CMS Meaningful Use Definition Impact on Rural Providers
by Louis Wenzlow, Rural Wisconsin Health Cooperative CMS Rule: Meaningful Use Definition Impact on Rural Providers Under the American Recovery and Reinvestment Act (ARRA), eligible physicians and hospitals must reach a certain threshold of EHR adoption (called "meaningful EHR use") in order to earn CMS incentive payments. In July, the ARRA-established HIT Policy Committee recommended a wide range of meaningful use objectives for CMS to consider in the development of a proposed HIT incentive rule. Released on December 30th, the proposed rule largely follows the Policy Committee's recommendations. So how will the proposed rules meaningful use requirements impact rural providers? How long will providers have to achieve the meaningful use thresholds? And are these timing requirements reasonably achievable by small and rural providers? CMS Proposed Definition of Meaningful Use Consistent with HIT Policy Committee recommendations, the CMS proposed rule creates 3 stages between 2011 and 2015 over which providers will need to meet increasingly stringent meaningful use requirements. The proposed rule identifies the requirements associated with Stage 1. Providers that reach Stage 1 meaningful use by the end of 2012 will maximize the value of their incentive. Providers that meet Stage 1 requirements by 2014 can still receive some level of incentive (see next section for detail regarding how this works). The definition of Stage 1 meaningful use in the CMS proposed rule is similar to the definition established by the HIT Policy Committee in July. The major differences are:
- 2 HIT Policy Committee recommended requirements (record advance directives, and provide access to patient-specific educational resources) have been removed
- The HIT Policy recommendation to implement 1 clinical decision support rule has been increased to 5
- The information exchange requirement has been qualified so that it is allowable to exchange unstructured information, and the requirement can be met through a test of an EHRs "capacity" to exchange
- Specific measures have been defined for each one of the 20+ requirements
- Numerous quality measures have been defined (I will be dealing with how the quality measures impact rural providers in a separate analysis)
- Eligible professionals and hospitals whose first payment year is 2011 must meet stage 1 requirements in 2011 and 2012, stage 2 requirements (not yet defined) in 2013 and 2014, and stage 3 requirements (not yet defined) in 2015.
- Eligible professionals and hospitals whose first payment year is 2012 must meet stage 1 requirements in 2012 and 2013, stage 2 requirements in 2014, and stage 3 requirements in 2015.
- Eligible professionals and hospitals whose first payment year is 2013 must meet stage 1 requirements in 2013, stage 2 requirements in 2014, and stage 3 requirements in 2015.
- Eligible professionals and hospitals whose first payment year is 2014 must meet stage 1 requirements in 2014, and stage 3 requirements in 2015
- Eligible professionals and hospitals whose first payment year is 2015 must meet stage 3 requirements in 2015