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Nicole
Manager
Value Based Services

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On July 14, CMS announced changes to Meaningful Use including a proposed 90 day reporting period for 2016. TSI Healthcare is committed to keeping our family of clients informed with the latest industry news. We would like to take the opportunity to clarify what was proposed by CMS as part of the “Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems and Quality Reporting Programs” Proposed Rules. The full proposed rule can be found here. Summarized below are the key takeaways as they pertain to Meaningful Use in 2016. Public comments are being accepted through September. We expect the final rule to be published in late October/November.

Click here to learn more about the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA)

Proposals Impacting 2016 Reporting Period:

• Proposed Revisions to the EHR Reporting Period in 2016 for EPs, Eligible Hospitals, and CAHs
  • Proposal
    • CMS is proposing a 90 day reporting period for Modified Stage 2 in 2016
      • Rationale: Allow providers to focus on preparing for MIPS starting in 2017
      • If finalized, providers could report Modified Stage 2 for any consecutive 90 day period in 2016
        • The attestation period (submitting data to CMS) would still occur in January and February 2017
        • Clinical Quality Measures can be reported for either the same 90 day reporting period or a different 90-day period in 2016
        • (“Aligned reporting” is still an available option)
• Proposed Modifications to Measure Calculations for Actions Outside the EHR Reporting Period
  • Proposal
    • CMS is proposing to include actions that may occur outside the reporting period yet occur within the reporting year in the Modified Stage 2 report calculations for the 2016 reporting period
      • Because the 2016 reporting period is proposed to change to 90 days, CMS is proposing that actions that occur in 2016 (the reporting year) but not necessarily within the 90 days (reporting period) may count towards the measure report
        • Example: A provider may choose to report October-December as their 90 day reporting period but a Direct Message that was sent in January for a patient seen October-December would count towards the measure report because the action occurred during the reporting year, 2016
    • Important Note: any reference to “reduced measure thresholds” apply to hospitals and CAHs ONLY
      • In other words, the Modified Stage 2 percentage thresholds for Eligible Professionals (EPs) are not proposed or subject to any change

Proposals Impacting First Time MU Participants in 2017:

• Proposal to Require Modified Stage 2 for First Time MU Participants in 2017
  • Original Premise: The Certified EHR system version you use during a reporting period determines whether you report on Modified Stage 2 or Stage 3
    • For the 2017 reporting period, NextGen expects to continue utilizing 2014 CEHRT edition to reduce unnecessary upgrades and workflow disruptions
      
  • Proposal
    • The following applies ONLY to any providers who have not previously participated in Meaningful Use and will be doing so for the first time in 2017
      • Providers who have previously attested for MU before: this section does not apply as these providers will not participate in Meaningful Use in 2017 since they will be working on MIPS
    • Under this proposal, providers who have not previously participated in Meaningful Use and will be doing so for the first time in 2017 will report on Modified Stage 2 in 2017, regardless of which CEHRT edition
      
• Proposed Significant Hardship Exception for First Time MU Participants Transitioning to MIPS in 2017
  • Background
    • Normally, penalties are based on a 2 year look back period
      • However, as established in the 2015 EHR Incentive Programs Final Rule, “first timers” (providers who have not participated in MU previously) have a special opportunity to avoid the 2018 payment adjustment by attesting to Meaningful Use in 2017 (for a 90-day EHR reporting period in 2017)
      • Attestation must occur by October 1, 2017
    • 2017 is also the first participation year for all providers in the MIPS program (from our understanding, all other providers who have participated in MU before would only need to participate in MIPS)
  • Proposal
    • Applies ONLY to any providers who have not previously participated in Meaningful Use previously and will be doing so for the first time in 2017
    • These “first time” providers are required to participate in both Meaningful Use (as a part of the EHR Incentives Program) and MIPS, however CMS is proposing the following:
      

 

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