Tuesday, October 6, 2015

The CMS and ONC Final Rules Arrive

Steve Posnack from ONC declared today IT Bonanza Day.   The Interoperability Roadmap, CMS Meaningful Use Final Rules with a Comment Period (Stage 2 and 3) as well as the ONC 2015 Certification Rule were published today.

Here are a few resources to help you navigate these rules

A press release for today’s announcement 

For more detailed information about today’s announcement

For more information on the CMS final rule with comment period

For more information on the ONC final 2015 Edition Certification Rule

The EHR Incentive Programs final rule itself

The 2015 Edition Certification final rule itself 

Here’s my first impression:

It remains to be seen how the comment period on the EHR Incentive Programs final rule will be used to align the Meaningful Use program  with the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) effort.    It would not surprise me that the CMS final rules are not really final.

There will be one Meaningful Use rule that will cover 2016 to 2018 both modifications (to Stage 2) and Stage 3.

The final rules are not substantially different than the proposed rules, but the thresholds have been reduced.   Given that existing certified EHRs were created to support the previous  Stage 2 thresholds, I'm guessing vendors will have to modify code to support the changes.  

2017 will still be an optional Stage 3 reporting year.   2015 will be a 90 day reporting period for everyone.

Quality measures have not changed, but the industry will have to support other initiatives in merit-based performance that have requirements.

In the upcoming days, I will review the certification criteria in detail.   Immature standards such as HPD for provider directory query have been removed.  Others such as DS4P for data segmentation are included but are not required.

CMS and ONC have incorporated many of the changes requested by professional organizations and expert commentators, which is a good thing.

I'll post details and briefs on these rules in the next week.

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