The proposed rule for meaningful use Stage 3 was announced on Friday, March 20, 2015, and is now available for comment by stakeholders. Here are five highlights of the Stage 3 proposed rule and what I see as three provider wins:
Highlights
2017 is now a Flex Year– Meaningful use Stage 3 was originally slated to begin in 2017 for providers that had completed Stage 2; now 2017 is a flex year. This means that providers who would have progressed from Stage 2 to Stage 3 in 2017 now have the option to stay in Stage 2 an additional year. Only providers who use an EHR certified to the 2015 ONC standards will be allowed to attest to Stage 3.
Every provider will be Meaningful Use Stage 3 in 2018 even if 2018 is the provider’s first reporting year – In order to simplify the meaningful use program, all providers will be in the same stage. This will allow group practices to focus on a single set of measures for all providers.
Meaningful Use Stage 3 is the final stage of meaningful use– However, CMS is clear that because it expects technology and care standards to evolve over time it will consider (and we expect) that there will be future rulemaking related to meaningful use Stage 3 somewhere down the line.
All providers will report for one calendar year – in an effort to continue to align meaningful use with other government reporting programs such as PQRS, all providers will report for a full year based on the calendar with one exception. Medicaid first year providers will still be allowed to report based on a 90-day period measurement period. In the past CMS has shortened measurement periods based on provider feedback and we expect that to be true about this year. This year (2015) was slated to be a full year for most providers, but we expect it to be scaled back to a quarterly measurement period because of the continued side effects of the poor implementation of Stage 2 last year. For 2017 and beyond, we expect the implementation will be smoother and we don’t foresee more flexibility on measurement periods beginning next year.
There are eight objectives and some objectives have more than one measure – the total number of measures that providers will be required to report is 16.
Wins for Providers in the Meaningful Use Stage 2 Proposed Rule
I see three wins for providers in the meaningful use Stage 3 Rule, including:
Guest post by Dr. Seth Flam, board certified in Family Practice and co-founder and CEO of HealthFusion.
CMS has some good re-imbursement news for primary care physicians for 2015: It has announced a new chronic care management program starting January 1 that will allow providers to bill for providing care management for patients with chronic conditions.
In other words, primary care providers can get paid for care they likely already provide.
With this new program, chronic care management can provide a good source of revenue for a practice, if designed, managed and billed correctly. Since a provider can bill $42.60 per patient per month, with a reasonable number of patients with chronic conditions in the practice, a provider can easily see revenue of more than $50,000 per year.
Annually: $511.20 per year per patient X 100 patients = $51,120 per year
(Assumes the provider bills for each patient 12 months out of the year)
But—there are very specific things providers need to know about the program, and particular requirements they need to follow in order to get paid. Here is a preview of some of the requirements:
Identify chronic care patients who qualify.
Eligible patients include those with two or more chronic conditions expected to last at least 12 months, or until death, that place the individual at significant risk of death, acute exacerbation/decompensation, or functional decline.
Only one provider can bill for the chronic care management code for a patient in a 30-day period.
The billing provider must have a signed agreement with the patient allowing them to bill for these services and detailing cancellation rights, co-payments and types of services.
Among other things, the provider needs to supply 20 minutes or more of chronic care management services per patient per 30 day billing period.
The provider will need to create a patient-centered care plan document compatible with the patient’s choices and values.
The provider must provide either a written or electronic copy of the care plan to the patient.
The provider will need to manage care transitions between and among health care providers and settings.
Bill in accordance with CMS requirements using CPT code 99490, making sure the practice’s EHR software provides the information needed to manage and bill for this program.
Begin the process of establishing practice processes and gathering patient agreements soon, although the program doesn’t go into effect until 2015.
