In case you missed the news, CMS posted the proposed rule that modifies meaningful use in 2015-2017 (Here’s the rule on the Federal Register). The 210 page document dropped late on Friday right before HIMSS. If you think we’ve seen CMS do this before, we’ve seen it happen a lot. They love to issue the rules on Friday and often right before HIMSS. At least that’s better than when they released the rule during HIMSS, but not much.
The summary of the changes is pretty straightforward:
- Streamlining reporting by removing redundant, duplicative, and topped-out measures
- Modifying patient action measures in Stage 2 objectives related to patient engagement
- Aligning the EHR reporting period for eligible hospitals and CAHs with the full calendar year
- Changing the EHR reporting period in 2015 to a 90-day period to accommodate modifications
The patient engagement was changed from 5% to a single download, view, and transmit as it’s been called. I think many will look on this as a very favorable change since you can’t force a patient to do something and so your incentive and penalties shouldn’t depend on their action.
It also makes sense that they change the hospital reporting period to the calendar year like it’s been for EPs. The change probably has some logistical questions for many hospitals, but it will make the process cleaner.
The big one of course is the 90 day attestation period. We knew it was coming and I think everyone’s glad that it’s here. Now it will be interesting to see how many wait until October to start their attestation period. That’s pretty risky if you ask me, but that didn’t stop organizations from waiting just the same.
I don’t think there will be many issues with what’s in this proposed rule. Although, we’ll see over the next week what other things people find as they dig into the rule. I know many were waiting for this to drop and are now breathing a sigh of relief over the 90 day reporting period.
Let us know in the comments if there are other details you find that we didn’t talk about or nuances we might have missed. Enjoy the light reading on the flight to HIMSS.