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1 1. Introduction. CMS finally released its' Final Rule on modifications f Meaningful Use Stage 2 (MMU2) as well as Stage 3 () on Oct. 6, 2015! The MMU2 ptions of this rule are retroactive to Jan. 1, 2015, affecting the demonstration of Meaningful Use f the 2015 repting period! The good news is that demonstrating MU f 2015 will be easier than it would have been under the old rules, both because the 2015 MU repting period has been reduced to any consecutive within CY2015 and because MMU2 has fewer measures, and in some cases easier measures. Docts who had adapted their 2015 clinical wkflow and Medflow EHR usage so as to succeed with the old MU2 MU1 rules f their previously defined CY2015 repting periods should have no difficulties succeeding with MMU2 attestation f The details of the MMU2 Final Rule closely follow the Proposed Rule which had been published on April 15, 2015, and practices who had anticipated those proposed changes should have no negative surprises either. Imptant f all Medflow EHR customers to know is that no new release of software is required to successfully demonstrate MMU2! Also, MMU2 did not in any way change the MU requirements f CQM repting. Some caveats: The new rule ("EHR Incentive Program - Stage 3 and Modifications to Meaningful Use in 2015 through 2017") will be officially published in the Federal Register on Oct. 16, 2015, and will be effective 60 days after date of publication, in other wds on Dec. 15, The new rule is not completely final, it is officially called a "Final Rule with comment period". The public comment period will last f 60 days and is only applicable to the ptions of the rule - the MMU2 ptions are truly final, f all intents and purposes. F, we should expect further changes to the rules based on public comment. A justification provided by CMS f the very late release of the Final Rule is that it had to address the "Medicare Access and CHIP Reauthization Act of 2015 (MACRA)" aka the SGR Repeal enacted on Apr. 16, 2015, which sunsets MU payment adjustments at the end of CY2018 and requires establishment of a new program called MIPS (Merit-Based Incentive Payment System) to subsume the current MU, PQRS and VBM programs starting with the 2019 payment adjustment year. CMS indicated intent to issue a Proposed Rule f MIPS by mid-2016, and it may reasonably be expected that this MIPS Proposed Rule will address the upcoming public comments to the ptions of this latest "Final Rule with comment period". The CMS MU attestation web site has not yet been updated f MMU2 and is currently unavailable. CMS has promised the new MMU2 attestation web site will be available Jan. 4, A recent announcement from ASCRS appears to suggest that providers may automatically be eligible f a MU hardship exemption f 2015 due to the extreme lateness of the MMU2 Final Rule. However, the CMS response to ASCRS focused on the reduced repting burden f MMU2, and although indicating that any provider could apply f a hardship exemption, such hardship exemption applications would be evaluated on a "case-by-case basis". Medflow recommends its customers attempt to demonstrate MMU2 rather than rely on hardship exemption based solely on lateness of the MMU2 Final Rule. Given the extreme urgency f MMU2 (being retroactive f CY2015), and the lack of firmness f the rules, we will focus only on MMU2 and attempt to explain what it is, finally! Medflow, Inc. Page 1 of 6

2 2. MU Schedule The new rule intends to eliminate the staged approach to MU; by 2018, all program participants, even those in their first year of participation, will be required to demonstrate. The years represent a transition period f sunsetting earlier stages of MU. The revised schedule is as follows: 1st Year MU1 MU1 MU1 MU2 MMU2 MMU2 MMU MU1 MU1 MU2 MMU2 MMU2 MMU MU1 MU1 MMU2 MMU2 MMU MU1 "MMU1" MMU2 MMU "MMU1" "MMU2 Lite" 2016 "MMU2 Lite" MMU2 MMU MMU Table 1: Schedule of MU Stages A couple of items require explanation in the table above: "MMU1" - refers to the special accommodations which CMS is making f 2015 only f those participants who had been previously scheduled f MU1. As we will see in the next section, alternate measures and exclusions f MMU2 are available f those participants so as to ensure that MU would not be me difficult to demonstrate than had previously been planned. CMS does not use the term "Modified Stage 1", preferring to call it "Modified Stage 2" subject to complicated special accommodations. "MMU2 Lite"- a last vestige of Stage 1 will be provided f 2016; participants who had been previously scheduled f MU1 may exclude from the CPOE imaging measure only. Medflow, Inc. Page 2 of 6

3 "MMU2 " - f 2017, participants may opt to demonstrate if their EHR has been certified to the 2015 Edition. If exercising this option, participants would only have to demonstrate f a 90 day period in This is an attempt by CMS to encourage early adopters. The MU repting periods required f participants in the years are as follows: Perfmance Year Payment Year (Incentive) Medicaid Only 2018 Medicaid Only 1st Year Payment Adjustment Year (Penalty) MIPS TBD nd + Year 1st Year < Oct. 1 2 nd + Year full year full year 1st Year < Oct. 1 2 nd + Year MMU2: full year : MMU2: full year : 1st Year < Oct. 1 2 nd + Year full year Table 2: Schedule of MU Repting Periods This table also requires a little explanation: "" refers to any consecutive within the cresponding perfmance year; "full year" refers to the entire calendar perfmance year. First year participants' perfmance impacts their payment adjustments f two years! Starting with the 2016 perfmance year, the first of the two impacted payment years requires successfully attesting to MU by Oct. 1 of the perfmance year; the 90 day MU repting period must therefe end by Sept. 30 at the latest. As already indicated in Table 1, there is an option to demonstrate in 2017 with the incentive to reduce the MU repting period to. Medflow, Inc. Page 3 of 6

