The Medicare and Medicaid Electronic Healthcare Record (EHR) Incentive Program is likely to change significantly in the next two years.
Providers, whether they are eligible hospitals, critical access hospitals, or eligible professionals (the category in which doctors of chiropractic fall), will want to pay attention to proposed changes and stay abreast of how those changes may impact their own practices.
Chiropractic practices participating in the incentive program are quite possibly wrangling with the requirements for demonstrating meaningful use (MU) stage 2, using the CMS’ interactive timeline tool and the various worksheets and other resources the agency provides. Some may even still be shopping for an appropriate EHR and working to implement the system. It is unlikely that many DCs are ready to consider how recently proposed changes to stage 3 could impact their practices. However, it is always best to be prepared and know what to expect.
On March 30, 2015, the Federal Register released a proposed rule regarding stage 3. This proposed rule is supposed to make meeting the requirements of stage 3 more flexible and more streamlined.1
Perhaps the biggest change is that stages would be eliminated. In 2017, providers can participate in stage 1, 2, or 3, but by 2018, all providers would need to be in stage 3.2 Eliminating the stages should certainly simplify the process; however, for those just getting started, jumping from stage 1 to stage 3 could pose some difficulties. The best way to avoid having to make that leap is to get started sooner rather than later.
One of the more confusing aspects of the incentive program as it stands now is the way the reporting periods are set up. The proposed changes would eliminate the current 90-day reporting periods. Everything would move to a single, calendar-year reporting period beginning in 2017.
The number of criteria that providers are required to meet would be reduced, according to the proposed rule. The idea behind this change is to eliminate those criteria that are adopted at the highest rates—the things that almost everyone is already doing. The reduced number of criteria also reflects the agency’s plan to focus on just eight core objectives.3
Objectives and measures
The streamlined objectives are:
- Protect patient health information
- Electronic prescribing
- Clinical decision support
- Computerized provider order entry
- Patient electronic access to health information
- Coordination of care through patient engagement
- Health Information exchange
- Public health and clinical data registry reporting
While, some of those objectives may not apply to DCs, the overarching goal is to make the entire healthcare system more interoperable. In other words, the patient’s record will reflect the entire range of healthcare received, including chiropractic care.
1 Department of Health and Human Services, Centers for Medicare & Medicaid Services. Medicare and Medicaid Programs; Electronic Health Record Incentive Program—Stage 3. Federal Register. 2015;80(60):16732–16804.
2 Patsos C. “CMS Proposes a Single Stage Meaningful Use After 2017 – Attorney Advertising.” Patsos Health Law Blog. http://patsoshealthlawblog.com/2015/04/20/cms-proposes-a-single-stage-meaningful-use-after-2017-attorney-advertising/#_ftn1. Published April 2015. Accessed April 2015.
3 Bowman D. “Meaningful Use Stage 3: A battle for appropriate patient engagement requirements.” Fierce Health IT. http://www.fiercehealthit.com/story/meaningful-use-stage-3-battle-appropriate-patient-engagement-requirements/2015-03-31. Published March 2015. Accessed April 2015.