As most in the medical profession know, "meaningful use" refers to use of certified electronic health record (EHR) technology. Implemented in 2011, meaningful use has had three stages: Stage 1 ran from 2011 to 2013, Stage 2 began in 2014 and Stage 3 began in 2016.
Each stage has overall objectives. For Stage 1, the objective was data capture and sharing; for Stage 2, it was advanced clinical processes; and for Stage 3, the objective is improved outcomes.
It's Complicated
The Medicare Access and CHIP Reauthorization Act (MACRA) essentially replaces the current meaningful use criteria starting in 2017, which complicates matters. There are two ways to participate in MACRA: 1) the Alternative Payment Model (APM), and 2) the Merit-based Incentive Payment System (MIPS).
Providers who do not meet the qualifications for the APM — that is, through participation with an Accountable Care Organization (ACO) — will automatically default to the MIPS program.
Components and Compliance Options
Each of four components is weighted and, taken together, generate a provider's unique composite score. The components are quality (formally, Physician Quality Reporting System [PQRS], but now consisting of only six measures), weighted at 50%; improvement activities (formally, meaningful use), weighted at 25%; advancing care information, weighted at 15%; and cost (waived in 2017), weighted at 10%.
The composite score ultimately determines the provider's fee schedule and is posted on the Centers for Medicare and Medicaid Services (CMS) website. The CMS will exempt physician practices with less than $30,000 in Medicare charges or fewer than 100 Medicare patients per year. MIPS provides three compliance options for 2017:
- Test
If you submit a minimum amount of 2017 data to Medicare (for example, one quality measure or one improvement activity for any point during the year), you can avoid a downward payment adjustment. - Partial
If you submit 90 days of 2017 data to Medicare, you may earn a neutral or positive payment adjustment. - Full
If you submit a full year of 2017 data to Medicare, you may earn a positive payment adjustment.
The size of your payment will depend both on how much data you submit and your performance results.
Final Ruling
In October 2016, the CMS published a final ruling for meaningful use that carries through 2017. The rule also has provisions that encompass Stage 3 in 2018 and beyond.
For instance, there is a 90-day reporting period for new participants in 2016 and 2017, and for any provider moving to Stage 3 in 2017. According to the CMS, "New participants who successfully demonstrate meaningful use for this period and satisfy all other program requirements will avoid the payment adjustment in Calendar Year 2018 if the eligible professional (EP) successfully attests by October 1, 2017."
In addition, there are 10 objectives for EPs, including one public health reporting objective. This is down from the 18 total objectives required in earlier stages. The Clinical Quality Measures (CQM) reporting requirements for EPs remain the same as previously finalized.
And in 2017, the Stage 3 requirements are optional. All providers will be required to comply with Stage 3 requirements starting in 2018 using EHRs certified to the 2015 Edition.
Stage 2 Tweaks
Stage 2 objectives and measures have been tweaked for 2017 to align more closely with the forecasted Stage 3 requirements of meaningful use. Notable provisions include eight objectives for Eps — in Stage 3, more than 60% of the proposed measures require interoperability (up from 33% in Stage 2). In addition, public health reporting has flexible options for measure selection, and CQM reporting aligns more closely with the CMS quality reporting programs and has finalized the use of application program interfaces (APIs) that will enable the development of new functionalities to build bridges across systems. These changes are expected to improve data access and efficiency.
Uncertain Future
It is also worth noting that, on November 30, 2016, the American Hospital Association contacted then-President-elect Donald Trump to ask that his administration cancel Stage 3 of the meaningful use program. With the Republican-controlled House sending "repeal and replace" legislation to the Senate, there is some uncertainty surrounding meaningful use requirements. Contact your CPA for the latest updates.
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