Stage 3 2015 Proposed NPRM: What is CMS Thinking?

Written by Kay Jackson, Education and Advisory Manager, Iatric Systems

Stage 3 2015 Proposed NPRM image

As of last September, I’ve been watching for CMS to officially announce the switch to a shorter EHR reporting period for 2015. At that time, Congress first introduced Bill H.R. 270, designed to allow for a 90-day Meaningful Use reporting period, and the bill was supported by 33 co-sponsors.

Now, 8 months into reporting for 2015, CMS recently issued a notice of proposed rulemaking (NPRM), a complete game-changer for 2015. While this includes the reporting period change we were all hoping to see, I’m confused as to why CMS is changing the measures mid-reporting year.

We know that you have enough difficulties around Meaningful Use, so to have measures dropped mid-year and require eRx has increased the stress and challenges. Of course, to add to the confusion, these are just proposed changes, and CMS must wait for comments before finalizing in August.

Adding to the confusion is the change for Core 6.2; dropping from a required >5% of patients accessing the portal to the requirement of only a single patient to access the portal. While this may seem like a relief, here's the worry: for now, there's a lack of focus on Patient Engagement; but then hospitals have to face Stage 3, where the proposed requirement for patients who access the portal jumps to greater than 25% of patients, along with the requirement to provide electronic access to educational resources to more than 35% of patients. An additional proposed change for 2015 is to remove the ability to include paper TOC for Core 12.1.

All of these changes seem to be Meaningful Use Madness, and leave me scratching my head. The Comment period for proposed Stage 2 changes ended  on June 15, 2015, so watch for future blog posts as we wait for CMS to make final Stage 2 announcements.

Pick a date to register for our upcoming educational webcast:
How to Succeed with Meaningful Use Stage 3

July 16, 2015

July 28, 2015

Topics: Meaningful Use, Stage 3, NPRM, CMS

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