Overview and Analysis of
Proposed Changes to
Meaningful Use in 2015-‐16
A White Paper
Impact Advisors LLC 400 E. Diehl Road Suite 190 Naperville IL 60563
Executive Summary
On April 10, 2015 CMS published the highly anticipated proposed rule on changes to meaningful use in 2015 and 2016. This proposed rule comes on the heels of the recently published proposed rule on Stage 3 (which only pertains to requirements in 2017 and 2018).
The proposed rule from April 10th would make many important changes to meaningful use requirements in 2015 and 2016:
Beginning in 2015, the EHR reporting period for all hospitals and EPs would follow the calendar year.
For 2015 only, all hospitals and EPs would be able to attest to 90 consecutive days of meaningful use, instead of an entire year.
A “revised” version of Stage 2 would be required for all hospitals and EPs in 2015 and 2016; though, providers currently scheduled to demonstrate Stage 1 this year would have a number of exclusions and alternate measures available.Changes to 2015 Reporting Period
Beginning in 2015, the EHR reporting period for all hospitals and EPs would follow the calendar year. (Note that the reporting period for EPs is already based on the calendar year, but for hospitals the reporting period is currently based on the Federal Fiscal Year.)
For 2015, all EPs and hospitals would be able to attest to an EHR reporting period of any consecutive 90 days:
EPs would be able to choose any consecutive 90-day period between January 1, 2015 and December 31, 2015.
Hospitals would be able to choose any consecutive 90-day period between October 1, 2014 and December 31, 2015.The 90-day reporting period – which many providers have been calling for – would only be for 2015. In 2016, a full, 365-day reporting period would again be required (except for first time MU participants, who would continue to be able to attest to any consecutive 90-day period).
“Revised” Stage 2 Objectives and Measures
In the “revised” version of Stage 2, many existing Stage 1 and Stage 2 measures – specifically those CMS believes to be redundant, duplicative or “topped out” – would be removed.
Removed HOSPITAL Objectives /
Measures Removed EP Objectives / Measures
Record Demographics
Record Vital Signs
Record Smoking Status
Structured Lab Results
Patient List
Summary of Care - Measure 1 - Measure 3
eMAR
Advanced Directives
Electronic Notes
Imaging Results
Family Health History
Structured Labs to Ambulatory Providers
Record Demographics
Record Vital Signs
Record Smoking Status
Clinical Summaries
Structured Lab Results
Patient List
Patient Reminders
Summary of Care - Measure 1 - Measure 3
Electronic Notes
Imaging Results
Family Health HistoryOf the existing objectives and measures that CMS would retain in the “revised” version of Stage 2, virtually all would have the exact same scope and threshold that they currently do. There are four important exceptions:
The second measure of the “Patient Electronic Access” objective would only require that “at least 1 patient discharged from the hospital during the EHR reporting period views, downloads or transmits his or her health information to a third party.”
The EP-only “Secure Messaging” measure would only require a yes/no attestation to the statement “the capability for patients to send and receive a secure electronic message was enabled during the EHR reporting period.”
The threshold of the Summary of Care measure requiring a summary of care document to be electronically transmitted at transitions of care would stay at 10%, but the transmission would be able to occur via “any electronic means” rather than only via Direct.Attesting to the “Revised” Version of Stage 2
All hospitals and EPs – regardless of current Stage – would be required to attest to the “revised” version of Stage 2 in 2015... but there would be many exclusions and alternate measures available for providers currently scheduled to demonstrate Stage 1 this year. For example, CMS would allow Stage 1 providers to use a lower threshold for certain Stage 2 measures in 2015. Additionally, there would be exclusions available for “revised” Stage 2 measures that do not have a Stage 1 equivalent. [See the table below for details.] The only exclusion available for providers currently scheduled to be on Stage 2 in 2015 would be for hospitals that had not planned to select the (previously optional) e-prescribing measure this year.
“Revised” Stage 2 Objectives and Measures
[Note: measures in red represent proposed changes from current Stage 2 requirements]
PROPOSED OBJECTIVES AND MEASURES FOR ALL HOSPITALS AND EPs IN 2015, 2016 & 2017
For Providers Scheduled to Be on Stage 1 in 2015 ONLY
Objective Measure(s) Alternate Measure
Available?
