As we discussed in our previous post,  the CMS folks have been burning a lot of midnight oil this spring. The Proposed Rule for Modifications to Meaningful Use / MIPS in 2015 through 2017  contains many dramatic changes. This NPRM is well worth studying, as most of the changes will benefit over-worked providers in their efforts to qualify for Meaningful Use / MIPS incentive money. In this post, we focus on the changes that impact the specific objectives and measures that are used to qualify providers as Meaningful Use / MIPSrs.

The changes offered in the Modification NPRM are intended to align the current MU goals with the Stage 3 NPRM, and to reduce the reporting burden on providers. Those objectives, which are aligned with those for Stage 2 are discussed in more detail in my previous post about the Stage 3 rule.  As a result of that alignment, the Stage 2 objectives are:

• Protect electronic protected health information (ePHI)
• ePrescribing
• Clinical decision support (CDS) interventions
• Computerized provider order entry (CPOE)
• Patient electronic access to health information
• Coordination of care through patient engagement
• Health Information Exchange
• Public health and cinical data registry reporting

Measures Eliminated:

Key to reducing the burden on providers, CMS is eliminating 12 measures from the original Stage 2 requirements. These measures were considered redundant with other measures, duplicated between paper and electronic functions, or already achieving the highest scores (topped out).

The measures that would be eliminated by the Modification NPRM, if finalized as is, are:

• Demographics
• Vital Signs
• Smoking Status
• Incorporate Lab results
• eMAR
• Transition of Care any means (50%)
• Generate Patient List
• Record Advance Directives
• Imaging Results
• Ambulatory Lab Results
• Family History
• eNotes

Measures Changed:

The Modification NPRM makes meaningful changes and clarifications to 5 measures.   These changes should generally ease the burden of providers, and were carefully selected to not require technical changes by systems vendors in order to measure and attest. There are no increased burdens in the requirements for the provider except for ePrescribing, which becomes mandatory. The proposed changes:

• View/Download/Transmit patient use (5%): The threshold for this measure would be lowered to one patient.   It is unclear what, if anything, this measurement reduction implies for the Stage 3 measure, which would increase the standard to 25%.
• Transition of Care electronic: A change in definition is proposed, stating that a provider would be required to create the summary of care record using CEHRT and transmit the summary of care record electronically. This appears to remove the requirement that the transition document actually be received by a provider, making submission to an exchange valid for Meaningful Use / MIPS.   We anticipate clarifying comments in the final rule.
• Public Health: The public health measures are changed to include the other registry types in the Stage 3 NPRM.   An increase in options for meeting this measure, which also includes the previous measures of reportable labs, syndromic surveillance, and immunization, will benefit the provider by providing more options.
• Clinical Quality Measures. The NPRM indicates that attestation to collecting these measures would continue to be a valid method through 2017, with submission through electronic means required beginning in 2018.
• ePrescribing would become mandatory, with an exclusion available for 2015 for those providers who did not intend to attest to this.

Finally,  6 Measures with Insignificant Changes:

• CPOE
• Clinical Decision Support
• Protect PHI
• Patient Education
• Medication Reconciliation
• View/Download/Transmit availability (50%)

In general, CMS’ proposed changes will greatly simplify the requirements for most providers, and should be welcomed.  A number of influential healthcare groups, including HIMSS, the Medical Group Management Association, and the American Hospital Association have already spoken out in favor of the changes.

Contact us! We devote much effort into deciphering, communicating and providing on-the-ground support to hospital providers moving forward in Meaningful Use / MIPS. It’s complex. We make it simple.