CMS has proposed big changes for meaningful use (MU) that will affect eligible providers (EP’s) and hospitals in 2015.  Below is a summary of what has been proposed but first let’s discuss what got us where we are today.

So why change?  Well, 2014 was a very difficult year for CMS.  Many vendors could not meet the stage 2 requirements and failed to certify their applications timely and failed to implement upgrades.  Also, many states still lack the infrastructure to accommodate many of the interoperability and reporting requirements.  This led many providers to fail to report and both EP’s and hospitals sought hardship exemptions at an alarming rate.  CMS responded last year by reducing the reporting period to one calender quarter but obviously it was too little too late.

The result of these failures has led to criticism on all fronts.  Congress is questioning the lack of progress and CMS’ ability to manage the programs.  The ONC has been criticized for failing to address the interoperability issues.  Vendors have been called out for a lack of response to their customers and failing to advance the MU goals.  Many professional organizations are demanding changes.  It has been reported that many EP’s are expected to leave the program entirely and take the financial hit in the form of penalties.

Well, it appears CMS is finally listening.  They have proposed significant changes that should provide relief in the form of a simplified set of requirements to meet MU in 2015.  The changes will also eliminate having different participants at different “stages” and beginning in 2016 all providers and hospitals will have to meet the same MU requirements regardless of which year they are in.  The goal is to have everyone on the same page and ready for stage 3 in 2018.

Below is a summary of the proposed changes for hospitals, including critical access hospitals.  I will include a link to the full proposal at the bottom of the page.  CMS is currently accepting public comments on the changes until June 15th, 2015.  You can expect the changes to become final as soon as 60 days after closing of comments.

Stage 1 in 2015

Reporting Requirements

  • Have until December 31, 2015 to collect data
  • Report on 90 consecutive days of data (not calender quarter)

Measures

  • CPOE to order meds on 30% of unique patients or 30% of total med orders
  • Clinical Decision Support – Implement one rule and drug interaction on all medications
  • Public Health Reporting – Be actively engaged with your public agency to submit data for 2 of the 6 measures (“actively engaged” means you at least have an agreement with the agency)
  • Provide 50% of patients electronic access to records within 36 hours of discharge
  • Perform a system security analysis

Stage 2 in 2015

Reporting Requirements

  • Have until December 31, 2015 to collect data
  • Report on 90 consecutive days of data (not calender quarter)

Measures

  • CPOE to order meds (60%), lab (30%), rad (30%)
  • Electronically submit summary of care on 10% of transfers
  • Clinical Decision Support – Implement 5 rules and drug interaction
  • Perform medication reconciliation on 50% inbound patients
  • Provide patient education to 10% unique patients
  • Provide 50% patients electronic access to records within 36 hours of discharge and have at least one patient access it
  • Public Health Reporting – Be actively engaged with your public agency to submit data for 3 of the 6 measures
  • Perform  a system security analysis

Years 2016 and 2017 (all providers and hospitals regardless of previous stage)

Reporting Requirements

  • Collect and report data for entire year Jan. 1 to Dec. 31st

Measures

  • CPOE to order meds (30%), lab (60%), rad (60%)
  • Electronically submit summary of care on 10% of transfers
  • Clinical Decision Support – Implement 5 rules and drug interaction
  • Perform medication reconciliation on 50% inbound patients
  • Provide patient education to 10% unique patients
  • Provide 50% patients electronic access to records within 36 hours of discharge and have at least one patient access it
  • Public Health Reporting – Be actively engaged with your public agency to submit data for 3 of the 6 measures
  • Perform a system security analysis
  • e-Prescribe 10%

So as you can see, there’s big changes coming this year.  Below is the link to view and comment on the proposed changes (be patient… it takes a minute or so for the entire page to load).

http://www.regulations.gov/#%21documentDetail;D=CMS-2015-0045-0001

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