Netgain

On Friday, April 10^th, CMS released a 210 page document outlining the long awaited proposed rule for the 2015 reporting year. CMS originally announced their intention to do so in January but did not state many specifics at that time. This document is scheduled to be published in the Federal Register on April 15, 2015. It will also be available online at http://federalregister.gov/a/2015-08514, and on FDsys.gov.   

This is only a proposed rule and will not be finalized until later this summer. However, there is very strong support behind the shortened reporting period, including stakeholders and even CMS.

The rule would shorten Medicare and Medicaid meaningful use attestation for eligible professionals and hospitals to a 90-day period in 2015. The best part about the 90-day reporting period is that it does not have to be a calendar quarter, which allows extra flexibility in meeting the measures. For anyone who is reporting for a second or subsequent time, 2016 will be a full calendar year reporting period. In 2017, all providers, regardless of their previous participation, would use a full calendar year reporting period as proposed in the Stage 3 proposed rule.

In addition to the reporting period adjustment, this proposed rule would modify the patient action measures in the Stage 2 objectives related to patient engagement. Notably the threshold for a patient to view, download, or transmit their record "VDT" would be reduced from 5% to only one patient. Also, secure messaging would have to "be enabled," but there would be no threshold to meet. This is great news because these two measures were two of the toughest ones to meet for those reporting Stage 2 in 2014.

Finally, in their summary CMS states that this rule would streamline the program by removing reporting requirements on measures which have become redundant, duplicative, or topped out through advancements in EHR function and provider performance for Stage 1 and Stage 2 of the Medicare and Medicaid EHR Incentive Programs.

Check with your EHR Vendor and consultants for more specifics on additional changes that are proposed or for further clarification.

CMS will accept public feedback on the proposed rule during a 60-day comment period after the date of publication in the Federal Register.