CHA News Article

CMS Issues Final Rules on Stage 3 Meaningful Use, EHR Incentive Program Updates for 2015-17
2015 EHR certification criteria also finalized

The Centers for Medicare & Medicaid Services (CMS) has issued the attached final rule with comment period, modifying the reporting period for the Medicare and Medicaid Electronic Health Records (EHR) Incentive programs in 2015 and defining stage 3 of meaningful use. In the final rule, CMS finalized provisions for two separate proposed rules issued in March. In addition, the Office of the National Coordinator for Health Information Technology released a companion rule that finalizes 2015 certification criteria, standards and implementation specifications for EHR technology.

The finalized modifications to EHR Incentive programs for 2015 through 2017 include moving from fiscal year to calendar year reporting for all providers beginning in 2015 and offering a 90-day reporting period in 2015 for all providers, as well as for new participants in 2016 and 2017, and for any provider moving to Stage 3 in 2017. CMS also reduces the number of objectives for eligible hospitals and critical access hospitals (CAHs) from 20 to nine — including one public health reporting objective — and maintains electronic clinical quality measure (eCQM) reporting as previously finalized.

CHA is disappointed that CMS finalized proposals to begin Stage 3 of meaningful use as optional in 2017 and required for all providers in 2018. Beginning in 2018, a full calendar year of reporting is required for all providers. Other provisions finalized for Stage 3 include eight objectives for eligible professionals, eligible hospitals and CAHs, 60 percent of which require interoperability (up from 33 percent in Stage 2); options for public health reporting; alignment of eCQM reporting with other federal programs; and the use of application program interfaces.

The final rule includes a 60-day comment period where CMS seeks feedback on the future of EHR Incentive programs beyond Stage 3 of meaningful use. Specifically, CMS notes that the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) requires the establishment of the Merit-Based Incentive Payment System and consolidates certain aspects of a number of quality measurement and federal incentive programs into a single, more efficient framework. CMS will use feedback gathered from the final rule’s comment period to inform its rulemaking to implement MACRA, expected in spring of 2016. CHA is currently reviewing the final rules and will provide members with a more detailed summary in the coming weeks. Comments on the final rule will be due 60 days following the rule’s publication in the Federal Register, scheduled for Oct. 16.