CMS Seeks More Changes to MU Stages 1 and 2

The Centers for Medicare and Medicaid Services late in the day on April 10 came out with yet another proposed rule to make modifications that will ease compliance with Stages 1 and 2 of the electronic health records meaningful use program.

The goal of the rule is to reduce burdens on providers while focusing more on advanced use of EHRs to support health information exchange and quality improvement, according to CMS.

The American Hospital Association took a quick look at the 210-page rule and issued a mixed early review. “The shortened reporting period that the Centers for Medicare and Medicaid Services proposes gives hospitals more time to transition to Stage 2 and increases the likelihood they will meet CMS’s timetable. However, the inclusion of numerous additional program changes at this late date risks causing confusion and added burden for hospitals on top of the elements proposed in the Stage 3 rule.”

Also See: Medicaid EPs Growing, But Medicare EPs Attesting at Higher Rate

The rule changes the reporting periods to attest for meaningful use, substantially scales back several Stage 2 measure thresholds, and eliminates the need to report multiple measures as conducting these measures has essentially become common practice. “In this proposed rule, we are seeking to make changes to the requirements for Stage 1 and Stage 2 of meaningful use for 2015 through 2017 to align with the approach of Stage 3 of meaningful use in 2017 and subsequent years,” CMS says in the rule.

The changes are an attempt to address concerns about program complexity, the agency adds. For instance, the proposed rule would change the reporting period for hospitals from the fiscal year to the calendar year starting in 2015.

In 2015 only, eligible professionals—regardless of the stage they are in—can attest to a reporting period in any continuous 90-day period within the calendar year. Also, new participants in 2015 and 2016 can attest in any reporting period of 90 continuous days within the calendar year.

All participating providers demonstrating meaningful use for the first time in 2016 can use any continuous 90-day reporting period during the year. All returning participants would have a full calendar year reporting period in 2016. Finally, all participants—new and existing—would have a full calendar year reporting period in 2017, except for those attesting for Medicaid for the first time.

Changes to Measures

Stage 2 measures made easier under the proposed rule include:

*Changing the threshold for the Patient Electronic Access measure from 5 percent to “equal to or greater than 1.”

*Changing Secure Electronic Messaging from a percentage-based measure to a yes-no measure on whether the messaging capability is “functionally fully enabled.”

*Consolidating all public health reporting objectives into a single objective with measure options following the structure of the Stage 3 public health reporting objective.

*Changing the hospital electronic prescribing objective from a “menu” item to mandatory, with exclusions possible for certain hospitals.


Beginning in 2015, the following objectives and measures are considered redundant, duplicate or “topped-out,” meaning they have substantially been adopted and therefore are no longer required to attest to:

Eligible Professionals: Record demographics, vital signs and smoking status; clinical summaries, structured lab results, patient list, patient reminders, summary of care (Measure 1 – Any Method and Measure 3 – Test), electronic notes, imaging results and family health history.

Hospitals: Record demographics, vital signs and smoking status; structured lab results, patient list, summary of care (Measure 1 – Any Method and Measure 3 – Test), eMAR, advanced directives, electronic notes, imaging results, family health history, and structured labs to ambulatory providers.

The rule is available here and will be officially published on April 15.

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