On November 1, 2016, CMS issued the CY 2017 Outpatient Prospective Payment System (OPPS) Final Rule which included updates for the Electronic Health Record (EHR) Incentive Program (Meaningful Use).
Reduced Reporting Period
In CY 2016 and CY 2017, CMS has reduced the EHR reporting period for eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs).
The reporting periods for each year are as follows:
2016: Any continuous 90-day reporting period between January 1, 2016 and December 31, 2016
2017: Any continuous 90-day reporting period between January 1, 2017 and December 31, 2017
Clinical Quality Measures (CQMs):
CMS had finalized requirements for 2016 CQMs for eligible hospitals and CAHs in two separate rulemakings, the FY16 Inpatient Prospective Payment System (IPPS) Final Rule and the CY17 OPPS Final Rule. In 2016, eligible hospitals and CAHs have 2 options for reporting CQMs. Eligible hospitals and CAHs that choose to report CQM data by attestation must report 16 measures for any continuous 90-day period during CY 2016 through the Medicare EHR Incentive Program Registration and Attestation System. Alternatively, eligible hospitals and CAHs that choose to electronically report CQM data must report at least 4 eCQMs for either Q3 or Q4 of 2016 through the QualityNet Secure Portal.
Likewise, CMS had finalized requirements for 2016 CQMs for EPs in two separate rulemakings, the CY16 Physician Fee Schedule (PFS) Final Rule and the CY17 OPPS Final Rule. In 2016, EPs have 2 options for reporting CQMs. EPs that choose to report CQM data by attestation must report 9 measures for any continuous 90-day period during CY 2016 through the Medicare EHR Incentive Program Registration and Attestation System. Alternatively, EPs that choose to electronically report CQM data must report 9 eCQMs for the full calendar year through the CMS Enterprise Portal.
It is important to note that CQM data submitted via attestation can be submitted for a different 90-day period than the EHR reporting period for the Meaningful Use objectives and measures.
New Participant Requirements
CMS finalized requirements for new participants who have not demonstrated meaningful use in a prior year and would like to avoid the 2018 payment adjustment.
New participants (either EPs or eligible hospitals) trying to avoid the 2018 payment adjustment must attest to Modified Stage 2 objectives and measures for an EHR reporting period in 2017 through the EHR Incentive Program Registration and Attestation system by October 1, 2017. New CAH participants trying to avoid the FY 2017 payment adjustment must attest to Modified Stage 2 objectives and measures by October 1, 2017.
Significant Hardship Exception for New Participants Transition to MIPS in 2017:
EPs who have not demonstrated meaningful use in a prior year but are transitioning to MIPS as eligible clinicians in 2017 can apply for a one time significant hardship in 2017 by October 1 to avoid the 2018 payment adjustment and not attest to meaningful use in 2017. In their application, EPs must explain why demonstrating meaningful use for the first time in 2017 under the EHR Incentive Program and reporting on measures specified for advancing care information in MIPS in 2017 would result in a significant hardship. Once available, the application will be posted on the CMS EHR Incentive Program website.
Modifications to Measure Calculations
CMS finalized modifications to its policy for measure calculations for specified meaningful use measures (please refer to the “Additional Information” section of the measure specification sheets for measures that are affected). Beginning in CY 2017 actions included in the numerator must occur within the EHR reporting period if that period is a full calendar year. However, if the reporting period is less than a calendar year, actions included in the numerator must occur within the calendar year in which the EHR reporting period occurs. In other words, when a hospital selects any continuous 90-day EHR reporting period within CY 2017, the action must occur between January 1 and December 31, 2017, but does not have to occur within the 90-day reporting period.
Removal of 2 Objective Measures
Beginning in CY 2017, CMS is removing 2 objective measures: Computerized Provider Order Entry (CPOE) and Clinical Decision Support (CDS) because of their “topped out” status. However, CPOE and CDS are still required as part of the eligible hospital’s or CAH’s CEHRT but hospitals will not have to report on these measures for attesting to Meaningful Use.
Reduction of Reporting Thresholds
CMS has reduced some of the thresholds for eligible hospitals and CAHs attesting under the Medicare EHR Incentive Program for Modified Stage 2 in CY 2017 and Stage 3 in CY 2017 and 2018. CMS has also finalized a new naming convention for some of the objective measures.
The tables below include the new threshold requirements and naming conventions for Modified Stage 2 in CY 2017 and Stage 3 in CY 2017 and 2018.
By Alexis Donnaruma at 13 Dec 2016, 10:54 AM