Stage 3 Program Requirements for Providers Attesting to their State’s Medicaid Promoting Interoperability (PI) Programs

CMS is renaming the EHR Incentive Programs to the Promoting Interoperability (PI) Programs to continue the agency’s focus on improving patients’ access to health information and reducing the time and cost required of providers to comply with the programs’ requirements. CMS is also in the process of finalizing updates to the programs through rulemaking. For more information, visit the landing page where CMS will publish updates and additional resources as soon as they are available.

In October 2015, CMS released a final rule that modified the requirements for participation in the Electronic Health Record (EHR) Incentive Programs for years 2015 through 2017 as well as in 2018 and beyond. This page provides information on requirements for Stage 3.

Medicaid providers who are only eligible to participate in the Medicaid EHR Incentive Program are not subject to the Medicare payment adjustments.

States will continue to determine the form and manner of reporting CQMs for their respective state Medicaid EHR Incentive Programs subject to CMS approval.

NOTE: All providers who have not successfully demonstrated meaningful use in a prior year and are seeking to demonstrate meaningful use for the first time in 2017 to avoid the 2018 payment adjustment must attest to Modified Stage 2 objectives and measures.

Objectives and Measures

• All providers are required to attest to a single set of objectives and measures.
• For eligible professionals (EPs) and eligible hospitals there are 8 objectives.
  • View the Stage 3 Specification Sheets for EPs (PDF) and hospitals (PDF).
• To meet Stage 3 requirements, all providers must use technology certified to the 2015 Edition. A provider who has technology certified to a combination of the 2015 Edition and 2014 Edition may potentially attest to the Stage 3 requirements, if the mix of certified technologies would not prohibit them from meeting the Stage 3 measures. However, a provider who has technology certified to the 2014 Edition only may not attest to Stage 3.
• Please note there are no alternate exclusions or specifications available.
• There are changes to the measure calculations policy, which specifies that actions included the numerator must occur within the EHR reporting period if that period is a full calendar year, or if it is less than a full calendar year, within the calendar year in which the EHR reporting period occurs. Specific measures affected are identified in the Additional Information section of the specification sheets.

Flexibility within Objectives and Measures

Stage 3 includes flexibility within certain objectives to allow providers to choose the measures most relevant to their patient population or practice. The Stage 3 objectives with flexible measure options include:

• Coordination of Care through Patient Engagement – Providers must attest to all three measures and must meet the thresholds for at least two measures to meet the objective. 
• Health Information Exchange – Providers must attest to all three measures and must meet the thresholds for at least two measures to meet the objective.
• Public Health Reporting – Eligible professionals must report on two measures and eligible hospitals must report on four measures.

EHR Reporting Period

• In 2017, for all new and returning participants, the EHR reporting period is a minimum of any continuous 90 days between January 1 and December 31, 2017.

Stage 3 Requirements for Medicaid EHR Incentive Program Resources

• Patient Electronic Access Tip Sheet  (PDF)
• Security Risk Analysis Tip Sheet  (PDF)
• Medicaid Eligible Professionals: Public Health and Clinical Data Registry Reporting (PDF)
• Medicaid Eligible Hospitals: Public Health and Clinical Data Registry Reporting (PDF)
• Guide for Eligible Professionals Practicing in Multiple Locations (PDF)
• Health Information Exchange Fact Sheet (PDF)