On October 6, 2015, the Centers for Medicare and Medicaid Services (CMS) and the National Coordinator of Health IT (ONC) released the 752-page final rule for the EHR Incentive Programs, which they say will ease reporting requirements for providers. The rule finalizes proposals that were made by the agency back in April of 2015. This new framework will be based on the landmark bipartisan legislation – the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) – that requires the establishment of a Merit-based Incentive Payment System (MIPS) and consolidates certain aspects of a number of quality measurement and federal incentive programs for Medicare physicians and other providers into one more efficient framework. Some of the key takeaways of CMS’ final rule are:
- Eligible Professionals (EPs) will no longer have to provide information on 10 measures that have been judged redundant, duplicative, or widely adopted. This is down from 18 objectives in previous stages. These objectives include imaging results, family health history, electronic notes, patient list, patient reminders, clinical summaries, structured lab results, vital signs, smoking status, and patient demographics.
- The threshold for showing that a practice is successfully providing patients with electronic access to records to View, Download, and Transmit (VDT) will change from 5% of all patients to at least ONE single patient. Showing that a practice is successfully providing patients with secure messaging options will change from meeting or exceeding a threshold of 5% of patients to a simple “yes or no” question.
- In 2015, all practices, regardless of when they started meaningful use, need to report on their use of EHRs for any continuous 90 days, by February 29, 2016. This may be extended to the end of March if providers need more time.
- For 2016 and 2017 for both Medicare and Medicaid providers (and 2018 for Medicaid providers), providers that are NEW to the EHR Incentive Programs need to have additional flexibility and can report on any 90 days.
- For Medicare providers experiencing difficulty, CMS encourages applying for hardship exceptions, which are reviewed on a case-by-case basis. For example, providers switching EHR vendors or who have other technology difficulties may be eligible for a hardship exception.
- Give providers and states (Medicaid) more time – 27 months, until January 1, 2018 – to comply with the new requirements and prepare for the next set of system improvements.
- Give developers more time to create the next advancements in technology that will be easier to use and more appropriate to new models of care and access to data by consumers. This would give developers additional time to develop innovations and create usability-focused EHRs.
Meaningful Use Stage 3 Updates – A Mixed Bag for Physicians
From the proposed rule to the finalized version, CMS made some changes to the Stage 3 rule and kept other things in place. It kept the timing on Stage 3. Providers who opt to start Stage 3 in 2017 will only have a 90-day reporting period. Come 2018, all providers must comply with Stage 3 regulations using a certified EHR. It also kept its focus on interoperability. Of the 8 objectives for eligible providers, more than 60% require interoperability, compared to 33% previously. This is a strong indication that shows that CMS is dedicating itself to this kind of “interoperability.” In other words, you start figuring out how to combine a FitBit and your EHR. Some of the thresholds for Stage 3, such as the VDT, secure messaging, and patient education requirements, were lowered. The VDT and secure messaging requirements went from 25% of an EP’s patient panel to 5%. It also lowered the threshold on a requirement that asked EPs to incorporate patient-generated health data into the EHR, from 15% to 5%. Although CMS has announced its final rulemaking, it provides an additional 60 day public comment period. In 2017, Stage 3 requirements are optional, but providers who opt to start Stage 3 that year will have a 90-day reporting period. Come 2018, all providers must comply with Stage 3 regulations using a certified EHR.
EHR and the US Healthcare System
Patients, providers, businesses, health plans, and taxpayers all have a common interest in building a healthcare system that puts the patient at the center of their care. The new healthcare is modelled to:
- Deliver better care;
- Spend health care dollars more wisely; and
- Make our communities healthier.
Electronic health records are critical to making the US healthcare system better. The goal is to have an EHR system where health care providers and consumers are able to readily, safely, and securely exchange information. Overall, EHRs should offer several benefits to providers such as:
- Easy access to patient information;
- A series of tools, such as clinical alerts and reminders to support clinical decisions;
- Enhanced communication with other clinicians, labs, and health plans;
- Documentation that facilitates accurate coding and billing; and
- Safer, more reliable prescribing.
EHRs also should benefit patients. Some of the benefits are:
- Less paperwork;
- Reminders of important health interventions;
- Convenience of e-prescriptions; and
- An avenue for communication with their providers.
However, there is going to a paradigm shift to Health Information Technology (HIT) as EHRs become a tool for care improvement, not an end in itself. There is still more work to be done, according to CMS. More than 70% of eligible physicians and other clinicians have successfully used EHRs and received incentive payments from the federal government. That represents great progress from the days when a doctor’s handwriting needed to be interpreted and paper records could be misplaced.