There's been a lot of hoopla about the Stage 2 proposed rule's impact on patient engagement, health information exchanges and quality improvement. But what has received relatively little attention is that the Centers for Medicare & Medicaid Services is considering adding a new exemption from the payment adjustment for certain eligible professionals (EPs) who, based on their particular practices, will struggle to meet Stage 2 of Meaningful Use.
Under the incentive program, EPs who don't successfully meet the Meaningful Use criteria will be subject to a "payment adjustment" of 1 percent in 2015, 2 percent in 2016 and 3 percent in 2017. The proposed rule outlines three categories of exceptions for EPs: lack of internet/IT, new EPs, and unforeseen circumstances (such as a natural disaster).
But CMS is soliciting comment on a fourth exception, Tony Mira, president and CEO of Miramed Global Services, points out in a recent blog post. The fourth exception consists of "a combination of clinical features limiting a provider's interaction with patients and lack of control over the availability of Certified EHR technology at their practice locations." The criteria for these EPs includes:
- Lack of face-to-face/telemedicine interaction with patients
- Lack of follow up with patients
- Lack of control over the availability of certified EHRs at their practice locations.
CMS also wants to know if this potential exception should have a two year shelf life, and how soon EPs who fit this category could reasonably meet Meaningful Use. Mira says the exception could be welcome news for physicians such as radiologists, anesthesiologists and others, who don't meet the "hospital-based" exception from the incentive program but who won't meet the use thresholds, and for whom the critical quality measurements are not "relevant."
"The EHR incentive program is targeted at office-based practices," he points out.
The deadline for submitting comments on the proposed rule is May 7.