May 12, 2015
By now, you’ve all (hopefully) read my previous post on the proposed Meaningful Use / MIPS Stage 3 rule. That proposed rule is a dramatic departure from the current Stage 2 rule, making significant strides in aligning the Meaningful Use / MIPS rule with functionality and clinical behavior needed in patient care.
CMS has told us to expect an additional Notice of Proposed Rulemaking (NPRM) that would provide for several changes in 2015 reporting, and that would align Stage 2 objectives and measures with the NPRM for Stage 3. The promised proposed rule on changes in reporting was released on April 10. If you haven’t had time to read the 210-page rule (no surprise!), here is our summary.
The most anticipated change in the NPRM was shortening the 2015 EHR reporting period to 90 days to provide more time for providers to implement these changes. This change had broad industry support from 16 major industry groups such as CHIME and HIMSS, and was included in several bills introduced in congress. CMS provided for maximum flexibility with this change by permitting providers to select any consecutive 90 days instead of requiring that reporting over a calendar quarter.
CMS has also chosen to realign the reporting periods beginning in 2015, so hospitals would participate on the calendar year instead of the fiscal year, as has always been required of eligible physicians. This change also has the impact of aligning the Meaningful Use / MIPS reporting year with the reporting year for various other programs, including key quality programs.
Shortening the reporting period to 90 days gives all providers 274 extra days to meet compliance, and the change to calendar year reporting adds an additional 91 days for hospitals. This gives hospitals a full additional year to work on implementing 2014 edition software implementations and meeting the associated requirements for Stage 2. Under these guidelines, the last day for providers to begin a 90 day reporting period for this year is October 2, 2015.
Reporting periods for 2016 and after are proposed to remain a full year in length, with a limited exception for first year providers participating in the Medicaid program.
Prior to NPRM, providers spent 2-3 years at each stage of MU before moving on to the next stage, with the stage usually defining the software technology required. Under the proposed rule, this process is simplified:
A set of exceptions has also been included, for providers whose first year of participation was 2014 or 2015 to allow them to attest to a limited set of these rules in 2015. There is a fair amount of complexity there, so If you are in this category, please contact us for more information.
All providers may continue to use EHR technology certified to the 2014 Edition for reporting periods in 2015, 2016, and 2017. EHR technology certified to the 2015 Edition will be required beginning in 2018.
The net impact of all these changes is positive for the provider. Under the NPRM, providers will gain another year to get 2014 edition software up. Providers who started MU in 2011-2013 also gain another year of stage 2 in 2017, and another year before 2015 Edition Certified software must be in place.
The changes to the objectives and measures for the Stage 2 Modified Rule are just as dramatic, and just like the changes here, are all in favor of the provider. Stay tuned for that article.
If you want to speak to one of our experts about how the rule changes affect you and your Meaningful Use / MIPS strategy, contact us!