Home > EHR, meaningful use, Medicare > ACR Overview of the CMS Proposed Rule to Modify Meaningful Use in 2015-2017

ACR Overview of the CMS Proposed Rule to Modify Meaningful Use in 2015-2017

On April 15, the Centers for Medicare and Medicaid Services (CMS) formally published its proposed rule to modify the EHR Incentive Program requirements in 2015 through 2017. As with the recent proposals for 2017 and beyond, the latest proposed rule would create a smaller set of Meaningful Use (MU) objectives, revise several (not all) of the problematic requirements, and establish a ninety-day reporting period in calendar year (CY) 2015 for all participants.

Reporting Period Changes
For 2015 only, the reporting period for all participants would be any continuous 90 days in the CY. This change was promised back in January via a CMS staff blog announcement.

As a technicality, CMS’ revisions to the online attestation system would not roll out until January 1, 2016. Thus, first-year participants in 2015 would attest by the end of February 2016 to avoid 2016 payment reductions. These rookies would also have a period of time in which they receive payment reductions. CMS would reprocess and reconcile those reduced Medicare payments when rookies’ 2015 MU attestations are processed.  Veteran participants would be unaffected by this technicality.

MU Objectives for 2015, 2016, and (optional) 2017
The proposed rule would eliminate the concept of “core” and “menu” objectives, instead requiring all participants, regardless of Stage, to complete the Stage 2 MU objectives listed below.

Stage 1 participants in 2015 could use the Stage 1 thresholds through “alternative measures.” These participants would have new exclusions available to them to negate increased thresholds and new requirements taken from Stage 2.

  1. Protect health information/HIPAA
  2. Enable CDS functionality
  3. Meds, labs, and radiology orders captured using CPOE
  4. E-Prescribing
  5. Summary of care creation/transmittal for transitions of care and referrals (modified)
  6. Patient specific educational resources
  7. Medications reconciliation for received transitions of care
  8. View/Download/Transmit (modified to reduce reliance on patient action)
  9. Secure electronic messaging (modified to only require enabling the functionality)
  10. Public health/registries (modified to consolidate the registry-related objectives – choose to actively engage with 2 or 1 registries depending on MU Stage)

As proposed, most diagnostic radiologists would likely need to complete the measures of four total MU objectives: (1) protect health information, (2) CDS, (8) patient view/download/transmit (if exclusion not met), and (10) public health/registries (if exclusions not met).

The “imaging results access” Stage 2 objective is one of the many objectives that would be eliminated by the proposed rule.

Although it is unclear if this was intended by CMS, the proposed language appears to separately define and no longer explicitly include referrals as transitions of care in the “medications reconciliation” objective. On the flip side, referrals would be included alongside transitions of care in the “summary of care” objective for referring providers.

CQM Reporting
The component of MU that requires reporting of clinical quality measures (CQMs) would mostly remain the same. Veteran participants could choose to report CQMs for their 90-day reporting period via attestation in 2015 (as first-year participants do) versus one of the other CQM reporting options.

Significant Hardship Exceptions
CMS does not propose any changes to the hardship exceptions currently in the regulations. Therefore, radiologists would continue to avoid penalties automatically for up to 5 years per individual.

“Hospital-Based” Determination / Eligibility
CMS requested public comment on whether Place of Service Code 22, or other settings, should be used in the hospital-based determination.

Next Steps
Following the close of the sixty-day public comment period, CMS will review the submissions and draft a final rule for promulgation later in 2015. American College of Radiology members who wish to submit feedback for potential inclusion in ACR’s future comments should please contact Michael Peters, ACR Director of Regulatory and Legislative Affairs, at mpeters@acr.org or 202-223-1670.

Categories: EHR, meaningful use, Medicare

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