12-Month Extension of Meaningful Use Reporting Criteria in 2014 Policy Proposal & Policy Alternatives

CHIME Response to REBOOT white paper – May 2013 – Defended the federal incentive program’s progress to date – Agreed on report criticisms over a lack of standards – Declared that a one-year extension of Meaningful Use Stage 2 would “maximize the opportunity of program success.” Additional 12-months for meeting Stage 2 will give: – Providers: Optimize EHR technology – Vendors: prepare, develop and deliver needed technology – Policymakers: time to assess and evaluate programmatic trends 19 June CHIME “Reboot” Response

19 June Timing crunch – Drive disparities – Compromise interoperability – Jeopardize $30 billion in taxpayer investments In order to maximize the opportunity of program success: – Maintains MU momentum – Relieves pressure in 2014 – Provides relief from penalties CHIME Rationale

Stage 1Stage 2Stage Current Policy 19 June 2013

5 1 st Year Current Policy: Stages of Meaningful Use *112*233TBD 20121*12*233TBD 20131*1R*2233TBD 20141R*1R2233TBD 20151R*1R2233TBD 20161R*1R R*1R223 *= 90-day reporting period (quarter-based in 2014, unless first 1) R = Revised Stage 1 (2014 Edition CEHRT) = 2014 Edition CEHRT Current Policy 19 June 2013

6 Current Policy 19 June 2013 From a practical perspective: 3,000+ hospitals will upgrade to Stage 2 or Revised Stage 1 226,000+ eligible professionals will upgrade to Stage 2 or Revised Stage 1 4 complete EHRs meet 2014 Edition certification criteria (in-patient setting, 7/2/13)

7 1 st Year CHIME Proposal A *112*23*TBD *12*23*TBD *1R*2*23*TBD R*1R2*23*TBD R*1R2*233*TBD R*1R2*23* R*12*23* * = 90-day reporting period (quarter-based in 2014 or 2015) R = Revised Stage 1 = 2014 Edition CEHRT CHIME Proposal A Detailed 19 June 2013

Provides needed flexibility to maximize Stage 2 participation, while easing the transition to Stage 2 – CMS could give providers an additional four quarters to attest to their required 2014 Stage (either Stage 2 or Stage 1 Revised) Increases chances of success without compromising momentum – CMS would keep the October 1, 2013 start date for Stage 2 and Revised Stage 1 – CMS would not pay providers until they had met meaningful use objectives and measures, but could pay incentives for both 2014 and 2015 based off a single reporting period – CMS could apply payment adjustments retroactively to those providers starting in 2014 if they fail to attest during any quarter CHIME Proposal A Detailed 19 June 2013

9 1 st Year CHIME Proposal B *112* 2** 3*3TBD *12* 2** 3*3TBD *1R* 2** 233TBD R* 1R** 2*23*3TBD R*1R2*23*3TBD R*1R2*23* R*1R2*23* *= 90-day reporting period (quarter-based from 2014 through Q2 2015) ** = 180-day reporting period (quarter-based in 2015) R = Revised Stage 1 = 2014 Edition CEHRT CHIME Proposal B Detailed 19 June 2013

Provides similar flexibility to maximize Stage 2 participation, while easing the transition to Stage 2 Increases chances of success without compromising momentum – Same as Proposal A – Keeps Stage 3 start in FY / CY 2016 Pushes providers to reach more difficult levels of achievement in consecutive years – CMS could require an addition time period (90 or 180 days) worth of reporting to satisfy Incentive requirements in 2015 – If providers beginning in 2014 fail to attest during the first two quarters of 2015, they would be subject to payment adjustments 10 CHIME Proposal B Detailed 19 June 2013

11 1 st Year CHIME Alternative Proposal A *112**23*TBD *12**23*TBD *1R**2*23*TBD R**1R2*23*TBD R*1R2*233*TBD R*1R2*23* R*12*23* * 90-day reporting period (quarter-based) R = Revised Stage 1 (2014 Edition CEHRT) ** = Eligible for incentive payments in 2014 & 2015, if two reporting periods are submitted across both years; no payment adjustments if only one successful attestation in 2015 = 2014 Edition CEHRT CHIME Alternative Proposal A Detailed

Alternative to CHIME Proposal A – How to Avoid Procrastination? One potential shortfall of Proposal A is that providers (or developers) use the additional time unwisely and simply procrastinate, thus leading toward a similar situation in “Alternative Proposal A” would: Require providers in any stage to complete a reporting period of one quarter prior to 2016 to receive their 2014 payment (same as with Proposal A). But by completing any two quarters submitted across both 2014 and 2015, they would receive both their 2014 and 2015 payments. 12 CHIME Alternative Proposal A Detailed

Tactics: 2014 Certification Rule (ONC jurisdiction) stays as is Meaningful Use Stage 2 Rule (CMS jurisdiction) is changed to allow providers an additional 12 months, or four quarters, to attest to their required stage in 2014 Providers who meet requirements in 2014 are eligible for incentives in 2014 – This cohort of providers are then eligible to demonstrate again in 2015 Providers who need additional time beyond 2014 are allowed that additional time, but are only eligible for one (1) payment across both 2014 and 2015 Benefits: Providers are encouraged to attest as soon as they are able Exemplar providers are enabled to implement requirements early in 2014 and share their experience for the good of the program Current program timelines / momentum are maintained while distributing the strain of conversion of vendor product and physician workflow over a 21-month period rather than a 9-month period These changes would not need additional legislation 13 CHIME Alternative Proposal A Detailed

Sharon Canner, Sr. Director of Public Policy, CHIME (703) Jeff Smith, M.P.P. Director of Public Policy CHIME (703) Questions?