CMS Proposed Rule Creates New MU Pathways in 2014
Key Takeaway: The Centers for Medicare and Medicaid Services (CMS) will allow providers to meet Stage 1 or Stage 2 meaningful use with any combination of Certified EHR Technology (CEHRT) regardless of which requirements the provider is scheduled to meet in 2014.
Why it Matters: Attestations for this critical year of meaningful use have lagged due to CEHRT availability and tight implementation deadlines. The rule proposed by CMS would create new pathways for providers to meet MU in 2014, rather than force them to file hardship exceptions and forego incentives.
Signs that CMS had taken action to address lagging attestations for meaningful use were first revealed two weeks ago. The agency responsible for EHR incentives, and forthcoming penalties, sent a rule to the Office of Management and Budget, entitled “Modifications, Revisions: Medicare and Medicaid Electronic Health Record Incentive Programs for 2014.” The proposed rule published a week later contained several provisions to help struggling providers and EHR vendors deal with Meaningful Use requirements in 2014. Among those are new flexibilities that will allow providers to choose different pathways to meet MU this year. Depending on what Edition of Certified EHR Technology a provider has and which Stage they would like to attest, CMS and the Office of the National Coordinator for Health IT (ONC) have made available several distinct options.
If you were scheduled to attest to Stage 2 in 2014, you may:
- Attest to Stage 2 objectives using 2014 Edition CEHRT;
- Attest to Stage 2 objectives using a combination of 2014 and 2011 CEHRT;
- Attest to 2014 Stage 1 objectives using 2014 Edition CEHRT or a combination of 2011 and 2014 Edition CEHRT; or
- Attest to 2013 Stage 1 objectives using 2011 Edition CEHRT or a combination of 2011 and 2014 Edition CEHRT.
If you were scheduled to attest to your second year of Stage 1, you may choose from options three or four above. The differences between 2014 Stage 1 objectives and 2013 Stage 1 objectives are outlined in this CHIME crosswalk; and this CMS tip sheet outlines changes resulting from Stage 2 final rules.
For Eligible Hospitals (EHs) and Critical Access Hospitals (CAHs), the decision on how to proceed must be made quickly and without the certainty of a final rule, which will not be available until after July 1 – the beginning of the last reporting period. Given the realities of timing, CIOs should consider their options carefully; but they should also note the proposed rule requires 365-days of data in 2015. For many providers this means having 2014 Edition CEHRT in place to meet Stage 2 requirements by October 1, 2014.
CHIME will provide further guidance in the coming days. Please direct all questions or comments to Jeff Smith, Sr. Director of Federal Affairs.
Senators Applaud Changes to Meaningful Use in 2014
Key Takeaway: Last Thursday Sens. Lamar Alexander (R-TN), John Thune (R-SD), Richard Burr (R-NC), Mike Enzi (R-WY) and Pat Roberts (R-KS) commended ONC and CMS’ decision to alter the requirements for providers to achieve Meaningful Use in 2014.
Why it Matters: Despite past criticism of HHS health IT efforts, the Republicans congratulated officials for taking sensible steps to ensure providers continue their MU journey. This showing of support bolsters health IT as a bipartisan issue. A group of Senators applauded CMS and ONC for their proposed rule to give providers much-needed flexibility in 2014. Sens. Lamar Alexander (R-TN), John Thune (R-SD), Richard Burr (R-NC), Mike Enzi (R-WY) and Pat Roberts (R-KS) have been actively engaged in the health IT space for over a year: they published the “REBOOT: Re-examining the Strategies Needed to Successfully Adopt Health IT” whitepaper in April 2013, which focused on interoperability among other things; sent a letter to HHS in September 2013 requesting an extension of the timelines for Meaningful Use in 2014; and send an additional letter to HHS in March 2014 expressing concern about the expansion of the Meaningful Use hardship exception to aid providers struggling with implementation.
Due to the large taxpayer investment, the Senators expressed the need to keep momentum for the program going, but called for appropriate timelines to ensure patient safety.
$110 Million in Grants Given for Health Innovation Awards Program
Key Takeaway: The Department of Health and Human Services (HHS) has announced grant awards totaling as much as $110 million for twelve recipients under the Affordable Care Act’s Health Innovation Awards Program for delivery system reform projects.
Why it Matters: Providers who continue to reshape the way they deliver care should remain vigilant for such opportunities to scale best practices. Federal funds will continue to be available for hospitals and physicians who are willing to innovate.
Despite political turmoil surrounding the Affordable Care Act, HHS is committed to implementing the law to continue efforts to reduce cost in the healthcare system and provide better care to patients. The projects will focus on the following areas:
- Care models that reduce costs for Medicare, Medicaid and CHIP;
- Models that improve care for patients with specialized needs;
- Models that test financial and clinical model transformation for specific types of providers; and
- Models that focus on population health – including geographic location, socioeconomic status or clinical status (people with a certain type of disease).
The first round of awards went to 107 recipients from all 50-states and the District of Columbia. Find out more about the second round of grants on CMS’ Healthcare Innovation site.
CHIME Calls for Volunteers: FDASIA Health IT Report and Quality Measurement
The FY 2015 Inpatient Prospective Payment System (IPPS) proposed rule was published in late April. Each year CMS publishes an IPPS proposed rule for the upcoming FY that includes payment rules for acute care hospitals and long-term care hospitals as well as quality reporting requirements. This workgroup will consider the quality reporting requirements as well as proposals to intertwine Meaningful Use status for payment bonuses and penalties.
The first meeting Friday, May 30 at 1pm ET with plans to hold four additional calls. Timing of those additional calls will depend on workgroup availability, but CHIME looks to meet at a consistent day/time leading up to June 20. Comment deadline: Monday, June 30, 2014.
CHIME is forming a workgroup to help answer the question: What’s the government’s role in regulating health IT? The workgroup will give feedback on FDA, ONC and FCC’s draft risk-based regulatory framework for health IT and create recommendations for the final report.
The first meeting will be held Friday, May 30 at 11:30am ET with plans to hold five additional calls. Timing of those additional calls will depend on workgroup availability, but CHIME looks to meet at a consistent day/time leading up to June 27. Comment deadline: Monday, July 7, 2014.
Please contact Angela Morris if you are interested in either workgroup.
Edited for style by Gabriel Perna