Meaningful Use over the next two years: what to expect

In 2017 Centers for Medicare and Medicaid Services (CMS) implemented two major changes in the Meaningful Use rules slated to go into effect in 2018 and 2019. In the next two years, practices should pay attention to changes to the Meaningful Use program arising from the FY2018 Inpatient Prospective Payment System (IPPS) final rule for 2017 which implemented significant changes to Meaningful Use standards providing some flexibility to the previous guidelines set to take effect in 2018.  

Changes arising from the Inpatient Prospective Payment System (IPPS) final rule

The FY2018 IPPS final rule released on August 3. 2017 by CMS offers modifications to previous guidelines regarding Stage 2 and Stage 3 reporting and guidelines concerning certified EHR technology.

For 2018, CMS modified the EHR reporting periods for new and returning participants attesting to CMS or their state Medicaid agency from the full year to a minimum of any continuous 90-day period during the calendar year.

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Further, for 2018, CMS is adopting final policies to allow healthcare providers to use either 2014 Edition CEHRT, 2015 Edition CEHRT, or a combination of 2014 Edition and 2015 Edition CEHR. The modification of this rule will come as a relief for practices given the shortage of product meeting the 2015 CEHRT standards. According to August 4, 2017, a report published in Modern Healthcare, “only 96 products are certified for the 2015 edition, according to the Office of the National Coordinator for Health Information Technology's Certified Health IT Product List, compared to 3,749 certified for the 2014 edition.”  

Extended deadlines for Meaningful Use Stage 3

Another significant change arising from the IPPS final rule issued in 2017 shifts the compliance deadline for hospitals to meet Meaningful Use Stage 3 objectives and measures until 2019, rather than the 2018 deadline originally contemplated. In place, of Stage 3 attestation hospitals and critical access hospitals will have the option to report modified stage 2 for the 2018 reporting period or move forward with Stage 3.

Moderated standards for Meaningful Use Stages 2 and 3

Under the rules articulating the modified Stage 2 and 3 standards, CMS reduced the threshold for one Stage 2 measure, reducing the requirement regarding the number of patients should practices enable to view, download, and transmit their health data was reduced from more than 5 percent of patients to one patient. The rule also reduced the threshold for eight measures in Stage 3:

• Patient Access (80% to 50%)
• Patient-Specific Education (35% to 10%)
• View, Download or Transmit measure (10% to one patient)
• Secure Messaging (25% to 5%)
• Send a Summary of Care (transition of care) (50% to 10%)
• Request/Accept Summary of Care (incorporate) (40% to 10%)
• Clinical Information Reconciliation (80% to 50%)
• Public Health/Clinical Data Registries (four registries to three registries)

One significant takeaway from these changes rests in the fact that the modified Stage 3 thresholds expire December 31, 2018, at which time they revert to the original Stage 3 measures, which may present challenges for hospitals to meet.

In the next two years, the CMS appears to have taken a step back from their previously ambitious Meaningful Use standards. However, practices should realize that beyond 2019 the compliance burden will likely ramp up again, despite the reprieve offered in the IPPS final rule.