Just as physicians were considering abandoning Meaningful Use and surrendering to future Medicare penalties, CMS issued a proposed rule for 2015 that breathes new life into the program. If full-year reporting was perceived as the insurmountable obstacle, the proposed reduction to a 90-day reporting period should recapture interest.
Although a proposed rule is not final until it is codified as a final rule—not anticipated until August—past experience has demonstrated that the major structural features typically survive as proposed. The shortened reporting period was announced as CMS’ intention in January and formally proposed last Friday. I think it is fair to say that one can be reasonably confident in this particular provision of the rule.
As for the other features of this proposed rule: In a former EMR Straight Talk post, I wrote, “Even more intriguing to me than the change in reporting period is . . . the intention to “modify other aspects of the program to match long-term goals, reduce complexity, and lessen providers’ reporting burdens.” CMS has come through in this regard and proposed changes for 2015 through 2017. The revisions encourage a focus on the advanced use of EHR technology to support health information exchange, consumer/patient engagement, public health reporting, and quality improvement. This is the narrowed focus that stakeholders, (including SRS on behalf of physicians), have been demanding since the program’s inception.
The following are some other highlights of the proposed rule for 2015 through 2017:
- Reporting would be streamlined: Many Stage 2 measures would not be individually reportable, particularly the paper-based or box-checking measures. Caveat: this does not, however, mean that the data would no longer be required–the information would still be necessary for the patient portal, for the summaries exchanged between providers, and for CQM reporting.
- Patient engagement measures would be dramatically revamped:
- The threshold for “VDT”, (View, Download, or Transmit), would be reduced from 5% to “one patient.”
- Secure messaging would have to “be enabled,” but there would be no threshold to meet.
- To simplify the overall MU structure for practices that have physicians in different stages, all physicians would report on the same measures—a modified set of Stage 2 requirements. Stage 1 providers, however, would be able to exclude measures which go beyond the requirements they were expecting to report.
If you want to ensure that the above changes are included in the final rule, submit a comment to CMS by June 15. CMS receives plenty of comments opposed to particular components of its rules, but specifically asks for positive comments on the features that stakeholders do support.