Are You Ready for a Full Year of Meaningful Use Reporting in 2015?

Are You Ready for a Full Year of Meaningful Use Reporting in 2015?

Providers are going to have to report a full year for Meaningful Use according to the recent Final Rule handed down by CMS.  The reaction to the rule has been almost universal among industry leader regarding their disappointment in the required reporting period.  We have discussed that before here.  In 2014 medical groups were allowed to report for 90 days rather than the full year required for 2015.

Kathy McCoy discusses the dynamics in her recent post:

The release of CMS’ Final Rule on Meaningful Use Flexibility for certified EHR technology on August 28 provided some relief to medical practices for 2014–but not for 2015.

Vendors and providers were glad to see some flexibility in the rule, specifically whether a 2014 or 2011 edition could be used for attestation in 2014. CMS recognized that many providers were unable to “fully implement” 2014 Edition Meaningful Use software in 2014. These changes to the rule should help many providers meet the Meaningful Use deadline this year.

One of the most disputed points of the Final Rule is the requirement that providers must report for a full year in 2015, instead of the 90 days allowed for 2014.

Several industry experts have commented on the 2015 measurement period, including Russell P. Branzell, the President and CEO of the College of Healthcare Information Management Executives (CHIME), who said in a statement:

“CHIME is deeply disappointed in the decision made by CMS and ONC to require 365 days of EHR reporting in 2015. This single provision has severely muted the positive impacts of this final rule. Further, it has all but ensured that industry struggles will continue well beyond 2014.”

Well-known healthcare IT blogger John Lynn also noted on his EMR & HIPAA blog last week that the failure to change 2015 reporting in the Final Rule presents possible problems.

“CMS’ comments about this basically say that a change to the EHR reporting periods was not part of this proposed rule,” Lynn wrote. “Then, they (CMS) offered this reason for why they’re not considering changes to the reporting periods:

“’We are not considering changes to the EHR reporting periods for 2015 or subsequent years in this final rule for the same reasons we are not considering changing the edition of CEHRT required for 2015 or subsequent years. Changes to the EHR reporting period would put the forward progress of the program at risk, and cause further delay in implementing effective health IT infrastructure. In addition, further changes to the reporting period would create further misalignment with the CMS quality reporting programs like PQRS and IQR, which would increase the reporting burden on providers and negatively impact quality reporting data integrity.’”

With regard to the one-year reporting period for 2015, while we would have preferred a 90-day period we understand that our job is to help our users’ practices attest successfully as the rule requires. We remain concerned about whether the healthcare ecosystem is ready for Stage 2 Objectives for a full year. However, like you, we must live with the rule as it stands. As a result of the diligence of the MediTouch Meaningful Use Team, our EHR has been 2014 certified since June 2013. Our early preparedness has afforded our users time to adapt to many of the Stage 2 Objectives. As a result, we are comfortable that the work we are doing with MediTouch users will prepare them adequately such that they can successfully attest for Meaningful Use in 2015.

If CMS listens to those in the industry calling for changes to the 2015 attestation requirements, we recognize that our hard work and preparation may be for naught. And there is certainly precedence for that (ICD-10, anyone?). However, we much prefer to make sure our users are ready to meet the stricter requirements than to be caught short.

The analogy we like to make is to a student in class who wonders whether the last chapter covered by the instructor will be covered on the upcoming test; it’s better, we feel, to over prepare and be a good student than be surprised.

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I think Kathy has come to the right conclusion and best thing we can do is make like good students and prepare for a a full year of reporting in 2015.

– James