Guest post by Dr. Seth Flam, CEO, HealthFusion.
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:
- 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: