The Rules Have Changed for Meaningful Use 2015 - 2017

On October 6, 2015 CMS released the long awaited Meaningful Use final rules for 2015 through 2017. It was a busy week at CMS, with new rules flying out the door. Along with releasing the final rules for 2015 through 2017 they also released the Stage 3 (with a comment period) rules and the certification requirements for the 2015 Edition. Now that the rules have been released it’s time to start figuring out what has really changed and understanding the rules to the game.

Top game changing highlights include:

1. The change in the threshold for Stage 2-Patient Electronic Access, measure 2. The final rule has lowered the threshold from 5% to, “at least one patient seen by the EP during the EHR reporting period (or patient authorized representative) views, downloads, or transmits to a third party his or her health information during the EHR reporting period.”
2. The change in the threshold for Stage 2-Secure Electronic Messaging. The final rule has tossed out the threshold and changed it to a yes or no question in the attestation system. This means when an EP attests for 2015 he or she will need to answer yes or no if the “capability for patients to send and receive a secure electronic message with the EP was fully enabled during the EHR reporting period.”
3. The reporting period for all EP’s in 2015 has been changed to any continuous 90-day period within the calendar year. The attestation system will not be open for EPs to attest until January 4, 2016 and the last day an EP will be able to attest is February 29, 2016.

Breakdown of some of those changes for 2015 – 2017:

1. Stages 1 and Stage 2 have been combined and specific alternatives have been incorporated for 2015 only. In an effort to get all providers in alignment and attesting for the same Stage, CMS has combined Stages 1 and 2. Meaning that if an EP is scheduled to be in Stage 1, Year 2 they will now be attesting to the modified Stages where they will have the option to claim exclusions to certain objectives/measures that don’t have an equivalent in Stage 1. For example if an EP was planning to attest for Stage 1, Year 2 and had not planned on selecting the “Patient-Specific Education” as one of their Menu Set items they could claim an exclusion for that objective, for 2015 only. The reason being that the EP was scheduled to demonstrate Stage 1, not Stage 2, and since the rules combined the Stages, CMS has provided alternative exclusions for certain objectives and measures.
2. There are now a total of 10 Objectives and within those objectives there are measures that an EP will need to attest on. Some measures have been removed because they were considered “either topped-out or redundant,” reducing the amount that an EP will need to attest on. Such measures as recording patient demographics, recording patient vitals, or creating electronic notes, and others, have been removed from the final rules for 2015-2017. The 10 final objectives for 2015-2017 are listed here:
   - Protect Patient Health Information
   - Clinical Decision Support
   - Computerized Provider Order Entry
   - Electronic Prescribing
   - Health Information Exchange
   - Patient Specific Education
   - Medication Reconciliation
   - Patient Electronic Access
   - Secure Messaging
   - Public Health ReportingFor more detailed information on the final objectives and measures please visit CMS. They have added a new section to their site that provides helpful tip sheets and this is also where they will be adding additional resources in the coming months that include user guides, objective spec sheets, FAQs, etc. The new section is divided out by year so it easier to find out what needs to be done now and how to start preparing for the future.
3. Along with the final rules, CMS also published updated information on how payment adjustments will be avoided or applied to EP’s. If an EP previously attested in 2014 and successfully attests for 2015, they will avoid the payment adjustment for the calendar year 2017. If this is an EP’s first year of participating in Meaningful Use, and they successfully attest for 2015, they will avoid the payment adjustments for both calendar years 2016 and 2017.
4. Starting in 2017 EP’s will have the option to start attesting for Stage 3 as long as the EHR they are attesting with is certified for the 2015 Edition. EP’s are not required to attest to Stage 3 in 2017; it is only an option. Starting in 2018 all EP’s will be required to attest to the Stage 3 objectives with a certified 2015 Edition EHR.

Watch for more updates and check out resources at www.kareo.com/meaningful-use.