Last month, CMS released a proposed rule that could mean changes to the 2015 reporting period. While currently in the 60 day comment period, these changes are helping many providers sleep at night. But don’t get too comfy, it’s just a proposal at this time. Let’s take a look at the big changes:
- Alignment of reporting period to the calendar year
- Shortening of the reporting period in 2015 to 90 days
- Removing widely adopted redundant measures and reducing the number of objectives
- Changing thresholds of patient engagement measures
Alignment of Reporting Period to the Calendar Year
In 2015, eligible hospitals and critical access hospitals would move to a reporting structure that aligns with the calendar year. Reporting on the calendar year is essential to drive the alignment of several reporting programs that currently report on the calendar year (or calendar quarter).
In 2015, the IQR program is offering hospitals the ability to submit eCQMS for both Meaningful Use and IQR program credit. The Joint Commission is also allowing hospitals to submit the eCQMs in production. While the eCQM data is not currently being used for accreditation and quality data at this time, the idea is to get everyone reporting one set of quality data to multiple organizations to reduce reporting burdens. Getting everyone on the same reporting period will strengthen this initiative and cause less confusion.
90 Day Reporting Period
In 2015 only ALL eligible providers will be able to attest for any 90 day period within the reporting year. In 2016, first time attesters will be allowed to attest for any 90 day period within the reporting year.
The shortening of the reporting period was the biggest outcry of the industry since many were allowed to fall back on 2011 Edition certified technology for reporting last year. Many have said this additional time would allow them to fully implement and adjust workflows for the new software in preparation for Stage 2 initiatives.
Single Set of Objectives for All
Regardless of the current stage, the proposal states each provider would attest to the same objectives and measures. If you take a look at the list in the proposed rule, they are greatly reduced from current Stage 2 rules. There are exceptions and alternate measures for providers still reporting for Stage 1. The “maxed out” objectives such as vital signs and med allergies would be removed. All menu objectives would be removed or changed to a core.
Alert! Are you an EH that wasn’t using eRX? This proposal moves eRX to the required objectives.
Changing Patient Engagement Thresholds
How is your patient portal measure standing up? The proposal shows that many are struggling with this measure. Many clients ask me how they can make their patients view the portal. CMS and ONC hear this message and have reduced the threshold to at least one (1) patient within the reporting period logs in and views, downloads, or transmits their data. The patient had to be seen by the EP during the reporting period, and the patient for the EH must have been discharged during the reporting period.
When working with our customers I generally find a consensus in questions and confusion. Here are the top questions I have received:
With the proposed changes, what should I do about my reporting this year?
Keep going! Don’t stop or slow down your efforts. Remember this rule is only in the proposal phase, and items could be changed or removed all together. Once the rule is finalized, reassess your progress with your team and determine if you need to redirect priorities.
Do the eCQMs need to be electronically submitted this year?
Answer: You can electronically submit, or attest eCQMs via the Medicare attestation site just like last year. However, if you are submitting for IQR in addition to the EHR incentive program, you need to e-submit. This will hold true from 2015-2017.
I saw new Certification standards proposed for 2015. Do I need to wait for my vendor to be re-certified for the 2015 year?
No. The 2015 Certification Edition year represents the year of rulemaking and only applies to the new Stage 3 requirements. You will need to upgrade and attest to having these new standards when you attest for Stage 3.
Really? Just 1 patient has to log in and VDT?
Answer: Yes. Just 1 patient. This verifies that you have the technology in place to accommodate patient technology and a mechanism for onboarding. Expect this patient engagement to rally in Stage 3, so keep on engaging.
You can read the proposed rule here . Don’t forget to submit your comments on the proposed rule. Comments are due 6/15/2015 at 11:59 EDT. Expect to see a finalization around the end of summer, much like last year. I’d also love to hear your comments and thoughts on the 2015 reporting period, and anything else MU.
In addition to being the resident meaningful use expert, Sarah evangelizes and drives greater understanding of all things HIT through internal communications, newsletters, organized trainings, blogging, and social media.
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