Meaningful Use 2015: Proceed with Caution

For months, a coalition of national provider groups repeatedly told CMS that a shortened reporting period would have a dramatically positive effect on meaningful use program participation and policy outcomes sought in 2015. Based on reports released by CMS in December 2014, the requests certainly seem to have merit since only 4 percent of physicians had achieved Stage 2 meaningful use requirements.

In late January, CMS announced their intention to modify requirements for meaningful use reporting this year and limit the scope of the Stage 3 proposed rule to the requirements and criteria for meaningful use in 2017 and subsequent years.

According to the announcement, CMS is considering proposals to:

• Realign hospital EHR reporting periods to the calendar year to allow eligible hospitals more time to incorporate 2014 edition software into their work flow and to better align with other CMS quality programs.

• Modify other aspects of the program to match long-term goals, reduce complexity, and lessen providers' reporting burdens.

• Shorten the EHR reporting period in 2015 to 90 days to accommodate these changes.

Also in January, a bill known as the Flexibility in Health IT Reporting (Flex-IT) Act was reintroduced by U.S. House members designed to ensure healthcare providers would receive the flexibility they need to comply with the meaningful use program this year. Originally introduced in September 2014, the Flex-IT Act allows providers the option to choose any three-month quarter for an EHR reporting period in 2015.

According to Naomi Levinthal, senior consultant and healthcare IT adviser for The Advisory Board, while there is some uncertainty around the incentive program, it appears CMS will be addressing that soon.

"We know there will be two sets of rules in 2015 that providers should be on the lookout for," Levinthal said. "First, the Stage 3 proposal is expected this winter, and second, late last month CMS announced their intent to publish another rule [for Stage 2] in the spring.'"

Shaun Conrad, manager for Ernst & Young's Americas Health Care Advisory Practice said it is wise to prepare for Stage 2 as though the rules will not relax.

"I would say certainly do your best to stay close to any regulatory changes as possible, but you should think of this year as Stage 2 so you do have to meet the full year unless the Flex-IT Act passes," Conrad said.

Some of the 2015 meaningful use important dates for consideration include:

• February 28, 2015, is the last date to attest for the 2014 program year.

• July 1, 2015, is the deadline to submit a hardship exception application to potentially avoid the payment adjustments for those who could not attest in the 2014 program year.

• October 1, 2015, is the deadline to attest for the 2015 program for those providers in their first year of meaningful use.

• October 3, 2015, is the last day for eligible professionals (EPs) to begin 90-day reporting period for the calendar year 2015.

Mary Griskewicz, senior director of health information systems for, the Healthcare Information and Management Systems Society, said practices that are farther along should be setting their sights on Stage 3.

"The one-year reporting period is squarely in everyone's bull's-eye," Griskewicz said. "And we've seen the vendors have gotten better going from Stage 1 to Stage 2."

Levinthal added, "For those entering their first or second year of Stage 2, we're suggesting they focus on readiness in terms of the two aspects of Stage 2 that are most difficult for providers: patient engagement and care coordination."