In the inimitable style of government-speak, CMS recently announced its “intention to consider proposals” to shorten the 2015 meaningful use reporting period from a full calendar year to 90 days. While I would advise providers to be cautious about changing their plans until the relevant rule is published (anticipated in the spring), I think it is fair to assume that CMS would not have issued even such a noncommittal-sounding announcement if it were not planning to actually implement this change.
CMS has finally yielded to the relentless lobbying by the AMA and an alphabet soup of other professional societies and HIT organizations, all of which remain concerned about provider readiness and the challenges presented by an insufficient infrastructure to support Stage 2 requirements. Objections to full-year reporting for 2015 date back to last spring, when comments were submitted in response to the (then-proposed) 2014 Flexibility Rule. At that point, CMS adamantly rejected the overwhelming number of comments that recommended—or pleaded for—quarterly 2015 reporting. Currently, however, in addition to this external pressure, the dismal number of Stage 2 attestations to date has got to have CMS worried about the future of its MU program.
The devil, as always, will be in the details:
- When will the rule be available, and will its timing be early enough to avoid creating the aura of uncertainty that characterized last year’s mid-year revisions? (We are already one month into the 2015 physicians’ reporting period, four months into the hospitals’.)
- Would quarterly reporting be available to all providers, even those still at Stage 1?
- What happens to “harmonization’ with PQRS, which remains a full-year program? (This has been one of the reasons CMS has stated for its resistance to quarterly reporting.)
Even more intriguing to me than the change in reporting period is the second of the three proposals enumerated as being under consideration—that is, the intention to “modify other aspects of the program to match long-term goals, reduce complexity, and lessen providers’ reporting burdens.” Is it possible that CMS is taking the advice of the AMA and other organizations to increase flexibility, reduce the number of measures, add more choice, and maybe even eliminate the all-or-nothing nature of MU? Wouldn’t that be something!
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