Home > EHR, meaningful use, Medicare > CMS Expected to Propose a 90-Day EHR Reporting Period for 2015 Meaningful Users

CMS Expected to Propose a 90-Day EHR Reporting Period for 2015 Meaningful Users

Today, the Centers for Medicare and Medicaid Services (CMS) announced its intent to propose additional regulatory changes via a separate rulemaking from the imminent “Stage 3” EHR Incentive Program (“meaningful use”) rulemaking. The proposals would potentially include allowing a 90-day EHR reporting period in 2015 as well as other revisions to reduce complexity and lessen providers’ reporting burdens.

CMS’ “Stage 3 MU” and the HHS Office of the National Coordinator for HIT’s “2015 Edition EHR Certification Criteria” rulemakings have been under formal regulatory review for about one month. They were likely drafted months before both agencies realized that participation in the physician version of the program was going to be much lower than acceptable based on the small number of additional new participants in 2014 (and not even factoring in all the anticipated drop-offs from previous years). So, this second CMS MU rulemaking in 2015 will be another bite at the regulatory apple.

Timing-wise, we should expect to see the agencies’ Stage 3/2015 Edition proposed rules released for public comment within the next couple of months. Then, likely before those final rules are promulgated later this year, we should see this second CMS rulemaking published for comment around spring/early-summer (and presumably finalized before the end of the year).

Beyond the mechanics and expected timing of the various MU-related rulemakings in the pipeline, today’s announcement was also CMS’ way of signaling to the public that a 90-day EHR reporting period in 2015 is in the works. If all goes well with the rulemaking process, prior MU participants who could not begin their CY 2015 EHR reporting periods on January 1 should get another chance to comply this year.  Although the agency had several opportunities to include a shortened 2015 EHR reporting period in various rulemakings in 2014, this “announcement of intent” is better late than never.

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Categories: EHR, meaningful use, Medicare

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