Home > EHR, meaningful use, Medicare > ACR Overview of Meaningful Use Stage 3 and 2015 Edition HIT Certification Criteria Proposed Rules

ACR Overview of Meaningful Use Stage 3 and 2015 Edition HIT Certification Criteria Proposed Rules

The Centers for Medicare and Medicaid Services (CMS) and Office of the National Coordinator for HIT (ONC) will publish proposed rules to update the EHR Incentive Program’s meaningful use (MU) requirements and health IT certification requirements on March 30. Pre-publication versions of the proposed rules (CMS / ONC) were made publicly available on March 20. The American College of Radiology Government Relations team reviewed both documents and released a draft summary of the highlights of interest to radiologists on March 23.

The CMS proposed rule would establish Stage 3 MU requirements. In 2017, participants could choose Stage 3 or another Stage. In 2018 and every year thereafter, Stage 3 would be the only option. The eight total Stage 3 MU objectives would be: (1) Protect Patient Health Information, (2) eRx, (3) CDS, (4) CPOE, (5) Patient Electronic Access to Health Information, (6) Coordination of Care Through Patient Engagement, (7) Health Information Exchange (HIE), and (8) Public Health and Clinical Data Registry Reporting. Of these proposed objectives, most diagnostic radiologists would likely need to do four— (1), (3), (7), and (8)—because of proposed exclusions from measures that go with the other objectives.

While CMS proposes to continue the (original) hardship exceptions that protect radiologists and others from MU penalties for up to 5 total years per individual, the start date for MU compliance would be moved up to January 1, 2018 for physicians who used up all of their hardship exceptions in 2015 through 2019. The reason: CMS proposes to eliminate the 90-day reporting period for rookie MU participants. Thus, beginning in 2017, all MU participants would have yearlong reporting periods, and all participants would avoid penalties via MU compliance 2 years before the penalty year in question (e.g., 2018 compliance to avoid 2020 penalties).

CMS proposes that the clinical quality measure (CQM) reporting requirement of MU would be updated via future Medicare payment rules (beginning with 2016 Physician Fee Schedule for 2017 MU). The goal is to further align CQM reporting across the CMS quality incentive programs, such as PQRS, which are currently updated through the annual payment rulemakings instead of via standalone rulemakings.


Proposed S3 MU for most diagnostic radiologists in 2018+ (optional in 2017):

1. Four Stage 3 MU objectives (non-excludable by most radiologists):

  • Protect patient info (HIPAA)
  • Enable CDS functionality
  • Request Summary of Care Records/C-CDAs from referring providers and incorporate/reconcile info of interest
  • Actively engage with 3 registries

2. CQM reporting requirements (TBD in 2016 payment rules)

3. CEHRT equipped at location(s) where >50% patient encounters


Note that CMS is planning a separate rulemaking to address flexibility in the current Stage 1 and Stage 2 MU requirements for 2015-2017. That proposed rule should be published around Spring/Summer if all goes to plan.

Unlike the various regulatory framework changes in the CMS proposed rule, the ONC’s proposals for the health IT certification program would not be substantially different from a radiologist end-user’s perspective. There would be the requisite updates in the form of the 2015 Edition Health IT (no longer “EHR”) certification criteria (mandatory in 2018), new and revised standards and implementation guides, changes to the privacy/security scheme, new post-certification surveillance and transparency requirements, removal of “Complete EHR” certification status, and a slightly updated Base EHR definition. Additionally, the responsibility for defining “certified EHR technology” (CEHRT) for MU purposes would shift from ONC to CMS as ONC expands its HIT certification program beyond MU exclusivity. Most of these proposals were expected based on discussions included in an earlier ONC rulemaking.

In terms of ONC’s imaging-specific 2015E certification criteria, the “image results” and “CPOE-diagnostic imaging” certification criteria would be unchanged from the previous 2014 Edition/2014 Edition Release 2 versions (the CMS proposed rule provides clarification about “diagnostic imaging” would mean in the context of CPOE [i.e., all modalities], but it would not significantly alter the previous understanding of that requirement). The “view online, download, and transmit to a 3rd party” certification requirements which support patients’ electronic access to their data via portals, PHRs, and 3rd party applications would include “Diagnostic Image Reports”—thus, HIT modules certified for the V/D/T criterion would need to be technically capable of sharing these reports with patients.

For more information, please see ACR’s draft summary (subject to change).

If ACR members have additional questions, or would like to offer feedback for potential inclusion in ACR’s future comments on either of the proposed rules, please contact Michael Peters, Director of Regulatory and Legislative Affairs, ACR Government Relations, at mpeters@acr.org / 202-223-1670.

Categories: EHR, meaningful use, Medicare

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