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 an EHR reporting period in section 495.4; and
- Paragraphs (2)(ii)(C)(2) and (2)(iii) of the definition of an EHR reporting period for a payment adjustment year in section 495.4.
“With regard to Stage 3, the extra comment period will enable providers, CMS and other stakeholders to ensure that the next stage of Meaningful Use advances interoperability and takes into account new payment models being advanced by Medicare,” Board of Trustees Chair Charles E. Christian, CHCIO, LCHIME, FCHIME, said last month.