CMS Proposed Rule: MU Stage 3 Reporting Requirements Won’t Change

July 18, 2017
In a payment rule released last week, the Centers for Medicare & Medicaid Services (CMS) proposed that reporting requirements for Stage 3 of the meaningful use program would not change, with the last stage of the federal program on track to commence on Jan. 1, 2018.

In a payment rule released last week, the Centers for Medicare & Medicaid Services (CMS) proposed that reporting requirements for Stage 3 of the meaningful use program would not change, with the last stage of the federal program on track to commence on Jan. 1, 2018.

The rule from CMS, which keeps in place Stage 3 meaningful use requirements, scheduled to start in January, also did not propose any changes in regard to hospitals being required to use 2015 edition certified EHR technology (CEHRT) starting next year. For several months, industry groups have been urging CMS to give hospitals at least six more months to be fully up-and-running with the newer EHR editions that are required under meaningful use Stage 3, but it now doesn’t look like that request will be granted.

Predictably, many of these same health IT associations were upset following the release of the rule last week. The American Hospital Association (AHA), for one, said in a statement, “We are dismayed that CMS does not propose relief from unrealistic and unachievable Stage 3 reporting requirements that begin on Jan. 1, 2018. The mandate for all hospitals and critical access hospitals to switch to new EHR functionality and report for a full year is unattainable and is at odds with the meaningful use flexibility proposed for eligible clinicians in the Quality Payment Program proposed rule.”

What’s indeed noteworthy is that on the physician practice front, in the proposed Quality Payment Program rule for 2018 that CMS recently released, the use of 2014 Edition CEHRT would continue to be allowed to meet MIPS requirements, while the use of 2015 edition CEHRT would be encouraged, but not required.

It was also AHA which said last month that Stage 3 should be cancelled outright. The organization noted at the time that hospitals “already face “extensive, burdensome and unnecessary ‘meaningful use’ regulations from CMS that require significant reporting on use of EHRs with no clear benefit to patient care. These excessive requirements are set to become even more onerous when Stage 3 begins in 2018.”

Meanwhile, the Healthcare Information and Management Systems Society (HIMSS) also expressed a similar sentiment in response to the new rule. In a statement, HIMSS said, “Where our concern lies is that CMS did not use the Outpatient Prospective Payment System Proposed Rule to modify the requirement for the use of 2015 Edition Certified Electronic Health Record Technology (CEHRT) in hospitals starting January 1, 2018. Our concerns with the truncated timeline for providers to be fully up-and-running with new 2015 Edition CEHRT were addressed in our April 2017 letter to Secretary Price. We will continue to provide recommendations to CMS on a timeline that advances clinical outcomes and patient safety.”

What’s more, in a recent notice to its members, the College of Healthcare Information Management Executives (CHIME) expressed a desire for its members to share their concerns with CMS over the current situation with the CEHRT program, and the very real possibility that hospital organizations could be penalized for not using EHRs that have been certified as of the 2015 program requirements, even as EHR vendors have not yet completed their certifications. As Healthcare Informatics reported last month, CHIME said to its members, ““We are halfway through 2017 and most vendors still are not certified for 2015 CEHRT, raising concerns among members that their success at meaningful use, MIPS and a host of other programs CMS has hitched to this wagon will be jeopardized. Act today to help us convince CMS that another year using 2014 Edition CEHRT will give the provider and vendor community more time to prepare.”

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