Several healthcare organizations have once again written a letter to the Centers for Medicare & Medicaid Services calling for a shortened reporting period in 2016 for the meaningful use program.
With the release of the meaningful use final rules last fall, industry stakeholders were most pleased that CMS adopted a 90-day reporting period in 2015, down from a 365-day reporting period which was originally proposed. As such, all providers were able to attest to an electronic health record (EHR) reporting period of any continuous 90-day period within the calendar year (hospitals had a 15-month period). However, for 2016 reporting, while first-time participants may use an EHR reporting period of any continuous 90-day period between Jan. 1 and Dec. 31, 2016, all returning participants must use the EHR reporting period of a full calendar year, CMS mandated.
During the comment period following the release of the meaningful use Stage 3 rule, industry stakeholders called for a 90-day reporting period for every year of the program, including the first year at Stage 3, to allow providers adequate time for upgrades, planned downtime, fixes related to technology or optimizing the use of new technology within workflows.
Nonetheless, CMS has not made any changes regarding reporting periods for 2016. The Ann Arbor, Mich.-based College of Healthcare Information Management Executives (CHIME) has been a leading advocate for a 90-day reporting period; doing so would build continuity with the shortened reporting period that the agency implemented in 2015, CHIME said.
The letter to CMS, signed by CHIME and more than 30 other healthcare organizations, specifically said, “As a preliminary yet critical step to facilitate increased provider success, we respectfully request CMS adopt for the 2016 reporting year the same 90-day reporting period policy for participants in the Meaningful Use program that was offered in 2015. We also specifically recommend CMS allow participants to report on any 90 day period in 2016, as was the policy in 2015. Doing so will continue the significant progress providers are making to harness the use of technology to succeed in new payment and care delivery models. Further, announcing this as soon as possible will reduce the number of providers who will feel compelled to rely on filing for a hardship.”
According to a CHIME statement, which accompanied the letter, from its President and CEO, Russell Branzell, “Providers now are awaiting further changes to the program spurred by the Medicare Access and CHIP Reauthorization Act of 2015. However, the current regulatory scheme still calls for a 365-day reporting period. Until the final MACRA rules are issued, providers will be greatly challenged to meet the reporting requirements. Maintaining 365-day reporting period also will force providers to pull resources away from using health IT to innovate care processes and workflows. Additionally, it will limit the amount of time providers and vendors could spend on improving interoperability and information exchange.”
There has been some speculation about how meaningful use will be incorporated into the upcoming MACRA legislation. When asked about the tight window for MACRA to be put in place—2017 is the first year that the feds will measure physicians under the new legislation—CMS Acting Administrator Andy Slavitt said at HIMSS16 in Las Vegas, "We are trying to make it better, not worse. Some of these things have a lag time, and it is a journey. My hope is to create a better world and reduce more burden." When further asked by a reporter if CMS would consider delaying the start of the legislation by six months or a year, Slavitt would not comment, noting that CMS is still a few months away from having details on the proposed MACRA rule.