Meaningful Use Stage 3 Final Rule Reduces Provider Burdens

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CMS and the Office of the National Coordinator for Health Information (ONC) recently released the 752-page final rule for Meaningful Use Stages 2 (MU2) and 3 (MU3). The final rule provides a flexible timeline for providers and reduces the number of objectives and accompanying clinical quality measures required for reporting.

The rule further provides that:

  • The 365-day reporting period for 2015 is reduced to a 90-day reporting period. The attestation deadline for 2015 is February 29, 2016.
  • For MU2 2015 through 2017, the objectives with clinical quality measures have been reduced to 10 objectives for eligible professionals (EPs) and nine objectives for eligible hospitals and critical access hospitals (CAHs).
  • For MU3 2017 and subsequent years, the objectives are further reduced to eight objectives for EPs, eligible hospitals, and CAHs.
  • The public health objective for MU2 will be modified to more closely resemble MU3’s public health objective.
  • MU3 requirements will be optional in 2017. If a provider moves to MU3 in 2017, the provider will have a 90-day reporting period.
  • All providers will be required to comply with MU3 in CY 2018 using EHR technology certified to the 2015 Edition Objectives

Of note, the recently enacted MACRA effectively retired Meaningful Use-based payment adjustments and requires the incorporation and development of Meaningful Use in the replacement physician payment system, MIPS. The final rule includes a 60-day comment period on the transition to MIPS and the finalized requirements for the EHR Incentive Program. CMS and ONC plan to release a notice of proposed rulemaking (NPRM) by mid-2016 for MIPS.

Last but not least, the final rule includes 2015 Edition Health IT Certification criteria focusing on greater interoperability and greater data access. CMS and ONC will continue to release guidance as the transition from MU2 to MU3 takes place.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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