Alternate Exclusion Available? 1. Medication orders (more than 60%) Yes -- 2. Lab orders (more than 30%) -- Yes
CPOE
3. Radiology orders (more than 30%) -- Yes
e-Rx
Hospital measure:
Electronic prescribing (more than 10% of
discharge medications) [Note: exclusion available for Stage 2 hospitals in 2015] EP measure:
Electronic prescribing (more than 50% of
prescriptions)
Yes --
1. Implement 5 clinical decision support
rules Yes --
CDS
2. Drug-drug and drug-allergy alerts enabled -- -- 1. Online access to information (more than
50% of unique patients) -- --
Patient Electronic Access (V/D/T)
2. View, Download, Transmit (at least one
patient views, downloads, or transmits his or her health information to a third party)
-- Yes
Protect EHI Conduct or review a security risk analysis -- --
Patient Specific Education
Patient-specific education resources identified
by CEHRT are provided to patients (more than 10% of unique patients)
PROPOSED OBJECTIVES AND MEASURES FOR ALL HOSPITALS AND EPs IN 2015, 2016 & 2017
For Providers Scheduled to Be on Stage 1 in 2015 ONLY
Objective Measure(s) Alternate Measure
Available?
Alternate Exclusion Available?
Med Rec Medication reconciliation performed (more
than 50% of transitions of care) -- Yes Summary of
Care
Create summary of care document using
CEHRT and transmit summary of care document “electronically” (more than 10% of transitions of care; no specific transport standards required)
-- Yes
Secure Messaging [EP only]
EP measure:
During the EHR reporting period, the capability for patients to send and receive a secure
electronic message with the provider was fully
enabled.
-- Yes
Public Health
EPs: 2 of 5 measures must be successfully met* Hospitals: 3 of 6 measures must be successfully met*
1. Immunization Registry Reporting (active engagement with a public health agency) 2. Syndromic Surveillance Reporting (active
engagement with a public health agency) 3. Case Reporting (active engagement with a
public health agency)
4. Public Health Registry Reporting (active engagement with a public health agency)** 5. Clinical Data Registry Reporting (active
engagement to submit data to a clinical data registry)**
6. Electronic Reportable Laboratory Result
Reporting (active engagement with a public
health agency) [Hospital only]
-- --
*In 2015 only: EPs scheduled to be on Stage 1 would only have to successfully meet 1 of 5 public health measures; hospitals scheduled to be on Stage 1 would only have to successfully meet 2 of 6 public health measures.
**Measures #4 and #5 for Public Health Registry Reporting and Clinical Data Registry Reporting may be counted more than once if more than one Public Health Registry or Clinical Data Registry is available.
It is important to note that the proposed exclusions and alternate measures would only be for 2015 – and, except for the inpatient e-prescribing exclusion, would only apply to providers scheduled to be on Stage 1 this year.
requirements under the “revised” version of Stage 2 in 2016. The following chart provides details on the proposed timeline.
Key Takeaways
The proposed change to shorten the length of the 2015 reporting period was expected; the “revised” version of Stage 2 was not. The sheer number of changes CMS is proposing in the 200+ page document caught almost everyone by surprise – especially since many of the changes would apply to the current reporting period. Between the various exclusions, alternate measures, and other modifications, there is A LOT of information for providers to digest, and the reality is this proposed rule is nowhere near as straightforward and simple as most were expecting.
Although the proposed rule is complex, most of the changes in theory should make it easier to achieve meaningful use in 2015. However, 2016 could now be unexpectedly challenging, especially for hospitals that had been planning to defer the e-prescribing measure until Stage 3.
Perhaps the most important item to keep in mind is this is a proposed rule, not an interim final rule. So, there will be a 60-day comment period, and then CMS will publish the final rule (probably in the late summer or fall). Given the changes will apply to the current meaningful use reporting period though, this timetable could very well make planning tricky for providers, since we won’t know for sure which of the proposed changes will actually be finalized until the 2015 reporting period is more than halfway over!About Impact Advisors
Impact Advisors provides high-value strategy and implementation services to help healthcare clients drive clinical and operational performance excellence through the use of technology. We partner with industry-leading organizations to identify and implement improvements in quality, safety and value. Our Associates are experienced professionals with deep domain expertise and a commitment to delivering results.
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