On October 6, 2015, the Centers for Medicare and Medicaid Services (CMS) published a final rule for Stage 3 of the Electronic Health Record (EHR) Incentive Program. In the final rule, CMS specifies the criteria for eligible professionals (EPs) and eligible hospitals to qualify for Medicare and Medicaid EHR incentive program payments and to avoid the downward payment adjustments beginning in calendar or fiscal year 2015 for certain providers.
As discussed in the proposed rule, the CMS Stage 3 final rule establishes a single set of objectives and measures tailored to EPs or eligible hospitals for demonstration of meaningful use of certified EHR technology. In a fact sheet, CMS said that the final rule significantly changes the current requirements by easing the reporting burden for providers, supporting interoperability, and improving patient outcomes. Notably, CMS removed reporting requirements on measures that have become “redundant, duplicative, or topped out through advancements in EHR function and provider performance” for Stages 1 and 2 of the EHR Incentive Program. Modified versions of Stage 1 and 2 objectives will be applicable to providers in 2015 through 2017, while Stage 3 objectives will be mandatory beginning in 2018.
The final rule features 10 objectives for EPs in 2015 through 2017, down from 18 total objectives. Eligible hospitals will be required to meet 9 objectives, down from 20. Stage 3 criteria, optional for 2017 and mandatory in subsequent years, require the satisfaction of 8 objectives for EPS and eligible hospitals.
The final rule also synchronized reporting under the EHR Incentive Program to end the separate stages of meaningful use, intended to transition EPs to the Merit-based Incentive Payment System established under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). CMS also revised the EHR reporting period to coincide with the calendar year rather than the fiscal year. CMS finalized its proposal to implement optional 90-day reporting for providers demonstrating Stage 3 meaningful use in 2017, with full calendar year reporting for providers beginning in 2018.
Simultaneous with the issuance of the CMS Stage 3 final rule, the HHS Office of the National Coordinator for Health Information Technology (ONC) issued a final rule regarding EHR certification criteria for 2015. The Stage 3 meaningful use and EHR certification criteria final rules are each scheduled to be published in the October 16, 2015 Federal Register.
A 60-day public comment period, available through December 15, 2015, will allow additional feedback about the EHR Incentive Programs going forward. CMS expressed its particular interest in receiving comments regarding implementation of meaningful use requirements in conjunction with the MACRA Merit-based Incentive Payment System.