The American Medical Association (AMA), American Hospital Association (AHA), and several other influential providers groups are now coordinating efforts to push the Centers for Medicare & Medicaid Services (CMS) to delay the release of the Stage 3 MU final rule. Anticipation—and for some, anxiety—has been steadily growing since the release of the proposed rule in March and the end of the public comment period in May, with many observers expecting a final rule sometime this fall.
As outlined in the proposed rule, the Stage 3 rule would be mandatory for all providers in 2018, regardless of their previously scheduled stage. With many providers struggling to meet the Stage 2 requirements and Congress holding hearings to consider legislative tweaks to the program, the AMA is asking CMS to officially hit the “pause” button on Stage 3 until these issues can be sorted out. Also at issue is alignment of Stage 3 rulemaking with the implementation of the recently enacted Merit Based Incentive Payment System, set to go into effect in 2017.
The AMA recently conducted a town hall in Georgia where physicians voiced their dissatisfaction with the trajectory of the MU program and more generally, with their experiences with EHRs. In response to these advocacy efforts, Rep. Renee Ellmers (R-NC) recently introduced legislation that would delay the release of the final rule for Stage 3 until at least 2017. (See here, here, and here for more information.)
Impact for NextGen Healthcare clients. Aside from the impact on providers of having to meet new requirements, MU continues to drive extensive software development and certification requirements, many of which are out of step with the priorities expressed by our clients. As proposed, all providers will be required to meet Stage 3 requirements for a full year starting in 2018. While it is impossible to predict accurately, it appears likely that CMS will move for a delay. NextGen Healthcare has actively participated in advocacy efforts aimed at reducing the number of Stage 3 requirements while increasing the timeline for providers and vendors. We have also advocated for removal of proposed functionality not necessary for providers to meet attestation requirements. We encourage you to speak to your legislators as well about limiting requirements so that we can focus more on the enhancements that you have requested and less on regulatory-related functionality.