Meaningful Use Final Rule: Attest your 90-day reporting period on January 4th

CMS Final Rule states that all providers will attest for a 90-day reporting period in 2015 regardless of what stage or year they were previously attesting for.

What is my reporting timeline?

Medicare Electronic Health Record Incentive Program attestations for the 2015 program year will be accepted for all eligible professionals from January 4, 2016 through February 29, 2016. The 90-day reporting period is also applicable to providers demonstrating Meaningful Use for the first time in 2016 or 2017.

Why shorten the reporting period?

By shortening the reporting time-frame, and not tying the 90-day reporting period to a specified calendar quarter, CMS hopes to ease providers through the transition to the new modified Meaningful Use program. The 90-day reporting period in 2015 would allow providers additional time to address any remaining issues with the implementation of a 2014 certified EHR and to accommodate the proposed changes to the objectives for 2015.

Would shortening the EHR reporting period risk patient safety?

CMS maintains that a full year EHR reporting period is desirable and that it’s essential to maintain the processes and the workflows that support and promote patient safety. However, they claim that a 90-day EHR reporting period would allow providers additional time to address any remaining issues related to implementation of technology certified to the 2014 Edition. The reduction to a 90-day EHR reporting period will accommodate the proposed changes to the program and reduce the overall burden on providers to allow greater focus on the objectives and measures to promote patient safety, support clinical effectiveness, and drive the advanced use of health IT.

Beyond 2015, existing providers will need to attest for a full year of compliance with program requirements since any provider that has the necessary workflows and processes in place for a full year has little reason to not demonstrate Meaningful Use for that time period. If extreme circumstances outside of the provider’s control prohibit a full year of Meaningful Use reporting, the provider may file for a hardship exception from the Medicare payment adjustments.

Why 90-days and not three months?

Allowing 3 calendar months would open the possibility of a reporting period that is shorter than 90-days, and CMS believes that 90-days is already a short period as compared to the entire year. Furthermore, a 90-day period need not be tied to the beginning or end of a month and permits flexibility for providers.

Meaningful Use Attestation Deadline

Important Dates Attestation Deadlines
2016 Medicare EP Reconsideration Application deadline January 1, 2016 - February 29, 2016
2015 CQMs for PQRS Deadline January 1, 2016 - February 29, 2016
Medicare Attestation for 2015 EHR deadline January 4, 2016 - March 11, 2016
Submission of a hardship exception deadline January 1, 2016 - July 1, 2016

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