In today’s outpatient prospective payment system final rule, the Centers for Medicare & Medicaid Services sets the requirements for eligible hospitals and critical access hospitals to attest to meaningful use of electronic health records in the coming years. CMS finalizes a 90-day reporting period in 2016 and 2017, eliminates two objectives and measures beginning in 2017 and reduces the thresholds for some objectives and measures. For example, CMS revises the threshold for the View, Download or Transmit measure to at least one patient for Modified Stage 2 and Stage 3. CMS retains Stage 3 requirements to use new functionality, such as application programming interfaces, and new reporting requirements, such as clinical information reconciliation. CMS also retains the all-or-nothing approach that requires hospitals and CAHs to attest to all of the objectives and measures, and starts Stage 3 in 2018 with a full-year reporting period. “We are pleased to see some greater flexibility on the Meaningful Use program as hospitals work to optimize health information technology that facilitates high-quality care for patients,” said Ashley Thompson, AHA senior vice president for public policy analysis and development. “Specifically, we are encouraged to see CMS include a 90-day reporting period for 2016 and 2017 and an adjustment in some of the reporting requirements. However, the changes do not sufficiently align the hospital requirements with those that physicians will face under the Medicare Quality Reporting Program. We are disappointed that CMS finalized a mandatory start of Stage 3 in 2018. Additionally, we remain concerned about requirements for providers to provide third-party access to their systems through application program interfaces without evidence that a relevant standard is ready for nationwide use and despite concerns that this will create security risks.”

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