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CMS Proposes Changes for Meaningful Use to Take Effect in 2015

May 1, 2015
by David Holtzman, Vice President of Compliance for Cynergistek
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David Holtzman

The Centers for Medicare & Medicaid Services (CMS) proposed changes to the requirements of the meaningful use program that would take effect in this current MU reporting year. A proposed rule by CMS Modifications to Meaningful Use in 2015 through 2017 was published in the Federal Register on April 15th. The publication of the 2015 proposed rule in the Federal Register will start the customary 60-day public comment period which would be scheduled to end June 14, 2015.

Reporting Period for Hospitals

CMS is using this new 2015 MU proposed rule to make changes to extend the 2015 reporting period for Critical Access Hospitals (CAH) and Eligible Hospitals (EH).  The reporting period to attest to MU will be the end of the calendar year.  This means that for an EH or CAH the current MU reporting period that began on Oct. 1, 2014 would not end on Sept. 30, 2015, but would be extended to December 31st. Beginning in 2016, the reporting period for an EH or CAH would be the calendar year. The reporting period for Eligible Providers (EP) would not change under this proposal.

An EH, CAH or EP would still have 60 days from the end of the reporting year to file its attestation for MU.  If the CMS rule is adopted as proposed, the deadline for all filers to attest to MU in this current reporting year would be February 29, 2016.

Data Collection Period

CMS is proposing to make the data collection period for the 2015 reporting year 90 consecutive days for any hospital or provider attesting for MU. If the CMS rule is adopted as proposed, a EH or CAH could use data collected for any continuous 90 day period beginning Oct. 1, 2014 through Dec. 31, 2015. EPs would report data from 90 consecutive days collected during its calendar year reporting period.

The current Stage 2 MU Rules calls for a 12 month data collection to support this year’s demonstration of MU.  In the new 2015 MU proposed rule, CMS affirms that it is allowing the 90 day data collection period for 2015 MU reporting period only.  The 12 month data collection will be required for the 2016 and 2017 MU reporting periods.

Changes to Measures and Objectives in 2015

CMS is proposing to remove or reduce a number of objective and measures from Stages 1 and 2 of MU that a provider or eligible hospital would be required to report to demonstrate MU in 2015 through 2017.  Some of the objectives and measures that would no longer be required to be reported are recorded demographics, vital signs, smoking status, structured lab results or imaging results.  These proposed changes would remove the menu and core structure of Stages 1 and 2 and reduce the overall number of objectives to which a provider must attest.

Other significant changes are to modify the patient action measures in the Stage 2 objective related to patient engagement.  CMS proposes to reduce the threshold from the Stage 2 Objective for Patient Electronic Access from 5 percent of eligible patients to demonstrative that a single patient viewed, transmitted or downloaded their PHI for the EHR of the CAH or EP.

The 2015 MU proposed rule would also change the threshold of the Stage 2 Objective for Secure Electronic Messaging from  being a percentage-based measure, to a “yes-no” measure stating the EHR functionality was fully enabled.

CMS is also proposing to consolidate all the public health reporting objective into one objective with measure option following the structure of the Stage 3 Public Health Reporting Objective.  In addition, the 2015 MU proposed rule would change the eligible hospital (EH) prescribing objective from a “menu” object to a mandatory objective with an exclusion available for some EHs and CAHs.


The proposed rule making issued by CMS for changes to the 2015-17 Meaningful Use Program is just that; a proposal.  There is no firm date by which CMS would adopt a final rule.  CMS could also make modifications to the rule making when it is adopted in its final form.  However, there is a high level of confidence in the major provisions of these regulatory changes because CMS officials had been speaking for many months of the changes the agency was contemplating.  Further, many of the modifications proposed in the 2015-17 MU rule making conform to or provide a pathway to the changes that CMS has proposed in Stage 3 MU standards.


The Medicare Sustainable Growth Rate (SGR) legislation passed by Congress contains provisions that will end the penalty applied to EPs for not attesting to MU after 2018.  Beginning in 2019, participation in MU will entitle EPs to receive incentives under an existing CMS program that rewards meeting certain quality indicators. CMS will be required to develop regulations to implement the sunsetting of the MU penalty provisions over the coming months.