CMS Proposed Changes for Meaningful Use in 2015-2017Mark Segal, Vice President, Government and Industry Affairs, GE Healthcare ITMay 1, 2015

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Modifications to Meaningful Use in 2015-2017: Proposed RuleAligns with Stage 3 proposed rule

Removes redundant, duplicative and topped out measures

Modifies patient-focused Stage 2 measures for patient engagement

Single set of objectives & measures (with “stage” adjustments through 2017)

No changes to certified EHR technology required or CQM reporting

Aligns reporting period for all (including hospitals) to full calendar year

Reporting period in 2015 (only) is any continuous 90-day period

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Changes to Stages 1 and 2

Medicare and Medicaid

All on single set of Stage 2 objectives and measures

Some Stage 1 adjustments

Core and Menu eliminated – all objectives required (with exceptions)• Stage 1: three menu items now required – med reconciliation,

patient education, public health (multiple options)

• Stage 2 hospitals: one menu now required (eRx)

Public Health has multiple consolidated measures• EP – 2/5 (1/5 if Stage 1) and Hospital 3/6 (2/6 if Stage 1)

2015-17 Proposed Objectives

1. Protect Electronic Health Information – minor changes per Stage 3

2. Clinical Decision Support – retain with alternate specs.

3. Computerized Provider Order Entry (CPOE) – retain with alternate exclusions/specs.

4. Electronic Prescribing (eRx) - retain with alternate exclusions

5. Summary of Care – retain Measure 2 with alternate exclusion and with no transport specification; delete Measure 1 (any method) and 3 (Test)

6. Patient Specific Education – retain with alternate exclusion

7. Medication Reconciliation -retain with alternate exclusion

8. Patient Electronic Access (V,D,T) – retain measure 1 and revise measure 2 thresholds, with alternate exclusion

9. Secure Electronic Messaging – retain

10. Public Health and Clinical Data Registry (CDR) Reporting– replace with consolidated Stage 3 objective and “active engagement” 5

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Eliminated Stage 2 objective and measures

Source: Federal Register / /Vol. 80, No. 72 /Wednesday, April 15, 2015 / Proposed Rules

2015Attest to modified version of Stage 2

with accommodations for Stage 1 providers

2016 Attest to modified version of Stage 2

2017 Attest to either modified version of Stage 2 or full version of Stage 3

2018 Attest to full version of Stage 3

2015 Modification Proposed Rule: Timeline

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Timetable for revised meaningful use criteria

Source: Federal Register / /Vol. 80, No. 72 /Wednesday, April 15, 2015 / Proposed Rules

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Alternate 2015 exclusions & specifications for Stage 1 providers Maintaining Stage 1 specifications for objectives and measures with lower threshold or other difference between Stages 1 and 2 (e.g., eRx).

Exclusion for Stage 2 measures with no equivalent Stage 1 measure or where provider did not plan to attest to now-required menu objective (e.g., 10% TOC electronic transmission)

Defined for each applicable objective and measure

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Patient engagement changes

V,D,T – from 5% to one (1) patient seen (EP) or discharged (hospital)

Secure Messaging – from 5% to attestation that function enabled

These proposals are controversial and especially subject to revision after comments evaluated

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Public Health changes

“Active engagement” vs. “ongoing submission” - Completed Registration to Submit Data:, Testing and Validation, or Production

Modified consolidated objective & five/six measures per Stage 3 NPRM

• EPs: 2/5 measures (Stage 1 – 1/5) and EH: 3/6 measures (Stage 2 – 2/5)

• Bidirectional exchange required for immunization registries but not included in 2014 edition certification – will be an issue for comment/clarification

• Exclusions and one registry can meet multiple measures

• New measures – Case Reporting (2015 edition cert), Public Health Registry split from “Specialized Registry” and includes Cancer Registry, Clinical Data Registry split from “Specialized Registry”, Electronic Reportable Laboratory Result Reporting (Hospitals only)

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Public Health measures

Source: Federal Register / /Vol. 80, No. 72 /Wednesday, April 15, 2015 / Proposed Rules

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Attestation and payment adjustments

Cannot attest before January 1, 2016

Deadline – February 29 (2015) and February 28 (2016)

Hospitals – any 90 days between 10/1/2014 and 12/31/2015

EPs – any 90 days between 1/1/2015 and 12/31/2015

For 2015, 7/1 (hospital) & 10/1 (EP) Stage 1, Year 1 attestation deadlines to avoid 2015 penalties not feasible; penalties reversed retroactively

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Medicaid

No major changes

Alternate attestation option using CMS portal for Medicaid providers seeking to demonstrate meaningful use to avoid Medicare payment adjustment and who are prohibited from switching between Medicare and Medicaid EHR incentive programs.

Questions?

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