This final rule also set the reporting periods for 2015, 2016, and 2017 as follows:

• 2015 - Any continuous 90-day period
• 2016 -
  • New participants: Any continuous 90-day period
  • Returning participants: Entire calendar year
• 2017 -
  • New participants and participants electing to implement Stage 3: Any continuous 90-day period
  • Returning participants: Entire calendar year

Posted on February 22, 2016

Here are the highlights from the proposed rule for providers:

• In 2015, all providers will use a reporting period of any continuous 90-day period within the 2015 calendar year.
• In 2016, all providers in their first year of participation of meaningful use will use a reporting period of any continuous 90-day period within the calendar year.

Proposed Modifications to Existing Measures

• Patient Electronic Access Objective - Measure 2: Patient views, downloads, or transmits their health information
  • Existing Threshold: 5%
  • Proposed Threshold: Equal to or greater than 1 patient
• Secure Electronic Messaging Using Certified Electronic Health Record Technology
  • Existing Requirement: 5%
  • Proposed Requirement: Yes or No attestation statement that "functionality is fully enabled"
• Consolidate public health reporting objectives into one objective with measure options demonstrating "active engagement" as in the proposed Stage 3 structure.

Remove the Following Objectives for Providers:

• Record Demographics
• Record Vital Signs
• Record Smoking Status
• Structured Lab Results
• Patient List
• Patient Reminders
• Summary of Care
  • Measure 1: Transmission by any method
  • Measure 3: Electronic transmission test
• Electronic Notes
• Imaging Results
• Family Health History
• Clinical Summaries
• Patient Reminders

Removing the differentiation between Core and Menu Objectives and making all objectives as required.

Clinical Quality Measure (CQM) Reporting

• In 2015, the required reporting period in any 90-day period during the calendar year for all providers regardless of their previous meaningful use participation.
• In 2016, a 1-year reporting period for all providers beyond their first year of meaningful use. For providers in their first year of participation, a 90-day reporting period will be required during the calendar year.
• Providers are able to report CQMs through the EHR Registration and Attestation System or any established electronic reporting method in 2015 and 2016.

Posted on April 17, 2015

• Stage 3 objectives are the same as the current Stage 2 objectives with the exception of an additional option for the public health reporting along with clinical data registry reporting. And as with each new stage of meaningful use, requirements for proposed measures have increased.
• Full calendar year reporting, with the exception of Medicaid providers in their first year of demonstrating meaningful use – they will report for any continuous 90 days.
• Prior to 2018, all providers will be required to upgrade to the 2015 Edition of EHR Certified Technology
• Flexibility: Providers may use a combination of 2014 and 2015 Editions prior to 2018 if they have modules from both Editions which meet the requirements for the objectives and measures or if they
  full upgrade during an EHR reporting period.
• New 2015 Edition Capabilities include:
  • Record or create and incorporate family health history
  • Capture patient health information such as advance directives
  • Record numerators and denominators for meaningful use objectives with percentage-based measures and calculate the percentages
  • Calculate and report clinical quality measures
  • Any other capabilities needed to be a Meaningful EHR User
• In 2018, all providers regardless of their prior participation will report on the same definition of meaningful use at Stage 3.
• • Flexibility Year: 2017 will give providers the option to participate in Stage 1, Stage 2 or Stage 3
  • For a provider in Stage 2 in 2016, they will have the option of attesting for Stage 2 or Stage 3
  • For a provider in Stage 1 in 2016, they will have the option of attesting for Stage 1, Stage 2 or Stage 3

  Stage 3 Proposed Objectives Meaningful Use in 2017 and Subsequent Years

  All 8 are required

  1. Protect Patient Health Information
  2. Electronic Prescribing (eRx)
  3. Clinical Decision Support
  4. Computerized Provider Order Entry (CPOE)
  5. Patient Electronic Access to Health Information
  6. Coordination of Care Through Patient Engagement
  7. Health Information Exchange
  8. Public Health and Clinical Data Registry Reporting New Option Added!

  Proposed Clinical Quality Measure (CQM) Requirement for 2017 and Subsequent Years

• Providers may report PQRS to meet CQM requirements as in previous stages.
• Full calendar year reporting period, consistent with Meaningful Use Stage 3 reporting period, and with same exception for Medicaid providers demonstrating meaningful use for the first time in which they would report on any continuous 90 days that is the same as their EHR reporting period.
• Report CQMs either by electronic reporting or attestation
• Attestation reporting is only available in 2017
• All subsequent years will require electronic reporting
• Proposed Payment Adjustments
  • Payment adjustments effective for CY 2015 and subsequent years for providers who are not meaningful EHR users during the relevant EHR reporting period for the year.

  Posted on April 3, 2015
  

Posted February 17, 2015

How would the passing of the Flex-It Act impact providers attesting for meaningful use?

The bill will shorten the meaningful use reporting period in 2015 from 1 year to 90 days. If CMS approves this bill then it would enable eligible providers to use the beginning of the 2015 year to properly prepare to attest for meaningful use and report in the later part of the year.

The passage of the bill also looks to suspend the 1% penalty on Medicare reimbursement in 2015 for eligible providers that did not meet the 2013 based meaningful use requirements.

History of the Flex-IT Act

Flexibility in Health IT (Information Technology) Reporting Act, or Flex-IT Act, was originally introduced in September 2014, but the bill failed to pass before the 114th Congress ended its session. In CMS’ final rule released in September 2014 it declined to offer a 90-day reporting period during any quarter for Stage 2 in 2015. The final rule did however, give providers until 2015 to attest for meaningful use Stage 2 and delay the start date for Stage 3 from January 2016 to January 2017.

The reintroduction of the bill comes on the heels of CMS’ dreary report indicating that only 13% of Stage 2 eligible providers had attested to Stage 2. Of these eligible providers, 60% attested for Stage 2 and 40% attested for Stage 2 under CMS’ flexibility rule. The flexibility rule, announced in August 2014, allowed providers to report on Stage 1 core and menu objectives as a result of not being able to fully implement 2014 Edition Certified EHR Technology (CEHRT) due to delays in 2014 CEHRT availability by their EHR vendors.

The Flex-IT Act emphasizes the need for healthcare providers to have flexibility in meeting CMS’ stiff deadlines. The concern is that the time constraints imposed on providers and hospitals are inflexible and unmanageable which will ultimately result in more providers being unable to attest for meaningful use and increase the number of providers being penalized.

In 2015, more than 257,000 providers are experiencing the 1% penalty on their Medicare reimbursement as a result of failing to demonstrate meaningful use in previous years. This is more than 50% of eligible providers under the meaningful use program. The Flex-IT Act looks to suspend penalties in the incentive program until there are adjustments in the program requirements that are appropriate and realistic for providers to demonstrate.

The Flex-IT Act of 2015 has bi-partisan as well as prominent industry support:

• American Academy of Family Physicians
• American Hospital Association
• American Medical Association
• College of Healthcare Information Management Executives
• Healthcare Information and Management Systems Society
• Medical Group Management Association