The change is expected and welcomed. At the March HIMSS18 conference, CMS Administrator Seema Verma announced plans to overhaul MU in response to stakeholder feedback. CMS views this overhaul as an opportunity to make MU "stage-less" by moving beyond the Stage-specific requirements. Further, they look to recast the focus of the program on interoperability and patient access to health information.
Here are our top three takeaways from the MU overhaul:
- Rebranded MU to PI. The new name accomplishes CMS's goal to change the focus from EHR incentives (which have largely dried up) to promoting interoperability. As proposed, CMS intends to apply the substantial changes proposed in the PI program to only Medicare eligible hospitals (EHs) and critical access hospitals (CAHs). State Medicaid programs have the option to overhaul MU as proposed in the PI program or keep existing Stage 3 requirements in place for Medicaid-only hospitals. CMS also seeks comment on how to treat Medicaid eligible professionals in light of the new proposal.
- Refreshed MU Measures. The original Stage 3 MU measures are refreshed and reduced in number. Some measures are proposed to be eliminated entirely, and some new measures are introduced (e.g., use of prescription drug monitoring programs to combat the nation's opioid crisis). Most hospitals will be relieved to hear that nearly all the patient-action oriented measures are removed in the PI program (e.g., View, Download, and Transmit Health Information and Patient Generated Health Data). Hospitals have been challenged to engage patients in the use of their health information online, as certain populations are unable or unwilling to do so.
- Reconfigured Scoring Method. The overhaul includes significant changes to how CMS determines whether a hospital meaningfully uses certified EHR technology. CMS proposes a performance-based scoring method instead of their previous all-or-nothing-thresholds. This allows hospitals to focus performance on applicable measures. EHs/CAHs must earn a total of 50 or more points out of 100 to be considered a "meaningful EHR user."
We expect CMS will finalize their proposals to adopt the PI program requirements later this year, with the changes effective beginning January 1, 2019. In the meantime, CMS proposes no changes to the 2018 program year. Hospitals have until June 25, 2018 to submit public comment on the policies for 2019 and beyond. If hospitals agree with these proposals, they should lend their support—or take the time to detail specific changes.