May 7, 2015
Many have been calling for more information on CMS’ proposed rules on Meaningful Use / MIPS Stage 3, and Modifications to Meaningful Use / MIPS in 2015 through 2017, along with details of the comment process. I made a point on Tuesday, May 05, 2015, to call in and hang on every word of CMS’ teleconference “CMS EHR Incentive Programs Proposed Rules Overview.” I’m glad I did. If you missed it, here’s my summary.
CMS began the session by describing the rulemaking process and encouraging providers to submit comments for the current notices of proposed rulemaking. Comments for the proposed Meaningful Use / MIPS Rules Stage 3 rule are due by May 29th, and for the Modifications rule by June 15th. Comments must be made for the rules separately, and should not be combined into a single set of comments. Heed my advice…comments ARE listened to. Consider offering yours.
Next, CMS described the logic behind the development of the Stage 3 rule. The key goals for the Stage 3 rulemaking process are to:
• Simplify the MU program reporting.
• Set a stable regulatory platform for sustainability going forward after the end of the active MU program process. This requires retain flexibility for ongoing standards development as the technology matures, without stifling innovation.
• Advance the use of health IT, support exchange of health information, and improve outcomes.
CMS also reviewed the objectives of the Stage 3 Rule, but did not have enough time to review the slides in the presentation about the individual measures. But you can, if you follow the link I have provided at the end of this post.
Finally, CMS described the modifications to the current MU rules for 2015 to 2017. These modifications are intended to:
• Align current program rules with the Stage 3 draft rule and its goals.
• Reduce reporting burdens on providers. This includes changing the MU program year to match the calendar year for hospitals (instead of the current fiscal year).
• Move providers at any stage to the same set of objectives and measures.
These modifications include significant changes to the timeline and stage that providers will choose to attest. Based on the proposed rule, calendar year reporting period for provider attestation will be:
2015: 90 days Modified Stage 2 objectives with accommodations for Stage 1 providers
2016: 1 year Modified Stage 2 objectives
2017: 1 year Modified Stage 2 objectives OR the Stage 3 objectives
2018 and beyond: 1 year Stage 3 objectives
The slide deck used in the teleconference will be available at the CMS eHealth events page shortly.
The impact of these proposed rules on your facility, IT strategy, and clinical operations is significant and should not be minimized. Several hospitals I’ve worked with have changed direction on key objectives based on the direction of the proposed rules; their current strategy would not produce results that were proposed in the stage 3 rule. You should consider whether you should make similar adjustments in your organization.
Stay tuned for my summary of two more upcoming CMS teleconferences.
If you’d like to discuss these impacts or augment your internal efforts, contact us…