Meaningful use (MU) can be difficult to track and predict. It’s like a beach by the ocean: You know it will be there, but its outlook changes nearly constantly with the tide.
Case in point: The Inpatient Prospective Payment System (IPPS) Final Rule, published Aug. 14, 2017, by the Centers for Medicare and Medicaid Services (CMS), impacts the required timeline of the MU program. This includes providing far greater flexibility in the timing of the requirement for MU participants – hospitals, critical access hospitals (CAHs) and eligible professionals (EPs) – to be using 2015 edition Certified EHR Technology (CEHRT).
In this blog, we’ll explore the landscape of MU in 2018 and 2019, including what the requirements are, what to expect and what health care organizations can do to prepare.
First, let’s look at the changes from the IPPS final rule for 2018. The two biggest changes to the MU program in 2018 for MU participants are:
Because CMS is allowing use of 2014 edition CEHRT in 2018, it also leads to the ability for MU participants to continue to attest to the Modified Stage 2 objectives and measures in 2018. This allows for Stage 3 use to be potentially delayed until 2019 for those who want to defer on it.
These changes allow a great deal of optionality in attaining MU in 2018. They are designed to ensure all MU participants have adequate opportunity ready to go on 2015 edition CEHRT and Stage 3 if they believe they need until 2019. These changes apply to all providers participating in MU (hospitals, CAHs and EPs), as well as to both the Medicare and Medicaid MU programs.
Next, we need to understand MU requirements for 2018 and 2019 after the Outpatient Prospective Payment System (OPPS) final rule for 2017, which altered the thresholds for a few MU measures for the 2017 and 2018 program years only.
The OPPS rule created separate requirements for the Medicare MU program and reduced the threshold for one Modified Stage 2 measure (View, Download and Transmit was reduced from more than 5 percent to one patient). The OPPS rule also reduced the threshold for eight measures in Stage 3:
Providers that are only attesting to MU through the Medicaid program, such as children’s hospitals and EPs, did not have a change in thresholds. Since there are no penalties for Medicaid MU, providers only participate in Medicaid MU for incentives.
These changes were only established for the 2017 and 2018 reporting years for Medicare MU. This means that in 2019, all the thresholds revert back to the original Stage 3 requirements or Medicaid-only requirements. Computerized Provider Order Entry and Clinical Decision Support will continue to be excluded from the Medicare MU program, but not the Medicaid MU program. State Medicaid agencies cannot alter the MU measures as CMS outlines them outside of the public health measures.
Now we can look at MU in 2018 and 2019 as we know it. The 2018 Medicare MU program allows MU participants a chance to ease into the Stage 3 requirements or delay them. There are lower thresholds for the measures, and the ability to use a 2014 and 2015 edition CEHRT combination, as long as the functionalities for Stage 3 are enabled, such as Application Programming Interface (API).
Movement to 2015 edition CEHRT is essential not just for the MU program, but for a growing list of other programs that require CEHRT. The Quality Payment Program (QPP) requires the use of CEHRT through the Merit-based Incentive Payment System and Advanced Alternative Payment Models. QPP is currently proposing to allow use of either 2014 or 2015 edition CEHRT in 2018 as well.
While several programs are moving to allow CEHRT flexibility in 2018, CMS is using the Comprehensive Primary Care Plus (CPC+) program as an indicator that they still intend to move to 2015 edition CEHRT. CPC+ still requires 2015 edition CEHRT beginning Jan. 1, 2018. This, as well as the commentary in the IPPS 2018 final rule, indicate CMS’s intention to move forward with the 2015 edition CEHRT requirements.
There are many changes between the 2014 edition and 2015 edition CEHRT requirements and several new measures being introduced in Stage 3. Requirements for use of the API will be new for many providers and patients. Patient Generated Health Information, Request/Accept Summary of Care and Clinical Reconciliation will all introduce new measures and use requirements for MU participants and may require new or additional workflow or policies, some of which will likely have to occur outside the actual patient encounter or visit. The secure messaging measure is also new for hospitals in Stage 3.
These new workflows, in addition to new functionality, will require testing and training. Stage 3 is coming, and the thresholds reset to the original level in 2019. 2018 presents a good opportunity for MU participants to test their new workflows and gauge their ability to move to Stage 3 before it becomes a required, all-or-nothing program.
While it is tempting to use the additional year of flexibility to put off projects or to put off rollout of workflows, there is no better way for an organization to understand its readiness than to go through the process. Hospitals and other health care systems should consider using 2018 as a ramp-up year for Stage 3, finding what works and what doesn’t prior to the increase in thresholds in 2019. Even if Stage 3 remains out of reach after the attempt, Modified Stage 2 is still an option even on 2015 CEHRT, and organizations will have a better idea of your Stage 3 strategy when they are required to begin.
How will you stay ahead of the curve with new regulatory requirements? Count on Cerner to lead you through the future of regulatory compliance. Learn more here.