Today, CMS released the Meaningful Use Modifications and Stage 3 Meaningful Use final rule . The Stage 1 and Stage 2 Modifications rule contains major changes to both Stage 1 and Stage 2 Meaningful Use, including increased flexibility for providers.
ASCRS advocated for many of the changes regarding flexibility CMS finalized in this rule, but opposed finalizing the Stage 3 Meaningful Use rule due to the increased thresholds required, and the need to delay Stage 3 Meaningful Use until providers are successfully attesting to Stage 2. In addition, ASCRS urged a pause to the implementation of Stage 3 due to the requirement to integrate Meaningful Use into the MIPS program in 2017. Despite opposition and advocacy from ASCRS and the rest of the medical community, CMS finalized Stage 3 threshold increases and is continuing with the move to Stage 3 for all providers in 2018.
Stage 1 and 2 Modifications
For 2015 only, CMS finalized allowing all eligible professionals, regardless of their prior participation in the program, to attest to an EHR reporting period of any 90-day reporting period. For 2015, 2016 and 2017, CMS finalized allowing new participants in the EHR Incentive Program to attest to Meaningful Use for an EHR reporting period of any continuous 90-day period within the calendar year. All returning participants in 2016 and 2017 must use an EHR reporting period of one year.
Patient Engagement Measures
For the patient engagement measures, CMS changed the Stage 2 objective for Patient Electronic Access, that requires patients to view, download or transmit their health information, from '5 percent' to 'equal or greater than 1' for 2015 and 2016 only. The measure will increase to require that 5 percent of patients view, download or transmit their health information in 2017.
For the Secure Electronic Access measure, CMS finalized that in 2015 providers must have the capability for patients to send and receive a secure electronic message. For 2016, at least one patient seen by the eligible professional during the EHR reporting period must be sent a secure message. In 2017, for more than 5 percent of unique patients seen by the eligible professional during the EHR reporting period a secure message must be sent using the electronic messaging function of CEHRT to the patient. Finally, the public health measures, which were previous menu measures, have been consolidated, and require an eligible professional to report to actively engage with a public health agency or clinical data registry to submit data.
In addition, CMS eliminated the distinction between menu and core measures and all retained objectives and measures will be required to successfully attest. CMS finalized all eligible professionals must report on 9 objectives and one consolidated public health reporting objective for both Stage 1 and Stage 2 of Meaningful Use.
Stage 3 Meaningful Use
CMS finalized that Stage 3 Meaningful Use will be optional in 2017 and required for all participants beginning in 2018. CMS also finalized increased threshold reporting requirements for many Stage 3 Meaningful Use measures, including a requirement that for more than 25 percent of all unique patients seen by a provider during the EHR reporting period, a secure electronic message must be sent. CMS did lower some thresholds from the proposed rule, including lowering the number of unique patients that have to actively engage with the EHR from 35 percent to 10 percent, and reducing electronic prescribing from 80 to 60 percent.
CMS did not make any changes to the CQM selection and reporting for Stage 1, 2 or 3 of Meaningful Use.
Please review this rule carefully, and look for additional information in the Washington Watch, as many of the percentages and exclusions have changed. View the CMS Fact Sheet  and HHS Press Release  for more information. ASCRS will also continue to advocate for a delay of Stage 3 Meaningful Use and for a hardship exemption for the reporting year 2015.
If you have any questions, please contact Ashley McGlone at 703-591-2220.