CMS Listens to Those Calling for a 90 Day Meaningful Use Reporting Period

I think that most of us in the industry figured this was just a matter of time, but it’s nice that we were right and CMS is working to modify the requirements and reporting periods for meaningful use. I imagine they heard all the many voices that were calling for a change to meaningful use stage 2 and it’s just taken them this long to work through the government process to make it a reality.

Before I act like this change is already in place, CMS was very specific in the wording of their announcement about their “intent to modify requirements for meaningful use” and their “intent to engage in rulemaking” in order to make these “intended” changes. Basically they’re saying that they can just change the rules. They have to go through the rule making process for these changes to go into effect. That said, I don’t think anyone doubts that this will make it through the rule making process.

Here’s the modifications that they’re proposing:

  1. Shortening the 2015 reporting period to 90 days to address provider concerns about their ability to fully deploy 2014 Edition software
  2. Realigning hospital reporting periods to the calendar year to allow eligible hospitals more time to incorporate 2014 Edition software into their workflows and to better align with other quality programs
  3. Modifying other aspects of the programs to match long-term goals, reduce complexity, and lessen providers’ reporting burden

They also added this interesting clarification and information about the meaningful use stage 3 proposed rule:

To clarify, we are working on multiple tracks right now to realign the program to reflect the progress toward program goals and be responsive to stakeholder input. Today’s announcement that we intend to pursue the changes to meaningful use beginning in 2015 through rulemaking, is separate from the forthcoming Stage 3 proposed rule that is expected to be released by early March. CMS intends to limit the scope of the Stage 3 proposed rule to the requirements and criteria for meaningful use in 2017 and subsequent years.

I think everyone will welcome a dramatic simplification of the meaningful use program. The above 3 changes will be welcome by everyone I know.

In the email announcement for this, they provided an explanation for why they’re doing these changes:

These proposed changes reflect the Department of Health and Human Services’ commitment to creating a health information technology infrastructure that:

  • Elevates patient-centered care
  • Improves health outcomes
  • Supports the providers who care for patients

Personally, I think they saw the writing on the wall and it wasn’t pretty. Many organizations were going to opt out of meaningful use stage 2. These changes were needed and necessary for many organizations to continue participating in meaningful use. They believe meaningful use will elevate patient-centered care, improve health outcomes, and support the providers who care for patients. I’m glad they finally chose to start the rulemaking process to make the changes. I think many that started meaningful use can still benefit from the rest of the incentive money and will be even happier to avoid the penalties.

About the author

John Lynn

John Lynn

John Lynn is the Founder of the, a network of leading Healthcare IT resources. The flagship blog, Healthcare IT Today, contains over 13,000 articles with over half of the articles written by John. These EMR and Healthcare IT related articles have been viewed over 20 million times.

John manages Healthcare IT Central, the leading career Health IT job board. He also organizes the first of its kind conference and community focused on healthcare marketing, Healthcare and IT Marketing Conference, and a healthcare IT conference,, focused on practical healthcare IT innovation. John is an advisor to multiple healthcare IT companies. John is highly involved in social media, and in addition to his blogs can be found on Twitter: @techguy.


  • I think that they are doing right by the EP/EH community with this realignemnt, I also feel they are losing community trust in the program. I work closely with providers in the MU field, alot of the changes are adding fuel to the fire of not continuing with the program. With the fact that they are easing up on penalties and re-aligning reporting periods, but not extending incentives. I feel that an extension on incentives to 1st year attesters would prompt a new wave of participants. This is not discussed.

    Many providers that are moving to Stage 2 are so turned off by the reporting period and expectations of getting patients involved they are turning away from involvement. Providers with eldery patient populations are not wanting to add additional steps. Also there are flaws in exemptions that can hurt providers who took a year off OR moved to a new practice.

  • I think many issues not being resolved in healthcare. First and foremost is interoperability. The Government wants interoperability, but right now, today in 2015 I need to get a end users Endo Reports from their own owned ASC to their own owned EHR and the vendor of the equipment (No Names Needed) wants 40K (Software, Implementation, Support …). That is per center, they have three centers and to centralize to one server means they need to purchase 100Mbps Metro Ethernet to save on interface costs.

    This remains same for many Hospitals and Hospital Vendors (We all know this). Karen Desalvo knows this also. It is at the core of the problem. If she cannot even get vendors that create the Reports (Diagnostic and Surgical Centers) to give anyone the reports, how is the Government going to achieve interoperability.


    Anything short of this National Effort is simply based on Vendors Working Together. Really, if a vendor is willing to charge for it’s big money Interfaces, how do we ever get to this point of truly working together.


    To many vendors, to much self interest, to much lobbying and to much grid lock in Washington for this real and needed change to ever happen.

  • Justin,
    A really interesting analysis on whether this change might not be enough for many providers. I think it will be enough for many hospitals. So, we’ll see how that plays out.

    I also read somewhere that rulemaking could take until 2016 to get the change made. I’m not sure where they got that timeline, but if it’s true then it wouldn’t be much help for many organizations. I’ll be looking around to see if I can get a better understanding of the timeline since that will matter a lot.

  • Brendon,
    You’re so right about the complexity of how we’re trying to approach interoperability. Long story short: It’s not working and this frustrates the heck out of so many doctors. Interestingly, the doctors say they hate their EHR because it’s not interoperable even when the EHR might not have much choice (like the example you offered.

