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Summary of Medicare and Medicaid EHR Incentive Program: Stage 3 and Modifications to Meaningful Use (MU) in 2015 and 2017

  • Drugs and Devices
  • Quality Improvement and Patient Safety

Overview

On October 6, 2015, the Centers for Medicare and Medicaid Services (CMS) released its final rule, Medicare and
Medicaid Programs; Electronic Health Record Incentive Program—Stage 3 and Modifications to Meaningful Use
in 2015 through 2017. The rule specifies the requirements that eligible professionals (EPs), eligible hospitals, and
critical access hospitals (CAHs) must meet in order to qualify for the Medicare and Medicaid Electronic Health
Record (EHR) Incentive Program. It includes a 90-day EHR reporting period in 2015 for all providers and removes
reporting requirements on measures that have become redundant, duplicative, or topped out. In addition, the
rule establishes the requirements for Stage 3 of the program as optional in 2017 and required for all participants
beginning in 2018. CMS also continues to encourage the electronic submission of clinical quality measure (CQM)
data, establishes requirements to transition the program to a single stage, and aligns reporting for providers in
the Medicare and Medicaid EHR Incentive Programs.

While not clearly explained in the rule, providers who are unable to meet the requirements of meaningful use
for an EHR reporting period in 2015 for reasons related to the timing of the publication of the final rule may
apply for a hardship exception under the “extreme and uncontrollable” circumstances category. Each hardship
exception application will be reviewed on a case-by-case basis. CMS is expected to remind providers about this
hardship exception and its application to these unique circumstances as part of a frequently asked questions
(FAQ) document in the coming days.

The rule will be published in the Federal Register on October 16, 2015, and includes a 60-day comment period,
through which CMS hopes to gain additional feedback on the Stage 3 criteria. Note that page numbers below
link to the display version of the final rule.

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