You may have heard that the meaningful use (MU) reporting period for 2016 will be reduced from the full year to 90 days for all eligible professionals (EPs).
Although this has been proposed in at least two ways,
it is very important to remember that
existing legislation requires a full-year reporting period in 2016.
The most likely way the 2016 MU reporting period could be reduced is finalizing CMS' Hospital Outpatient Prospective Payment System (OPPS) Notice of Proposed Rule Making (NPRM). As noted in CMS' press release on July 6, 2016, CMS is proposing a 90-day EHR reporting period in 2016 for all EPs, eligible hospitals, and CAHs, as we believe it would continue to assist health care providers by increasing flexibility in the program. The EHR reporting period would be any continuous 90-day period between January 1, 2016 and December 31, 2016. The public comment period for this proposed legislation ended on September 6, 2016. (Please note that any proposals in the Hospital OPPS NPRM that refer to the changing MU objectives and measures are for eligible hospitals and critical access hospitals only; they are not proposed for eligible professionals.)
The second way the 2016 MU reporting period could be reduced is legislation introduced by the Senate's health IT working group, Re-examining the Strategies Needed to Successfully Adopt Health IT (referred to as REBOOT) Senate Bill 3173 is the EHR Regulatory Relief Act. Senator Pat Roberts is one of the bill's co-authors. A 90-day reporting period in 2016 is one of the legislation's key points. If you are so inclined, you could reach out to Senator Roberts (as well as Senator Moran) to encourage moving Senate Bill 3173 forward.
It is important to note that the Hospital OPPS NPRM has not been finalized (and may not be finalized until late fall or early winter); also, Senate Bill 3173 was referred to the Committee on Finance on July 13, 2016 but no additional action has been taken. We will notify you via Member Update when a final rule is published and if any action is taken on the bill.
We highly recommend that you continue to plan on a full year of meaningful use
so that you will be prepared to attest to meaningful use even if neither attempt to change the meaningful use reporting period is successful. Especially for providers attesting under the Medicaid EHR Incentive program, we also recommend that you begin monitoring your 90-day meaningful use reports so that you can discover any measure compliance differences in the full year versus 90-day reporting periods. (Attestations submitted under the Medicare EHR Incentive Program typically require a reporting period that is no less than 90 days; thus, you could choose to report for the full year. However, a 90-day reporting period under the Medicaid EHR Incentive Program is exactly 90 days because the Medical Assistance Provider Incentive Repository (MAPIR) automatically calculates the reporting period end date after the start date is entered in the attestation application.)
As a reminder, if one or more of your providers are attesting to meaningful use for the first time in 2016, their MU reporting period is already 90 days rather than the full year. From CMS' perspective, an adopt, implement or upgrade (AIU) attestation is not the same thing as an attestation of meeting the MU requirements.
