60 Days to Comment on Stage 3 Meaningful Use Rule

After much anticipation among the medical community, the Centers for Medicare & Medicaid Services (CMS) finally released the meaningful use modification rule last month. The agency is allowing for a 60-day comment period to hear feedback on how Stage 3 can better align with the Merit-Based Incentive Payment System (MIPS) and alternative payment models. The rule combines modifications for meaningful use in 2015 to 2017, as well as the Stage 3 rule, which is optional in 2017 and required for all physicians in 2018.

TMA and the American Medical Association advocated many of the changes included in the modification rule but opposed finalizing Stage 3 due to a need to first assess the changes made to Stage 2 and a lack of alignment with the new MIPS.

CMS released the modification rule on Oct. 6. Given the lateness of the rule, AMA says it's difficult to educate physicians on the changes, including increased requirements for the public health and clinical data registry reporting objective. Physicians have until Dec. 15 to submit comments to CMS.

In response to AMA advocacy, CMS released an FAQ that explains how physicians can apply for a hardship exemption if they had difficulty meeting the meaningful use 2015 requirements due to the late release of the final modification rule.

While TMA staff members continue to comb through the meaningful use modification rule in detail, this much is clear in regard to your meaningful use 2015 reporting:  

  • Physicians participating in the meaningful use program can attest for any continuous 90-day period from Jan. 1, 2015, to Dec. 31, 2015. 
  • The requirement for 5 percent of your patients to view, download, or transmit their health information has changed to at least one patient seen by you during the electronic health record (EHR) reporting period. 
  • The requirement for 5 percent of patients to send a secure electronic message to their physician is now a yes/no statement attesting that the secure message functionality is enabled during the EHR reporting period. 

This chart shows updated objectives and measures for the modified version of Stage 2 meaningful use (2015 - 2017): 

Physicians have until Feb. 29, 2016, to report on their 2015 meaningful use measures. 

If you have questions about the meaningful use program or other practice technologies, contact TMA's Health Information Technology Department by email or by calling (800) 880-5720.  

Action, Nov. 2, 2015

Last Updated On

January 25, 2016

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