Last night, the Centers for Medicare and Medicaid Services (CMS) issued the long-awaited Final Rule on the EHR Incentive Program. The notification was overdue, as the first day of the final reporting period for 2015 – October 3 – has passed. Indeed, CMS has confirmed that the reporting period is any continuous 90 days in 2015. Justifying its delay in the issuance of the rulemaking, CMS explains that the modifications being delivered accommodate all eligible professionals who have been diligently working towards a successful attestation based on the current program requirements. In addition to releasing the final criteria for the now-named Modified Stage Two, this Final Rule also addresses the future of the program, in the context of the new Merit-based Incentive Payment System (MIPS), as well as Stage Three. Unlike the government, we won’t waste our time mulling over the program’s future, instead turning our attention to what actions you need to take now to avoid the 3% penalty for 2017.
Without further ado, the final 10 Modified Stage Two criteria and measures for Meaningful Use are summarized herein:
- Protection of patients’ health information through a security risk analysis.
- Implementation of 5 clinical decision support interventions, and drug/drug and drug/allergy interaction checks.
- Computerized provider order entry for medications (60%), labs and radiology orders (30% each).
- Electronic prescriptions for 50 percent of all permissible prescriptions, including formulary checks.
- Creation and electronic transmission of summary of care records for more than 10% of transitions of care and referrals.
- Delivery of patient-specific education resources to more than 10% of all unique patients with office visits during the reporting period.
- Performance of medication reconciliation for more than 50% of the incoming transitions of care.
- Provision of timely access to health information for more than 50% of all unique patients seen during the reporting period to view online, download and transmit to a third party; with action confirmed on the basis of having one patient view, download or transmit during the reporting period.
- Confirmation that secure electronic messaging is enabled – i.e., yes/no.
- Reporting – or at least on the path to reporting – to a public health agency or a registry for two measures.
The 10 criteria for the new Modified Stage Two are changing slightly in 2016, with a requirement to report that at least one patient seen during the reporting period sent an electronic message, increased back to the 5% of all patients in 2017. In 2017, the “view, download, transmit” objective also reverts back to the 5% measure. CMS has declared that the 90-day reporting period is only for 2015, with the full calendar year reporting required for 2016.
CMS decided not to issue another set of criteria for Stage One, instead requiring all participants to move to this Modified Stage Two in 2015 – however, Stage One participants are provided extensive exclusions and alternative objectives and measures. Thus, despite the fact that all eligible professionals are required to attest to Modified Stage Two, the specifications for Stage One participants essentially create a separate reporting requirement – one that is much less burdensome.
CMS has yet to update the website for the EHR Incentive Program, but you can read the 752-page Final Rule (which will be on view until its official publication, slated for October 16) – or perhaps just spend a few minutes reviewing CMS’ announcement that accompanied the issuance of the new criteria.
CMS won’t open the attestation portal until the beginning of 2016, but you’ll have until the end of February to report (with CMS already indicating that they may extend that through March). Until then, get in gear for Modified Stage Two in order to gain any remaining bonus payments – and avoid the payment adjustments being imposed in 2017 based on this year’s performance.