- Stage 3 Criteria: CMS says the proposed criteria focus on “advanced use of certified EHR technology to promote health information exchange and improved outcomes for patients,” with Stage 3 expected to be the final stage of MU.
- Implementation Timeline: Stage 3 would be optional for 2017 so that, as noted on p. 30, providers could “move on to Stage 3 in 2017 or remain at Stage 2, or for some providers to remain at Stage 1, depending on their participation timeline.” In 2018, all providers would report on this “same [proposed] definition of Meaningful Use at the Stage 3 level regardless of their prior participation, moving all participants in the EHR Incentive Programs to a single stage of Meaningful Use in 2018.”
- Clinical Quality Measures (CQMs): CMS proposes to “continue encouraging CQM data submission through electronic submission for Medicare participants in 2017, and to require electronic submission of CQMs where feasible beginning in 2018 for Medicare providers demonstrating Meaningful Use.” Separate requirements apply for the Medicaid CQM submission.
- Reporting periods: The rule proposes to amend the EHR reporting period so that “all providers would report under a full calendar year timeline with a limited exception under the Medicaid EHR Incentive Program for providers demonstrating Meaningful Use for the first time”; these excepted providers would have a 90-day reporting period. Separately, CMS Acting Deputy Administrator and Chief Medical Officer Patrick Conway notes that the agency intends to propose a “new Meaningful Use reporting deadline soon.”
- 2015 Edition Criteria: The rule proposes certification criteria to “facilitate greater interoperability for several clinical health information purposes and enable health information exchange through new and enhanced certification criteria, standards, and implementation specifications.”
- EHR Definition: The proposed 2015 Edition Base EHR definition will not include privacy and security capabilities and certification criteria, as ONC believes these requirements are better addressed by newly proposed requirements to certify “Health IT Modules.” The 2015 EHR definition also includes a system’s ability to record and export Clinical Quality Measure data, but not the ability to import, calculate or record such data. Furthermore, the definition includes “smoking status,” “implantable device list,” and “application access to Common Clinical Data Set” certification criteria. ONC will also remove the “Certified EHR Technology (CEHRT)” definition from the 2015 EHR definition, and replace “Common MU Data Set” definition with “Common Clinical Data Set” in order “to make the ONC Health IT Certification Program more open and accessible to other types of health IT beyond EHR technology and for health IT that supports care and practice settings beyond those included in the EHR Incentive Programs.”
- Interoperability Standards: ONC’s proposed rule addresses its ongoing focus on achieving interoperability across EHRs. Toward that end, ONC proposes two certification criteria: one that allows easier searching through a “Common Clinical Data Set” and another that assess the product’s “C-CDA creation performance (for both C-CDA version 1.1 and 2.0) when presented for certification.”
- Going Beyond EHR Certification: ONC notes, “we also propose to modify the ONC Health IT Certification Program in ways that would further open access to other types of health IT beyond EHR technology and for health IT that supports care and practice settings beyond the ambulatory and inpatient settings.” To this end, the proposals would “permit other types of health IT (e.g., laboratory information systems (LISs)), and technology implemented by health information service providers (HISPs) and health information exchanges (HIEs)) to receive appropriate attribution and not be referenced by a certificate with “EHR” in it.” Other practice settings to be included in the certification program include long-term post-acute care (LTPAC), behavioral health, and pediatrics.
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