Last week, the Centers for Medicare and Medicaid Services (CMS) released a new rule proposal meant to “align Stage 1 and Stage 2 objectives and measures with the long-term proposals for Stage 3, to build progress toward program milestones, to reduce complexity, and to simplify providers’ reporting.” So far, reaction from those inside the healthcare industry has been mixed, with some saying the proposed rule oversimplifies requirements and caters to specific categories of providers, while others applaud CMS efforts to streamline and consolidate sprawling objectives and reign in redundancies.
But what does it all mean for the imaging sector?
Michael Peters, American College of Radiology Director of Regulatory and Legislative Affairs, detailed the implications of the proposed rule in a recent blog post for Radiology and Health IT. In addition to aligning the reporting period with the calendar year and expanding the period to 90 days to allow providers to adjust to the new requirements, the new rule eliminates “core” and “menu” objectives in favor of 10 universal Stage 2 objectives:
1. Protect health information/HIPAA
2. Enable CDS functionality
3. Meds, labs, and radiology orders captured using CPOE
5. Summary of care creation/transmittal for transitions of care and referrals (modified)
6. Patient specific educational resources
7. Medications reconciliation for received transitions of care
8. View/Download/Transmit (modified to reduce reliance on patient action)
9. Secure electronic messaging (modified to only require enabling the functionality)
10. Public health/registries (modified to consolidate the registry-related objectives – choose to actively engage with 2 or 1 registries depending on MU Stage)
“As proposed, most diagnostic radiologists would likely need to complete the measures of four total MU objectives,” wrote Peters, “(1) protect health information, (2) CDS, (8) patient view/download/transmit (if exclusion not met), and (10) public health/registries (if exclusions not met).”
The biggest changes of interest to radiologists in the proposed rule revolve around the Stage 2 “imaging results access” objective, which would be eliminated altogether under the new requirements, and updated language regarding the categorization of patient referrals. “Although it is unclear if this was intended by CMS, the proposed language appears to separately define and no longer explicitly include referrals as transitions of care in the ‘medications reconciliation’ objective,” Peters wrote. “On the flip side, referrals would be included alongside transitions of care in the “summary of care” objective for referring providers.”
Other items affecting radiologists, including clinical quality measure reporting and significant hardship exceptions, are largely unchanged under the newly proposed rule.
CMS will accept comments on the new rule proposal over the next 60 days before drafting a final version for implementation. Read the full text of the proposed rule for more information and instructions on how to add your comments for consideration.