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Breaking Down Stage 2 Meaningful Use Attestation in 2016

A need-to-know guide for all aspects of meaningful use attestation, including timeframes, objectives measures, EHR certification, and alternate exclusions.

By Sara Heath

As the new year quickly approaches, so does the start of meaningful use attestation under the new final Stage 2 Meaningful Use Modifications Rule. With that final rule comes many changes to Stage 2 Meaningful Use that providers will need to take into account as they attest in 2016.

What are these changes? What information do providers need to know about meaningful use attestation? Below is a roundup of materials from the Centers for Medicare & Medicaid Services (CMS) and EHRIntelligence.com articles to help providers prepare for meaningful use attestation in 2016:

Stage 2 Meaningful Use Attestation Timeframes

Under the final rule, which was released in early October of this year, meaningful use attestation timeframes were adjusted to align with the full calendar year. Starting in 2016, both eligible professionals (EPs) and eligible hospitals (EHs) will need to attest to Stage 2 Meaningful Use between January 1 and December 31 of 2016.

However, all first-time Stage 2 meaningful use participants, as well as those attesting for 2015, will only need to attest to a 90-day timeframe. These 90 days must be consecutive and occur between January 1 and December 31 of 2016.

Streamlining Objectives Measures

In a webinar following the release of the meaningful use Modifications Rule, CMS provided a comprehensive summary to the various changes to Stage 2 meaningful use, as well as the rationale behind it. Specifically, CMS discussed Stage 2 meaningful use objectives measures and the way they have been compressed.

Under the Stage 2 meaningful use Modifications rule, EPs attesting for 2016 will only need to attest to 10 core objectives. One of these core objectives must be an overarching public health reporting objective that includes three reporting measures.

The meaningful Use Modifications Rule also streamlines objectives for EHs and critical access hospitals (CAHs), reducing the number of objectives to nine, with one overarching public health reporting objective that includes four reporting measures.

These objectives were changed to align better with the goals and requirements of Stage 3 Meaningful Use, as well as to get rid of “redundant and duplicative” requirements.

CMS Meaningful Use Objectives

Certified EHR Technology

Although 2015 attestations required providers to use the 2014 edition of Certified EHR Technology, the 2016 meaningful use attestation requirements provide more flexibility. According to CMS, providers may attest to meaningful use using either the 2014 certification edition, or the newly-released 2015 edition.

The Department of Health and Human Services (HHS) Office of the National Coordinator for Health IT (ONC) released the 2015 EHR certification criteria at the same time as the Meaningful Use final rule. The 2015 criteria put an emphasis on interoperability and health information exchange (HIE).

Specifically, the criteria call for mandatory HIE testing reports, as well as updated data export to facilitate adequate interoperability.

As stated above, attesting with these EHR certification criteria is optional in 2016, but becomes mandatory in 2018.

Alternate Exclusions

Because providers may not have EHR systems that can support the new provisions in the Modified Stage 2 Meaningful Use guidelines, CMS is offering several alternate exclusions. CMS has released a comprehensive list of alternate exclusions for EPs, EHs, and CAHs as an attachment to other Meaningful Use attestation guidelines.

However, CMS has addressed notable exclusions including those for public health reporting. Due to an influx of concern regarding the ability to attest to public health reporting measures, CMS is offering alternate exclusions stating that EPs may report on only two of the three measures, but that one of the two measures must be measure 1, which pertains to immunization registry reporting.

Meaningful Use Public Health Reporting Measures

EHs and CAHs applying for an alternate exclusion may attest to only three of four measures, but one of the meaningful use measures must be measure 3, which involves specialized registry reporting.

When attesting to Stage 2 meaningful use in 2016, providers and hospitals alike will need to bear in mind these changes to the program in order to ensure a smooth attestation. Provided CMS’s rationale for the Stage 2 modifications—which includes the consistency between Stage 2 and Stage 3 meaningful use requirements—adhering to these new modifications will allow for a better transition to Stage 3 meaningful use come 2018.

Image Credits: Centers for Medicare & Medicaid Services, The Federal Register

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