D'Arcy Gue

Meaningful Use / MIPS Stage 3: A New War of Words

November 10, 2015

Meaningful Use / MIPS 4 Minute Read

Anyone who has been following healthcare news knows that Meaningful Use / MIPS Stage 2 modifications and final Stage 3 rules were published on October 6. According to CMS, the 752-page final rules were designed to simplify requirements and add flexibilities to help providers make health information available when and where it matters most.

While there has been little industry reaction to the Stage 2 portion of the rules, the Stage 3 details have become  a political hot potato, with loud calls from every direction to eliminate, delay, or follow through on the rule as planned.   Even CMS has entered the fray, by opening up a 60 day comment period on the final Stage 3 rules.

Here’s what the new Meaningful Use / MIPS war of words is all about:

Bear with me as I provide some background context….

The final rule includes modifications to Meaningful Use / MIPS that affect Stage 1 and Stage 2 providers in 2015-2017. These modifications were introduced in the draft rules, which we analyzed in a two-part series here and here. They are essentially unchanged.   The final rule also includes the final rules for Stage 3, under which attesting to Stage 3 will be optional in 2017 but mandatory beginning in 2018. Accordingly, providers may continue to use 2014 Edition Certified EHR Technology to attest to Meaningful Use / MIPS until they are ready to attest to stage 3 in 2018, when they will have to use 2015 Edition technology.

This rule ends the Meaningful Use / MIPS payment adjustment for eligible professionals at the end of calendar year 2018. It also introduces a new program, the Merit-Based Incentive Payment System(MIPS), beginning in 2019, in which requirements to be a Meaningful Use / MIPSr will be included.

The final rule aligns the reporting period for Medicaid and Medicare EHR Incentive Programs with the calendar year. The impact of this is that many providers are currently participating in a 90 day measurement period in the 4th quarter of 2015, and that beginning in 2016, measurement periods will be a full calendar year.

The changes remove objectives and measures from Stages 1 and 2 of Meaningful Use / MIPS that CMS believes were redundant, duplicative or topped out.   The most substantial changes occurred in the following areas:

  • The various public health reporting objectives were consolidated into one objective and were substantially expanded from the previous requirements.
  • The electronic prescribing objective has become a required objective, while the remaining previous “menu” items were eliminated or combined with other measures. CMS is offering an exclusion for hospitals in 2015 and 2016 if they had not planned to attest to this measure, and has indicated elsewhere that they will not require documentation to support the exclusion.
  • Previously acceptable measures that included paper-based workflows or other manual actions have been removed or modified to require an electronic format utilizing EHR functionality for Stage 3.

<a href="https://www.phoenixhealth visit site.com/wp-content/uploads/2015/11/bootcoloredredsrgb.jpg”>bootcoloredredsrgbSo, what’s behind the Stage 3 controversy?

Several industry leaders want to give certain Stage 3 features the boot. The arguments being put forth by the AMA, Dr John Halamka (the deservedly influential MD and Chief Information Officer of the Beth Israel Deaconess Medical Center), and other interest groups basically center around these contentions:

  • It is too early to make Stage 3 rules, as we don’t have results from the implementation of Stage 2.
  • Vendors will be unable to make the needed changes by 2018.
  • Stage 3 isn’t needed at all, because we have achieved the original goals of the program.
  • Some of the standards needed to successfully implement Stage 3 are not yet mature.
  • The impact on providers is far too great.

Regarding the last point, I will provide a full analysis of the changes between the Stage 2 and Stage 3 rules in a future post.   In short, though, of the 18 requirements that providers will have to meet if they take the most conservative approach, one third are essentially unchanged from Stage 2, one third are the same as Stage 2, but at a higher threshold, and one third are new requirements.

Will this Stage 3 final rule be final?

Almost certainly not.   Historically, no Meaningful Use / MIPS final rule has been implemented without some changes. A combination of factors, including vendor readiness, lessons learned from Stage 2, and pressure from provider groups will very likely cause at least some changes from this iteration of the rules.

To keep up with the news on Meaningful Use / MIPS, including potential changes, and to see my upcoming detailed  post on the final Stage 3 rules, be sure to subscribe to our HITpoint blog here.

Related Posts