4 3. MMU2 Measures and Stage 1 Accommodations. CMS aimed to significantly "reduce the repting burden" with the MMU2 rule. The following MU2 measures are eliminated entirely beginning retroactively with the 2015 repting year, based on CMS having deemed them to "have become redundant, duplicative, topped-out": Recd Demographics Recd Vital Signs Recd Smoking Status Clinical Summaries Structured Lab Results Patient List Patient Reminders aka Preventive Care Summary of Care Measure #1 - Any Method Summary of Care Measure #3 - Test Electronic Notes Imaging Results Family Histy The following MU2 measures currently requiring patient action have been redefined as a function of the perfmance year so as to make them easier to comply with: Objective / Measure Patient Electronic Access Measure #2 Secure Messaging MU2 Me than 5% of patients view, download transmit their health infmation Me than 5% of patients send a secure message using CEHRT MMU At least 1 patient views, downloads transmits his her health infmation The capability f patients to send and receive a secure message was fully enabled during the repting period At least 1 patient views, downloads transmits his her health infmation The provider sends at least 1 secure message reply to a patient Me than 5% of patients view, download transmit their health infmation The provider sends a secure message reply to me than 5% of patients Table 3: Schedule of Patient Interaction Measures There are a couple of things wth noting f Table 3 above: Patient Electronic Access measure #2 is simplified in the same way f 2015 and 2016, and then returns back to its iginal 2014 measure logic f The Secure Messaging measure is different each year 2015, 2016 and The measure logic transitions starting in 2016 from measuring secure messages sent by the patient to the provider, instead measure the number of secure messages ( replys) sent by the provider to the patient. This is the same approach taken f the Secure Messaging measure in. Medflow, Inc. Page 4 of 6

5 The remaining MMU2 objectives and measures are ganized differently than they were f MU2. The very concept of ce vs. menu measures has been eliminated in MMU2, and the remaining measures have been grouped into a smaller number of objectives: Objective 1. Protect Patient Health Infmation Measures Conduct review SRA 2. CDS #1: 5 CDS rule related to 4+ CQMs #2: Drug-drug & drugallergy checks 3. CPOE #1: >60% of medication ders Alternate measure: 1 CDS rule Stage 1 Accommodations Alternate measure: >30% of medication ders #2: >30% of lab ders #3: >30% of imaging ders 4. erx >50% of permissible all prescriptions queried f drug fmulary & transmitted electronically using CEHRT 5. Summary of Care Uses CEHRT to create a SoC recd and electronically transmit to a receiving provider f >10% of transitions of cares and referrals 6. Patient Specific Education 7. Medication Reconciliation Patient-specific education resources identified by CEHRT are provided to >10% of patients Medication reconciliation f >50% of transitions into the care of the EP Alternate measure: >40% of permissible prescriptions transmitted electronically using CEHRT Medflow, Inc. Page 5 of 6

6 8. Patient Electronic Access #1: >50% of unique patients provided timely online access to their health infmation, with the ability to view, download, and transmit #2: see Table 3 above 9. Secure Messaging See Table 3 above 10. Public Health Repting (any 2 out of 3 measures) #1: Active engagement with a public health agency to submit immunization data #2: Active engagement with a public health agency to submit syndromic surveillance data #3: Active engagement to submit data to specialized registry Any 1 out of 3 measures Table 4: MMU2 Objectives and Measures with Stage 1 Accommodations Some notes on the above table: The purpose of menu measures in MU1 and MU2 had been to provide certain limited choices f participants to select measures me appropriate to their practice; similar flexibility is still provided in MMU2 by allowing participants to choose from 2 out of 3 of the measures f the Public Health Repting objective ( 1 out of 3 f the 2015 Stage 1 Accommodations). The "active engagement" f public health repting measures is defined as (1) having registered to submit data, (2) being in the process of testing and validation of the electronic submission of data, (3) having ongoing electronic submission of production data. As mentioned in the Introduction, no new release of 2014 Edition certified Medflow EHR is required to successfully demonstrate MMU2. Medflow will provide detailed instructions to its users how to use their existing MU1 and MU2 measure repts f attesting to MMU2 f the 2015 perfmance year. F the 2016 repting period, Medflow intends to update its software with new MU measure repts to be fully harmonized with MMU2. If you have any questions regarding these new CMS regulations, please visit Medflow's new US HIT Compliance Fum at: elearning.medflow..com Medflow, Inc. Page 6 of 6