CMS Seeks Feedback on Stage 3 Meaningful Use Rule

On October 6, 2015, after much anticipation, CMS released the final rules for the Stage 3 Meaningful Use incentive program and the corresponding certification requirements for EHR vendors. Now, the Centers for Medicare & Medicaid Services is asking for feedback during the 60-day comment period that has followed the publishing of the Stage 3 Meaningful Use final rule.     CMS issued a recent bulletin calling for feedback on provisions in Stage 3 that will impact eligible professionals and hospitals for some Medicare providers in 2017 and all in 2018. According to CMS, there will be a 60-day public comment period to facilitate additional feedback about Stage 3 of the EHR Incentive Programs going forward, in particular with the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which established the Merit-based Incentive Payment System (MIPS) and consolidates certain aspects of a number of quality measurement and federal incentive programs into one more efficient framework. The 60-day comment period for the Stage 3 final rule ends December 15. The list of Stage 3 provisions eligible for comment include four of the seven bullet points identified by CMS: II.B.1.b.(3).(iii) – EHR Reporting Period in 2017 and Subsequent Years; II.B.1.b.(4).(a) – Considerations in Review and Analysis of the Objectives and Measures for Meaningful Use; II.B.2.b – Objectives and Measures for Stage 3 of the EHR Incentive Programs; II.D.1.e – Methods for Demonstration of the Stage 3 Criteria of Meaningful Use for 2017 and Subsequent Years; II.G.2 – EHR Reporting Period and EHR Reporting Period for a Payment Adjustment Year for First Time Meaningful EHR Users in Medicaid; Paragraphs (1)(ii)(C)(3), (1)(iii), (2)(ii)(C)(3) and 2(iii) of the definition of...