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CMS Releases Meaningful Use Stage 3 Proposed Rule

March 27, 2015The Centers for Medicare and Medicaid Services (CMS) March 20 issued a proposed rule defining the third stage of “meaningful use” for the Medicare and Medicaid Electronic Health Record (EHR) incentive programs. The proposed rule is expected to be published in the Federal Register on March 30, followed by a 60-day comment period. 

The proposed rule defines the Stage 3 meaningful use requirements that hospitals and eligible professionals (EPs) must meet to avoid downward payment adjustments under Medicare for Stage 3 of the EHR Incentive Program. The criteria CMS proposes for Stage 3 aims at increasing interoperability among EHRs and increasing the focus on patient outcomes to improve care.  

The criteria, effective on an optional basis in calendar year (CY) 2017, would be required of all providers beginning in payment year 2018, regardless of their prior participation in the program. In the rule, CMS eliminates requirements from Stages 1 and 2 that will no longer be relevant for the advanced use of EHRs.

Regarding the clinical quality measure (CQM) requirements, CMS intends to further align the EHR Incentive Program with established physician and hospital quality programs. Many future CQM reporting requirements for EPs will be proposed in the Physician Fee Schedule (PFS) rule, while hospital CQM requirements will be included in the Inpatient Prospective Payment System (IPPS) rule. CMS will continue to encourage electronic submission of CQMs for EPs and hospitals in CY 2017. The proposed rule mandates the electronic submission of CQMs starting in CY 2018.    

Finally, the Stage 3 proposed rule changes the EHR reporting period so that all providers would report under a full calendar year timeline, with a limited exception for Medicaid EPs, and eligible hospitals demonstrating meaningful use for the first time. CMS intends the Stage 3 rule to be the final stage of the meaningful use framework.

Additionally, the Office of the National Coordinator for Health Information Technology (ONC) March 30 released the 2015 Edition Health IT Certification Criteria proposed rule, expected to be published in the Federal Register on March 30, followed by a 60-day comment period.


Len Marquez
Director, Government Relations
Telephone: 202-862-6281


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Jason Kleinman
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Telephone: 202-903-0806