  • From my percpective a Diagnostic Report or Surgical Report or Patient Encounter note should be available within 72 hours to the whole nation if this is to succeed, and some requirement on part of patient to allow providers to get to the central system for this data must be established.

    In other words only physicians of record gets to this master database/repository.

    In Irony, we are archiving all the media ever produced right now in Washington for future generations, it was on 60 minutes. Yet, Healthcare cannot even archive reports of record, hardly the size of this database for health records.

    I guess it is all about priorities in Washington. I don’t envy Karen (Dr. DeSalvo) for this endeavor and fight. I hope she wins for the good of all.

  • John,
    In reality it would be very good for all, but we have been here to long, this goal needs national requirement, not standards. We have plenty of Standards.

    Many Stakeholders don’t really want this, money is in interface, not nationally available reports. I am not so sure Karen DeSalvo can beat the house on this, she is fighting a stacked deck.

  • Great article, repost it in five years to see where we are. I so much thought we would be here now. Not even close.

    Simple cases are abundant the nation over, where the rubber is hitting the road, and the truth of where we are at stands.

    Local Hospital, in our own Southern Palm Beach County. We have over 30 providers at this hospital. eClinical works has around 30-40, SAGE has around 20 and I believe eMds has a ton of end users at this hospital.

    One of our end users is former President of said hospital and has requeste interface with our product, so has 20 other doctors.

    The hospital clearly has interest in the EHR they choose, they don’t make available simple interface, even though I know for a fact ourselves and eClinicalworks end users have requested this now for over 3 years.

    So again, with these cases, no wonder end users and vendors are frustrated and giving up. Dr. DeSalvo has a hard task ahead, and many obstacles, all the way down to this hospital and many like it, that are using EHR interoperability as a tool for their own agenda’s and not nearly in the way Government intends.


  • We need National Requirement, Not Standards. Very interesting way to put it. Sadly, that requires Congress and/or the President to do something and we know where that goes. Plus, there’s just not an appetite for a central repository.

    It’s certainly not a technical challenge at all. I guess that’s why I find your National Requirement comment so interesting.

  • Brendon,
    They know the issues you describe, so I don’t see them posting opposing views. The question they’re asking is what are the solutions they can offer to work around those challenges? Like you said, I don’t envy DeSalvo’s job.

  • I think at the very least, make the now defacto Standard of HL7 CCD more stringent on compliance by all, including ASC and Hospital Settings to provide Summary to other systems, as a configurable option, to send all records, without any cost to end user.

    Maybe I am a bit of dreamer, but that would be the need based on current direction in regulatory requirements.

  • First of all it could be 90 seconds of reporting, no one is going to do MU2. With only 8% attesting to MU2 that are required to report MU2 (the other 7% used flex rule to report MU1), they have no chance for interop. Its like saying we want to share photos on the web, but everyone has different programs and many don’t have a computer to get on the web. They really need to reset MU. They have to pare it down to what they want from EPs. There are way too many rigid, data intensive requirements. EPs are way overburdened with too many programs (PQRS VBM, etc) and data entry. They should allow any EHR that can interop, whether certified or not, to get what they want out of interop. Credentials are mandatory, but the needless certification hurdle just adds massive costs. If they want interop, drop all other MU requirements and go for that. Forget the 100 clicks about BMI and tobacco use, patient portal percentages, forget all that. Use any EHR you want, customized, self built, old, new, as long as it can interop, you want us in your game.

    I agree with the comment that there should be one Master HIE. If you make a report, note, xray on a patient I upload that to the massive HIE. If I need to look something up, it asks for my credentials and I can view in long form, all the other providers reports, etc that have uploaded information. The HL7 CCDA upload download matching field disaster will not occur in todays current EHR environment. Its fairly simple, you make a note, a report, an xray, a lab value, you upload it, this could be easily automated. If you want to see what everyone else did, you can log in and view it. Forget trying to populate your EHR from someone else’s, it just gets too messy without a unique ID.

    The rest of the puffery language, flowery words for interop, like FHIR, CCDA updates, HL7, it will not happen so good luck with that. First things first. You need a robust EHR infrastructure. We are nowhere near that currently. Once you have that, make it super simple. You upload your consults, notes, xrays if you performed them. You want to see someone else’s, its on there. You can download files into your EHR if you want, but no reason, its always on the Master HIE. We just do not have the technology for matching field in disparate databases, it is just to easy to get an error with that or mess things up. Plus propagating once you upload can cause serious downstream problems if the initial upload is incorrect, or in error.

    I hope CMS realizes that MU is dying is last days. If they want to revive it, they have to get rid of all these core measures/menu options/attesting, etc etc. If they want interop. Go for that. But cut everything else out. It has to be easy as the costs of constant updating, maintaining, and interop are exorbitant an not sustainable. Penalizing EPs for not doing MU will never work, you are beating a dead horse with a stick. Penalties never worked in any other program in the past, why would it work now?

    When you pile on PQRS, VBM, MU, MOC, ICD-10, SGR cut threats, Sequester cuts, HIPAA, etc. the average EP is absolutely overwhelmed and literally on the brink of just forgetting about Medicare, retiring, quitting all programs they can, and that includes MU, PQRS, VBM, etc. We’d rather take the hit than participate in all these overburdening programs.

    So as I said in the beginning, sorry CMS, but MU is dead. You are way too late, too tone deaf to revive it. That is my take on it.
    Its actually SO much easier to just forget participating and take the hit and get back to taking care of patients.

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