Final Meaningful Use Requirements for 2015

 In Articles, Meaningful Use, Policy Updates, Provider Notes

At long last, CMS has issued its final rule on Meaningful Use (MU) for the 2015 reporting period. There were just a few minor modifications to the proposals published in April, with the result that 2015 requirements are significantly reduced for all providers. Here’s what you need to know:

  • The 2015 reporting period has been reduced to any consecutive 90 days during calendar year 2015. While October 3-December 31 is the last possible reporting period, you can choose any previous 90-day period within the calendar year as your reporting period. Security Risk Assessments must be completed by December 31. All providers will complete the MU attestation between January 1 and February 29, 2016. In 2016, the reporting period returns to a full 12-month calendar year for all providers except first-time participants.
  • All providers will attest to the same set of 10 measures, now being called “Modified Stage 2.” Many MU measures have been eliminated, but those that remain are mandatory for all providers (no more Core vs. Menu measures). Some thresholds have been reduced, and there are exclusions for providers who would have attested to Stage 1 requirements. See table 1 for a list of the final Modified Stage 2 measures.
  • For 2015, there are no changes to the Clinical Quality Measures (CQMs). All providers are still required to report nine CQMs covering three domains. There are three options for reporting 2015 CQMs: 1) Report on attestation website for any consecutive 90-day period during CY 2015, 2) Report electronically for any consecutive 90-day period during CY 2015, or 3) Report electronically for the full calendar year 2015. If you are trying to meet both MU and PQRS with a single reporting of CQMs, you must use option 3. Electronic reporting is accomplished either directly from your EHR vendor to CMS or by uploading a QRDA file to the CMS PQRS Portal.
  • In the final rule, CMS provides insights into scenarios appropriate for a hardship exemption application. These include switching EHRs mid-year, having an EHR that is decertified, and technology upgrades. All hardship applications are reviewed on a case-by-case basis and are due by July 1 of the year preceding the scheduled payment adjustment. A provider whose application is approved would avoid the payment adjustment but would not receive the incentive payment for that year.
  • The definition of “Hospital-Based Provider” – over 90% of encounters in the previous year were in POS 21-Inpatient or 23-Emergency Room – was not changed in the final rule. CMS had requested comments on adding POS 22 – Hospital Outpatient to the definition, but after review of a large number of comments on both sides of the issue, they declined to make any change.

The final rule is scheduled for publication in the Federal Register on 10/16/2015, but can be downloaded here prior to publication. In addition to finalizing the MU requirements for 2015, this 752-page document also finalizes requirements for MU Stage 3, which all providers will be required to meet in 2018. It also includes a request for additional comments regarding the MIPS program that will combine and replace MU, PQRS and the Value Based Modifier programs starting with reporting year 2017 (payment year 2019). Watch for details on what to expect beyond 2015 in future MSOC Health newsletters.

MSOC Health can help you sort through the complexities of Meaningful Use and other Quality Programs including PQRS, Value-Based Modifiers, NCQA recognition programs (PCMH and PCSP) and commercial payer initiatives. Contact Jeanne Chamberlin at 919-442-2422 or j.chamberlin@msochealth.com.

Table 1
Final Modified Stage 2 Measures
All Providers; Any 90-day Reporting Period during CY 2015

Measure Description Comment
Security Risk Assessment Conduct or review Security Risk Assessment of eHPI contained in Certified EHR;  correct deficiencies as part of risk management process Instead of covering all electronic PHI, content changed to just data in EHR, but still have to meet HIPAA regulations
Clinical Decision Support 1: 5 CDS rules turned on
2: Drug-Drug/Drug-Allergy checks enabled
Same as Original Stage 2; Stage 1 providers can have just 1 CDS rule
Order Entry (CPOE) Orders entered into EHR:  > 60% medications, > 30% lab orders, >30% radiology orders Same as Original Stage 2; Stage 1 providers can have exclusion on lab & radiology orders and 30% threshold for medications
Eprescribing Over 50% of permissible prescriptions are eprescribed Same as Original MU Stage 2; Stage 1 providers have 40% threshold
Health Info Exchange (Summary of Care) For >10% of referrals/transitions of care, Certified EHR is used to create a Summary of Care and it is ELECTRONICALLY transmitted to a receiving provider Same as Part 2 of the 3-part Summary of Care Measure in Original Stage 2; Stage 1 providers can claim exclusion from measure
Patient-Specific Health Education Over 10% of unique patients with office visits are provided patient-specific health education materials Same as Original Stage 2; Stage 1 providers can claim exclusion from measure
Medication Reconciliation Medication reconciliation is performed on > 50% of transitions of care when patient is transitioned into provider’s care Same as Original Stage 2; Stage 1 providers can claim exclusion from measure
Patient Electronic Access (VDT) 1. Over 50% of patients seen have access to electronic health information
2. At least 1 patient seen has viewed, downloaded, transmitted their electronic health information
1. Same as Original Stage 1 &2
2. REDUCED from 5%; in 2017 threshold returns to 5%. Stage 1 Providers can claim exclusion from Part 2 for 2015
Secure Messaging Functionality enabled REDUCED from 5% of patients sending a secure message; for 2016, threshold is 1 patient and 5% in 2017. Stage 1 providers can claim an exclusion
Public Health
(**more info below**)
Attest to ‘Active Engagement’ with at least 2 Public Health or Specialized Registries Combines several Core and Menu measures from Stage 2; Stage 1 providers must attest to at least 1 registry.

Definitions and exclusions for each measure remains the same as Original MU Stage 2 unless noted above with exception of Public Health Measure discussed below.

Public Health Measure:

  • “Active Engagement” is defined as ongoing reporting, being in the process of testing data feeds, or, at a minimum, being registered to participate with the registry by 60 days from the start of your reporting period.
  • The final rule lists three categories of registries – Immunization, Syndromic Surveillance, and “Specialized”. Specialized registries include those sponsored by a public health agency (including the state’s cancer registry) or a non-governmental entity such as a specialty association. CMS has indicated they plan to compile a list of such registries but have not yet done so. Resources you should check for available registries include: public health department in your state, your specialty association, certification board for your specialty, the Qualified Clinical Data Repository list for PQRS reporting (cms.gov/pqrs) and the National Quality Registry Network (www.nqrn.org – click on Inventory and register for an AMA account).
  • There are three exclusions: Provider’s scope of services does not include services captured by the registry (i.e. does not provide immunizations); provider is located in jurisdiction where no registry is capable of accepting electronic transactions; no registry in jurisdiction has declared readiness to receive electronic transactions as of the beginning of the reporting period.
  • Each category will have an exclusion option. Exclusions do not count toward the threshold of reporting to two registries. In other words to be fully excluded from the Public Health Measure, you will need to have an exclusion for Immunization and Syndromic Surveillance registries and be unable to identify an acceptable specialized registry related to your scope of service.

Click here for the entire 752-page rule.

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