Earlier this month, the Centers for Medicare & Medicaid Services (CMS) posted an FAQ webpage on their site with the aim of clarifying the Public Health Reporting Objective (PHRO) Alternate Exclusions for EPs and hospitals that are attesting to Stage 1 and Stage 2 of Meaningful Use in 2015.
According to the CMS website:
We do not intend to inadvertently penalize providers for their inability to meet measures that were not required under the previous stages of meaningful use. Nor did we intend to require providers to engage in new activities during 2015, which may not be feasible after the publication of the final rule in order to successfully demonstrate meaningful use in 2015.
In the final rule at 80 FR 62788, we discuss our final policy to allow for alternate exclusions and specifications for certain objectives and measures where there is not a Stage 1 measure equivalent to the Modified Stage 2 (2015 through 2017) measure or where a menu measure is now a requirement. This includes the public health reporting objective as follows.
First, EPs scheduled to be in Stage 1 may attest to only 1 public health measure instead of 2 and eligible hospitals or CAHs may attest to only 2 public health measures instead of 3. Second, we will allow providers to claim an alternate exclusion for a measure if they did not intend to attest to the equivalent prior menu objective consistent with our policy for other objectives and measures as described at 80 FR 62788.
In order to give our readers a quick understanding, here is an outline of the 2015 Alternate Exclusions for the Public Health Reporting Objective (EPs only):
- EPs Scheduled for Stage 1 Attestation: EPs must attest to at least one measure from PHRO Measures 1, 2, or 3
o EPs may claim Alternate Exclusion for Measure 1, 2, or 3
o EPs may only claim Alternate Exclusion for no more than two measures, and must either attest to or meet the exclusion requirements for the remaining measure as described in article 495.22 (e)(10)(i)(C)
- EPs Scheduled for Stage 2 Attestation: EPs must attest to at least two measures from PHRO Measures 1, 2, or 3
o EPs may claim Alternate Exclusion for either Measure 2 or Measure 3
The above information is up-to-date as of October 21st, so keep in mind that additional changes may come later. For the present moment, however, this is where the CMS stands on Meaningful Use exclusions for this year. Hopefully, these exclusions will take at least a little stress off the shoulders of those healthcare providers who have been growing increasingly concerned (and for good reason) about whether they’d be required to meet all the new measures in the proposed Meaningful Use Final Rule.
Well, there’s good news for those folks… they don’t have to do all of them.
