Qualifacts’ Point of View
Qualifacts is evaluating the most recent changes that the Centers for Medicare and Medicaid Services (CMS) made to Meaningful Use. CMS announced final rules on August 3, 2017 that include major changes for Eligible Professionals (EP) participating in Meaningful Use Program (MU) in CY 2017 and CY 2018.
Here are the top two implications of the changes:
- Reduce the MU EP reporting period in 2018 to 90 consecutive days, from January 1, 2018 to December 31, 2018
- Provide the flexibility for the MU EP to use a 2014 or 2015 ONC certified EHR for Meaningful Use in CY 2018.
Key changes for CY 2017 include:
- A 90-day Clinical Quality Measures reporting period during CY 2017 for all Medicaid EPs, regardless of submission method.
- Previously, in the 2015 EHR Incentive Programs Final Rule (80 FR 62762) for Medicaid EHR Incentive Programs, a CQM reporting period of the full CY 2017 for EPs who have demonstrated meaningful use in a prior year and a CQM reporting period of any continuous 90 days within CY 2017 for EPs who are demonstrating meaningful use for the first time.
Key changes for CY 2018 include:
- Final Rules set that an EHR reporting period of a minimum of any continuous 90-day period between January 1, 2018 through December 31, 2018 for new and returning participants attesting to CMS or their State Medicaid agency for Meaningful Use.
- Previously, the reporting period for and EP in CY 2018 was a full calendar year.
- Certified EHR Technology (CEHRT) flexibility in 2018: In an effort to grant more flexibility to health care providers. CMS has adopted a final policy to allow health care providers to use either 2014 Edition or 2015 Edition CEHRT, or a combination of 2014 Edition and 2015 Edition CEHRT, for their EHR reporting period in 2018.
- Previously, Medicaid MU EPs had to use a 2015 Edition CEHRT beginning January 1, 2018
- Under this final policy, for an EHR reporting period in CY 2018, health care providers will have the option to attest to the Modified Stage 2 objectives and measures using 2014 Edition CEHRT, 2015 Edition CEHRT, or a combination of 2014 and 2015 Edition CEHRT, as long as the EHR technology they possess can support the objectives and measures to which they plan to attest. Similarly, health care providers will have the option to attest to the Stage 3 objectives and measures using 2015 Edition CEHRT or a combination of 2014 and 2015 Edition CEHRT, as long as their EHR technology can support the functionalities, objectives and measures for Stage 3.
- Previously, Medicaid MU EPs had to attest to the Stage 3 objectives starting January 1, 2018.
Feeling caught a bit off guard? As Jim Tate of EMR Advocate advises in his blog, Meaningful Use in the Rear View Mirror, “Review the documentation in those early attestations, make corrections if possible, and don’t forget to glance at the rear view mirror from time to time.” Wise words, especially given today’s shifting health care expectations and requirements.