The Centers for Medicare and Medicaid Services (CMS) on March 20 released its proposed rule for Stage 3 of the Electronic Health Record (EHR) Incentive Program, also called Meaningful Use (MU) Stage 3. The rule contains the proposed criteria that eligible professionals, eligible hospitals and critical access hospitals would need to meet in order to qualify for EHR incentive payments and avoid penalties for non-participation. CMS’ stated objectives for the proposed rule are to increase simplicity and flexibility in the program while driving interoperability and focusing on patient outcomes in the MU program. CMS also makes it clear in the rule that it intends for its proposal to apply beyond EHRs to other categories of health information technology (IT).

Stage 3 is expected to be the final stage of MU and builds on the groundwork established in Stages 1 and 2. Given the continued effort to improve care and expand health IT functionality, there may be future changes to the objectives and measures of MU which could result in future rulemaking. The rule proposes that providers would have the option in 2017 of either participating in the previously prescribed stage, based on the year they entered the program, or participating in Stage 3, regardless of their first year of program participation. Beginning in 2018, all providers would report at the Stage 3 level regardless of prior participation

Therefore, come Jan. 1, 2018, the rule proposes that all providers would need to begin reporting to the proposed single set of eight Stage 3 MU objectives and their respective measures and do so for a full year. This means CMS is proposing to eliminate the current 90-day EHR reporting period for eligible professionals, eligible hospitals and critical access hospitals demonstrating MU for the first time, thus creating a single reporting period for all providers aligned to the calendar year. This approach would provide better alignment with other CMS quality reporting programs such as Hospital Inpatient Quality Reporting and the Physician Quality Reporting System. A single reporting period based on the calendar year would also allow for a single attestation period, which CMS believes would enable the Health and Human Services systems to better capture data, conduct enhanced stress testing and issue resolution, and improve quality assurance of systems before each deployment. However, this streamlining may hinder those implementing EHRs or demonstrating MU for the first time since they are not provided much of a window to allow for adjustments.

By requiring that all providers meet all eight objectives, the proposal appears to continue to focus on “checking the box” or providing a pass/fail approach to the program rather than changing care delivery to achieve the goal of improved patient care. In order to simplify the number of objectives from 17 or 16 to eight, CMS has proposed removing objectives and measures that the Agency believes are redundant, duplicative or “topped out.” "Topped out" is the term used to describe measures that have achieved widespread adoption at a high rate of performance and no longer represent a basis upon which provider performance may be differentiated. An example of a current Stage 1 objective that would be considered "topped out" is the objective to record demographics. Redundant objectives and measures include those where a viable health IT-based solution may replace paper-based actions, such as the Stage 2 Clinical Summary Objective. Duplicative objectives and measures included those where some aspect is also captured in the course of meeting another objective or measure, such as recording vital signs which is also required as part of the summary of care document.

Read the full summary for more information about clinical quality measurement, payment adjustments and hardship exceptions, proposed objectives and measures, and more.

The ACC is working with its members to develop a response and intends to submit comments by May 29.

Keywords: Centers for Medicare and Medicaid Services, U.S., Demography, Electronic Health Records, Group Practice, Inpatients, Meaningful Use, Medicaid, Medical Informatics, Medicare

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