12-Month Extension of Meaningful
Use Reporting Criteria in 2014
Policy Proposal
&
Policy Alternatives
CHIME “Reboot” Response
• 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 Rationale
• 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
19 June 2013
3
Current Policy
2011
Stage 1
19 June 2013
2014
Stage 2
2016
Stage 3
4
Current Policy
Current Policy: Stages of Meaningful Use
1st
Year 2011 2012 2013 2014 2015 2016 2017 2018 2019
2011 1*
1
1
2*
2
3
3
TBD TBD
2012
1*
1
2*
2
3
3
TBD TBD
2013
1* 1R*
2
2
3
3
TBD
2014
1R* 1R
2
2
3
3
2015
1R* 1R
2
2
3
2016
1R* 1R
2
2
2017
1R* 1R
2
= 2014 Edition CEHRT
2020
TBD
TBD
TBD
TBD
3
3
2
2021
TBD
TBD
TBD
TBD
TBD
3
3
*= 90-day reporting period (quarter-based in 2014, unless first 1)
R = Revised Stage 1 (2014 Edition CEHRT)
19 June 2013
5
Current Policy
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)
19 June 2013
6
CHIME Proposal A Detailed
CHIME Proposal A
1st
Year 2011 2012 2013 2014 2015 2016 2017 2018
1
1
2*
2
3*
TBD
2011 1*
1*
1
2*
2
3*
TBD
2012
1*
1R*
2*
2
3*
2013
1R*
1R
2*
2
2014
1R*
1R
2*
2
2015
1R*
1R
2*
2016
1R*
1
2017
= 2014 Edition CEHRT
2019 2020 2021
TBD
TBD
TBD
3*
3
2
2*
TBD
TBD
TBD
TBD
3*
3*
2
TBD
TBD
TBD
TBD
TBD
3
3*
* = 90-day reporting period (quarter-based in 2014 or 2015)
R = Revised Stage 1
19 June 2013
7
CHIME Proposal A Detailed
• 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
19 June 2013
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CHIME Proposal B Detailed
CHIME Proposal B
1st
Year 2011 2012 2013 2014 2015 2016 2017 2018
2**
1
1
2*
3*
3
TBD
2011 1*
2**
1*
1
2*
3*
3
TBD
2012
2**
1*
1R*
2
3
3
2013
1R**
1R*
2*
2
3*
2014
1R*
1R
2*
2
2015
1R* 1R
2*
2016
1R* 1R
2017
= 2014 Edition CEHRT
2019 2020 2021
TBD
TBD
TBD
3
3*
2
2*
TBD
TBD
TBD
TBD
3
3*
2
TBD
TBD
TBD
TBD
TBD
3
3*
*= 90-day reporting period (quarter-based from 2014 through Q2 2015)
** = 180-day reporting period (quarter-based in 2015)
R = Revised Stage 1
19 June 2013
9
CHIME Proposal B Detailed
• 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
19 June 2013
10
CHIME Alternative Proposal A
Detailed
CHIME Alternative Proposal A
1st
Year 2011 2012 2013 2014 2015 2016 2017 2018 2019
1
1
2**
2
3* TBD TBD
2011 1*
1*
1
2**
2
3* TBD TBD
2012
1*
1R**
2*
2
3* TBD
2013
1R**
1R
2*
2
3*
2014
1R*
1R
2*
2
3
2015
1R*
1R
2*
2
2016
1R*
1
2*
2017
= 2014 Edition CEHRT
2020 2021
TBD
TBD
TBD
TBD
3*
3*
2
TBD
TBD
TBD
TBD
TBD
3
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
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CHIME Alternative Proposal A
Detailed
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.
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CHIME Alternative Proposal A
Detailed
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
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Questions?
Sharon Canner,
Sr. Director of Public Policy,
CHIME
[email protected]
(703) 562-8834
Jeff Smith, M.P.P.
Director of Public Policy
CHIME
[email protected]
(703)562-8876
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