012

Stage 1

Stage 1

Stage 1 or 2

Stage 2

TBD

TBD

TBD

TBD

TBD

TBD

2013

Stage 1

Stage 1

Stage 2

Stage 2

TBD

TBD

TBD

TBD

TBD

2014

Stage 1

Stage 1

Stage 2

Stage 2

Stage 3

Stage 3

TBD

TBD

2015

 

 

 

 

Stage 1

Stage 1

Stage 2

Stage 2

Stage 3

Stage 3

TBD

2016

 

 

 

 

 

Stage 1

Stage 1

Stage 2

Stage 2

Stage 3

Stage 3

2017

 

 

 

 

 

 

Stage1

Stage 1

Stage 2

Stage 2

Stage 3

To be a meaningful user in Stage 1, you must successfully fulfill 20 criteria. Of those 20 requirements, 15 are prescribed explicitly in the regulation. For the others, you must choose from five out of 10 available options. Under the Stage 1 rule, reporting clinical quality measures (CQMs) was one of the 20 criteria. Going forward reporting CQMs will still be required but not counted as one of the criteria that are considered “core” or “menu.” One of the major changes CMS and the Office of the National Coordinator of Health Information Technology (ONC) made was to attempt to require that the EHR would be able to calculate the components of the required metrics. The ACC and other organizations urged CMS and ONC to take this step to alleviate the burden on physicians who would have been required to create a separate record-keeping system to calculate the metrics. With the exception of situations where patients seen during the reporting period are not entered into the EHR, the calculation of criteria and measures where attainment requires a determination based on your patient population seen during the reporting period should be done entirely by your EHR.

Core criteria

For each of the core criteria, the regulation spells out an objective and a correlating measure. Because of concerns that not all physicians will be able to meet the criteria as a result of the demands of their particular specialty, CMS has decided to allow physicians to not fulfill certain criteria if they meet requirements for exclusion. Core criteria, including objectives, measures and exclusions are contained here.

Electronic prescribing

One of the core criteria is e-prescribing. Originally, there was a standalone E-Prescribing Incentive Program; however, that program has ended and has been subsumed by the EHR Incentive Program, since it also requires e-prescribing. Physicians who did not comply with the e-prescribing requirements have been the subject of payment penalties for a number of years. Because the E-Prescribing Incentive Program has been subsumed by the EHR Incentive Program, physicians who fail to e-prescribe will no longer be subject to a separate payment penalty. Instead, they will only be subject to the penalty associated with the EHR Incentive Program.

Menu set objectives

CMS received a great deal of feedback from the ACC and others regarding the large number of requirements in the initial proposal. Because of that criticism, the Agency allows participants to choose among some of the measures. The “menu set” of options includes measures that attempt to address data collection for public health purposes. Going forward, CMS intends to generally incorporate the menu set into the core set and create additional criteria for the menu set with the advent of each new stage. As an example, Stage 2 requires that physicians perform all of the actions included in the menu set for Stage 1 with the exception of the measure pertaining to electronic syndromic surveillance. That particular requirement has been retained in the menu set for Stage 2.

Going forward, physicians will not be able to select menu set objectives for which they meet the exclusion criteria unless there are not enough others that they can meet to achieve the required number of objectives.

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