In a final rule issued Tuesday, the Centers for Medicare & Medicaid Services (CMS) finalized a 90-day reporting period, along with other changes, in the Medicare and Medicaid Electronic Health Records (EHR) Incentive Programs. The rule finalizes proposals from two rules — the stage 3 proposed rule and the proposed rule modifying the program from 2015 to 2017. CMS will accept comments until Dec. 15 on certain provisions of the rule pertaining to requirements of the Medicare and CHIP Reauthorization Act of 2015.
Among the accommodations offered in the rule is to allow all providers to report for 90 days of calendar year (CY) 2015 instead of the required full year. This marks the first year that hospitals will report on a CY instead of a fiscal year. Providers who attest for the first time in CYs 2016 or 2017 will also be able to use a 90-day reporting period instead of the full year. In addition to the shorter reporting period, CMS reduced the number of meaningful use objectives for hospitals from 20 to 9. The rule also eased the requirements of the patient electronic access measure, which has been particularly difficult for providers because it depends on patient action. CMS lowered the threshold from requiring 5 percent of patients to view, download, or transmit their electronic health information to only requiring one patient to do so.
CMS established 2018 as the first year of mandatory participation in stage 3, the final stage of meaningful use. Hospitals may also voluntarily attest to stage 3 in 2017. Stage 3 will require hospitals to attest to eight meaningful use objectives, many comprising multiple individual measures. The performance thresholds for many of these individual measures are higher than in stages 1 and 2.
America’s Essential Hospitals is closely reviewing the provisions of the final rule and will be sending members a more detailed update in the coming days. If you have questions or concerns, please contact Erin O’Malley, director of policy, at firstname.lastname@example.org or 202.585.0127.