On March 20, 2015, the Department of Health and Human Services’ (HHS) Centers for Medicare & Medicaid Services (CMS) issued a proposed rule for Stage 3 of the Medicare and Medicaid Electronic Health Record (EHR) Incentive Programs. Stage 3 raises the bar for all providers, increasing some existing threshold measures from Stage 2 and proposing aggressive timelines for attestation. The new rules require providers to meet rigorous qualifications, and all eligible Medicare and Medicaid providers (EPs) must attest to meaningful use Stage 3 by 2018. While financial incentives are tapering off for meaningful use, the implication is clear. The penalty phase is about to begin in earnest. Starting in January 2015, nearly 257,000 eligible professionals (EPs) – or half of all EPs - will face a one percent cut to their Medicare reimbursements for not meeting meaningful use standards, according to CMS.
Many provider organizations, including ophthalmology and dermatology practices, will have to contend with increased thresholds that may prove difficult. Ophthalmologists are concerned about meeting the new proposed threshold stating that 25 percent of patients must "actively engage" with their electronic records. These practices treat many patients who are elderly and often have vision challenges, making active engagement with electronic records potentially very challenging.
Dermatology practices have a range of concerns, in part due to the specialty nature of their work. The American Academy of Dermatology Association (AADA) noted one of their concerns with meaningful use Stage 3 as, “The AADA is concerned that many of the measures are structured to fit into national health priorities, but not all specialists fit this mold. Accordingly, the AADA urges the Health Information Technology Policy Committee (HITPC) to look at specialties and make meaningful use requirements more inclusive by tailoring measures for specialties to allow all to participate fully."
The proposed rules have garnered both praise and disparagement among industry leaders. For example, the College of Healthcare Information Management Executives (CHIME) has been generally positive in their reaction, stating, “Based on our initial review, we are pleased to see flexibility built into the Stage 3 proposed objectives.” However, the American Hospital Association is less enthusiastic, stating, “It is difficult to understand the rush to raise the bar yet again, when only 35 percent of hospitals and a small fraction of physicians have met the Stage 2 requirements”. All stakeholders are invited to comment until May 29, 2015, so there is still time to voice your opinion or concerns.
While meaningful use Stage 3 introduces some challenges, Nextech is strongly committed to helping specialty practices with attestation. In fact, Nextech physicians have earned over $14 million in incentive payments to date. With a combination of great support and solutions designed for specialty practices – don’t panic – we have you covered.