12-month extension of meaningful use reporting criteria in 2014 policy proposal & policy...
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12-Month Extension of Meaningful Use Reporting Criteria in 2014
Policy Proposal&
Policy Alternatives
• CHIME Response to REBOOT white paper – May 2013– Defended the federal incentive program’s progress to date– Agreed on report criticisms over a lack of standards– Declared that a one-year extension of Meaningful Use
Stage 2 would “maximize the opportunity of program success.” • Additional 12-months for meeting Stage 2 will give:
– Providers: Optimize EHR technology – Vendors: prepare, develop and deliver needed technology– Policymakers: time to assess and evaluate programmatic trends
19 June 2013 2
CHIME “Reboot” Response
19 June 2013 3
• Timing crunch– Drive disparities– Compromise interoperability– Jeopardize $30 billion in taxpayer investments
• In order to maximize the opportunity of program success:– Maintains MU momentum– Relieves pressure in 2014– Provides relief from penalties
CHIME Rationale
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Stage 1 Stage 2 Stage 3
2011 2014 2016
Current Policy
19 June 2013
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1st
Year
Current Policy: Stages of Meaningful Use
2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
2011 1* 1 1 2* 2 3 3 TBD TBD TBD TBD2012 1* 1 2* 2 3 3 TBD TBD TBD TBD2013 1* 1R* 2 2 3 3 TBD TBD TBD2014 1R* 1R 2 2 3 3 TBD TBD2015 1R* 1R 2 2 3 3 TBD2016 1R* 1R 2 2 3 32017 1R* 1R 2 2 3
*= 90-day reporting period (quarter-based in 2014, unless first 1)R = Revised Stage 1 (2014 Edition CEHRT)
= 2014 Edition CEHRT
Current Policy
19 June 2013
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Current Policy
19 June 2013
From a practical perspective:• 3,000+ hospitals will upgrade to Stage 2 or
Revised Stage 1• 226,000+ eligible professionals will upgrade to
Stage 2 or Revised Stage 1• 4 complete EHRs meet 2014 Edition
certification criteria (in-patient setting, 7/2/13)
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1st Year
CHIME Proposal A
2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
2011 1* 1 1 2* 2 3* TBD TBD TBD TBD
2012 1* 1 2* 2 3* TBD TBD TBD TBD2013 1* 1R* 2* 2 3* TBD TBD TBD2014 1R* 1R 2* 2 3* TBD TBD2015 1R* 1R 2* 2 3 3* TBD2016 1R* 1R 2* 2 3* 32017 1R* 1 2* 2 3*
* = 90-day reporting period (quarter-based in 2014 or 2015)R = Revised Stage 1
= 2014 Edition CEHRT
CHIME Proposal A Detailed
19 June 2013
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• Provides needed flexibility to maximize Stage 2 participation, while easing the transition to Stage 2– CMS could give providers an additional four quarters to attest to their
required 2014 Stage (either Stage 2 or Stage 1 Revised)• Increases chances of success without compromising momentum
– CMS would keep the October 1, 2013 start date for Stage 2 and Revised Stage 1
– CMS would not pay providers until they had met meaningful use objectives and measures, but could pay incentives for both 2014 and 2015 based off a single reporting period
– CMS could apply payment adjustments retroactively to those providers starting in 2014 if they fail to attest during any quarter 2015
CHIME Proposal A Detailed
19 June 2013
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1st
Year
CHIME Proposal B
2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
2011 1* 1 1 2* 2** 3* 3 TBD TBD TBD TBD2012 1* 1 2* 2** 3* 3 TBD TBD TBD TBD2013 1* 1R* 2** 2 3 3 TBD TBD TBD2014 1R* 1R** 2* 2 3* 3 TBD TBD2015 1R* 1R 2* 2 3* 3 TBD2016 1R* 1R 2* 2 3* 32017 1R* 1R 2* 2 3*
*= 90-day reporting period (quarter-based from 2014 through Q2 2015)** = 180-day reporting period (quarter-based in 2015)R = Revised Stage 1
= 2014 Edition CEHRT
CHIME Proposal B Detailed
19 June 2013
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• Provides similar flexibility to maximize Stage 2 participation, while easing the transition to Stage 2
• Increases chances of success without compromising momentum– Same as Proposal A– Keeps Stage 3 start in FY / CY 2016
• Pushes providers to reach more difficult levels of achievement in consecutive years– CMS could require an addition time period (90 or 180 days) worth
of reporting to satisfy Incentive requirements in 2015– If providers beginning in 2014 fail to attest during the first two
quarters of 2015, they would be subject to payment adjustments
CHIME Proposal B Detailed
19 June 2013
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1st Year
CHIME Alternative Proposal A
2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021
2011 1* 1 1 2** 2 3* TBD TBD TBD TBD2012 1* 1 2** 2 3* TBD TBD TBD TBD2013 1* 1R** 2* 2 3* TBD TBD TBD2014 1R** 1R 2* 2 3* TBD TBD2015 1R* 1R 2* 2 3 3* TBD2016 1R* 1R 2* 2 3* 32017 1R* 1 2* 2 3*
* 90-day reporting period (quarter-based)R = Revised Stage 1 (2014 Edition CEHRT)** = Eligible for incentive payments in 2014 & 2015, if two reporting periods are submitted across both years; no payment adjustments if only one successful attestation in 2015
= 2014 Edition CEHRT
CHIME Alternative Proposal A Detailed
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Alternative to CHIME Proposal A – How to Avoid Procrastination?One potential shortfall of Proposal A is that providers (or developers) use the additional time unwisely and simply procrastinate, thus leading toward a similar situation in 2015.
“Alternative Proposal A” would:• Require providers in any stage to complete a reporting period of
one quarter prior to 2016 to receive their 2014 payment (same as with Proposal A). But by completing any two quarters submitted across both 2014 and 2015, they would receive both their 2014 and 2015 payments.
CHIME Alternative Proposal A Detailed
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Tactics: • 2014 Certification Rule (ONC jurisdiction) stays as is• Meaningful Use Stage 2 Rule (CMS jurisdiction) is changed to allow providers an
additional 12 months, or four quarters, to attest to their required stage in 2014• Providers who meet requirements in 2014 are eligible for incentives in 2014
– This cohort of providers are then eligible to demonstrate again in 2015• Providers who need additional time beyond 2014 are allowed that additional time,
but are only eligible for one (1) payment across both 2014 and 2015
Benefits:• Providers are encouraged to attest as soon as they are able • Exemplar providers are enabled to implement requirements early in 2014 and share
their experience for the good of the program • Current program timelines / momentum are maintained while distributing the
strain of conversion of vendor product and physician workflow over a 21-month period rather than a 9-month period
• These changes would not need additional legislation
CHIME Alternative Proposal A Detailed
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Sharon Canner, Sr. Director of Public Policy,
CHIME [email protected]
(703) 562-8834
Jeff Smith, M.P.P.Director of Public Policy
(703)562-8876
Questions?