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Recapping EHR Meaningful Use Program Modifications Since 2014

The latest EHR meaningful use program modification potentially includes a complete overhaul of the entire program.

By Sara Heath

The Centers for Medicare & Medicaid Services (CMS) EHR meaningful use programs, the source of frustration for many healthcare providers, has undergone several modifications since it began in 2011.

From its flexibility modifications regarding certified EHR technology back in 2014 to CMS’s latest announcements about the large revisions being made in the near future, we’ve traced the various iterations the meaningful use programs have seen throughout the years.

CMS establishes CEHRT flexibility

In September 2014, CMS announced a final rule to the meaningful use programs, giving participants three different attestation options with their CEHRT. This decision came because several industry stakeholders and vendors were not ready to transition from the 2011 EHR certification rules to the 2014 EHR certification rules.

These changes allowed meaningful use participants to attest to the program using either 2011 CEHRT, 2014 CEHRT, or a combination of both, depending upon what stage of the meaningful use programs the provider was attesting to.

Although the rule was designed to provide further flexibility for providers and vendor alike, it was met with some critics. The College of Healthcare Information Management Executives (CHIME) expressed its disappointment that this finalized rule included a provision requiring a 365-day reporting period.

“This single provision has severely muted the positive impacts of this final rule. Further, it has all but ensured that industry struggles will continue well beyond 2014,” wrote CHIME’s leader Russell Branzell, FCHIME, CHCIO.

Original timeline for meaningful use

Stage 2, Stage 3 Meaningful Use rules released

Approximately one year later, CMS was ready to begin releasing a Stage 2 modifications rule, and the requirements for Stage 3 Meaningful Use.

After releasing a proposed draft rule for Stage 2 and Stage 3 Meaningful Use, CMS was met with a firestorm of industry resistance. Key stakeholders, including the American Medical Association (AMA) sent letters urging CMS to delay the implementation of Stage 3 Meaningful Use on the grounds that the industry was not ready for its implementation.

By the end of September 2015, even Congress was calling for a delay in the ruling.

"We have an interest in being active partners in successfully enabling health information technology to serve as the digital infrastructure necessary to achieve delivery system reform and meet the needs of a modern healthcare system," Congress wrote in a letter to CMS. "To that end, we urge you to refrain from finalizing Meaningful Use Stage 3 and 2015 Edition Certification at this time."

Despite the many protests from industry groups, CMS released its meaningful use modifications final rule on October 6, 2015. This rule both established modifications to Stage 2 Meaningful Use and established the requirements for Stage 3 Meaningful Use, which will begin with optional attestation in 2017 and required attestation in 2018.

The former part of the rule, the modifications to Stage 2 Meaningful Use, was generally met with positive reaction. The modifications reduced the reporting period to any continuous 90-day period, and got rid of any extraneous reporting requirements.

The Stage 3 Meaningful Use rule, however, was met with more protest from the healthcare industry. Organizations such as the AMA and the Healthcare Informatics and Management Systems Society (HIMSS) both submitted critical comments regarding the rule. AMA submitted a suggestion for a general overhaul of the requirements, while HIMSS suggested CMS revise the implementation timeline of Stage 3 Meaningful Use.

CMS says it wants to put MU back in physician hands

At the JP Morgan Healthcare Conference at the beginning of this year, several of Stage 3 Meaningful Use’s biggest critics received the news they’d been waiting for. CMS’s acting administrator Andy Slavitt announced that meaningful use as we know it would essentially be over, and that the program would be reshaped to put providers back in more power.

These modifications would also put a greater emphasis on interoperability, rewarding specific provider goals, and allowing EHR developers to cater more toward provider needs.

Days later, Slavitt and National Coordinator for Health IT Karen DeSalvo explained in a blog post that these changes would take time, and as of right now meaningful use is still functioning as it always has. However, this marks a major change within the program. Stage 3 Meaningful Use hadn’t even begun yet and CMS was already planning to make significant changes, perhaps highlighting a change in the back-and-forth and argumentative dynamic between industry stakeholders and the agency.




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