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Meaningful Use Update: Revised 2016/2017 Reporting Period and Other Updates

on Thursday, 8 December 2016 in Health Law Alert: Erin E. Busch, Editor

Last month, the Centers for Medicare and Medicaid Services (CMS) released a final rule with comment period regarding changes to the Medicare and Medicaid Electronic Health Record Incentive Programs (Meaningful Use). The changes come as many providers continue to face administrative burdens related to Meaningful Use software implementation and other issues as such as preparation for the Merit-Based Incentive Payment System (MIPS) quality payment program. The final rule includes a revised reporting period for Meaningful Use participants and various changes to the objectives and measures beginning in Program Year 2017.

Reporting Period for 2016 and 2017.

The final rule revised the Meaningful Use reporting period for 2016 and 2017 from one (1) calendar year to any continuous 90-day period in the calendar year. The revised reporting period applies to returning Eligible Professionals, Eligible Hospitals, and Critical Access Hospitals.

Revised Objectives and Measures.

The final rule also includes revisions to the Modified Stage 2 and Stage 3 objectives and measures, including removal of the Clinical Decision Support (CDS) and Computerized Provider Order Entry (CPOE) objectives and measures and lower reporting thresholds for a subset of the remaining objectives. These changes apply to Eligible Hospitals and Critical Access Hospitals, including Eligible Hospitals and Critical Access Hospitals that are eligible to participate in both the Medicare and Medicaid Meaningful Use programs.

The final rule eliminates the CPOE objective for Modified Stage 2 and Stage 3. CMS acknowledged that many providers have achieved widespread adoption of CPOE – and encouraged providers to continue to use CPOE. In addition, CPOE will remain a requirement for Certified Electronic Health Record Technology (CEHRT) certification purposes.

CMS also lowered the threshold for the patient electronic access (VDT) measure in Modified Stage 2 for 2017. The requirement for 2017 is that one patient views, downloads, or transmits his or her health information. For Stage 3 (2017 and 2018) CMS modified the thresholds for patient electronic access, patient engagement, health information exchange, and public health and clinical data registry reporting.

CMS will impose payment adjustments for those providers who do not achieve Meaningful Use. Therefore, it is important for providers to be familiar with the modified rules as they implement technology features and internal processes to comply with the Meaningful Use rules.

Michael W. Chase

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