MU Stage 3 - Final Rule comments requested

tmccormi wrote on Wednesday, November 25, 2015:

Remember to Comment on Stage 3 Final Rule
CMS invites the public to submit comments on certain provisions of the Medicare and Medicaid EHR Incentive Programs Stage 3 final rule. Submit comments electronically at https://www.regulations.gov by Tuesday, December 15, 2015 at 11:59 PM EST. Comments submitted by regular, express, overnight mail, or courier are due no later than 5:00 PM EST on December 15.

aethelwulffe wrote on Saturday, December 12, 2015:

My comment: My, a bit of light reading!

tmccormi wrote on Friday, December 18, 2015:

The Office of the National Coordinator (ONC) has released updated draft 2015 Edition test procedures for ePrescribing (b3), Direct Project (h1), and Direct Project, Edge Protocol, and XDR/XDM (h2). They have also released the Automated Measure Calculation/Numerator Recording (g1-2) test procedures and test data. All documents can be located at http://confluence.oncprojectracking.org/display/ONCCERT2015/ONC+Health+IT+Certification+Program+2015+Edition+Test+Methods+Home.

Public comments will be accepted through December 31st and we strongly encourage you to review these documents, as some of them have significantly changed from their first iteration. Of particular significance is the following:

170.315(h)(1) Direct Project
§ Must provide evidence that the SUT is able to successfully send encrypted and signed health information to 3 partner HISPs

§ Must provide evidence that the SUT has successfully received encrypted and signed health information from 3 partner HISPs

170.315(h)(2) Direct Project, Edge Protocol, and XDR/XDM
§ Must provide evidence that the SUT is able to successfully send encrypted and signed health information to 3 partner HISPs for each protocol (Direct, Edge, XDR/XDM)

NOTE: The partner HISPs that you use for h1-2 evidence will not be provided by the ONC or necessarily by the Accredited Test Lab (ATL). These are vendor partners that you would need to connect with prior to the certification test and collect the evidence specified in the test procedure. This evidence would then be reviewed and approved by your ATL to determine conformance.

You may submit comments directly to the ONC by clicking on the blue “Submit a Comment” button at the top of each test procedure. You can also view comments already submitted by others by scrolling to the very end of the page. Should you also like to share your thoughts with ICSA Labs, you can do so by responding to this email.

aethelwulffe wrote on Friday, January 01, 2016:

Hardship just signed into law.
Things continue to change.
Who shall volunteer to be on the OEMR MU3 committee?
Please tender your point of contact information to: secretary at oemr dot org.

tmccormi wrote on Saturday, January 02, 2016:

Eligible Professional (EP) Hardship Exception Application

The deadline for Eligible Professionals to submit hardship applications for the 2017 payment adjustment, based on the 2015 EHR reporting period is July 1st, 2016. For more information see the EP tip sheet.

Exerpt:
**Hardship Exceptions for Medicare Eligible Professionals
**EligibEligible Professional (EP) Hardship Exception Application

The deadline for Eligible Professionals to submit hardship applications for the 2017 payment adjustment, based on the 2015 EHR reporting period is July 1st, 2016. For more information see the EP tip sheet.le professionals may apply for hardship exceptions to avoid the payment adjustments described
above. Hardship exceptions will be granted only under specific circumstances and only if CMS
determines that providers have demonstrated that those circumstances pose a significant barrier to
their achieving meaningful use. Information on how to apply for a hardship exception will be posted on
the CMS EHR Incentive Programs website in the future.
EHR Reporting Period 2014 2015 2016
3
Eligible professionals can apply for hardship exceptions in the following categories:
 Lack of Infrastructure: Eligible professionals must demonstrate that they are in an area without
sufficient internet access or face insurmountable barriers to obtaining infrastructure (e.g., lack
of broadband).
 Extreme and Uncontrollable Circumstances: Examples may include a natural disaster or other
unforeseeable barrier.
o EHR Vendor Issues: The eligible professional’s EHR vendor was unable to obtain
certification or the eligible professional switched vendors.

 Patient Interaction:
o Lack of face-to-face or telemedicine interaction with patient
o Lack of follow-up need with patients
Practice at Multiple Locations: Lack of control over availability of CEHRT for more than 50% of
patient encounters.

aethelwulffe wrote on Saturday, January 02, 2016:

This doesn’t sound like a set of exceptions that is going to “kill Medicare” as I heard some people wailing. Outside of a doctor practicing in a stilt house in the middle of the Okefenokee swamp, one on the banks of Lake Houston (I mean the city of Houston…) or someone using some fly-by-night open-source EMR, it sounds like those that simply didn’t bother moving forward will indeed feel the crunch. Of course, that whole supposition was based on Medicare somehow actually needing the savings from the penalties to stay afloat.