On April 15, the Centers for Medicare and Medicaid Services (CMS) published a separate proposed rule that would impact the 2015 and 2016 U.S. Meaningful Use (MU) attestation periods.
Calendar Year Reporting
The proposed rule would make 2015 another 90-day reporting period. It would also change all hospital reporting to a calendar year basis rather than October 1 - September 30 reporting years. If finalized, hospitals' 2015 MU attestation could be for any consecutive 90-day period between October 1, 2014 and December 31, 2015. Eligible Professionals (EPs) could report any 90-day period between January 1, 2015 and December 31, 2015. Reporting periods would no longer have to be a Medicare quarter.
For 2016 and 2017, the reporting years would remain full 365 days.
Core and Menu Objectives
This CMS proposed rule would advance implementation of many attestation-related changes CMS details in the larger MU Stage 3 Proposed Rule, published on March 30. Certain core and menu objectives would be eliminated from reporting obligations. Public health reporting objectives would be consolidated into a pick-and-choose bundle rather than multiple mandatory stand-alone requirements. Among the remaining objectives, the proposed rule would move all menu objectives to mandatory Core Objectives, effective immediately in 2015. There would be certain transitional “exclusions” available to hospitals and EPs who are still in Stage 1 or who had not planned on attesting to the menu objectives that had been menu.
One example of a menu objective moving to mandatory core objective is e-Prescribing for hospital discharge medications. The new proposed rule would make that mandatory for 2015 attestation. An "exclusion" would be available if a hospital had not originally planned to implement e-Prescribing (a menu objective) in 2015. Discharge e-Prescribing would nonetheless be mandatory for the start of the January 1, 2016 MU reporting year - less than seven months from now.
The proposed rule adjusts the deadlines for avoiding the MU Medicare adjustments (penalties).
Plan Now for the Final Rule
Remember, the CMS proposal is a draft for public comment. CMS will review public comments before issuing a Final Rule. Conceivably, the Final Rule could be published as early as the end of July or, more typically, six months after the proposed rule. This means our QCPR customers will have almost no lead time to implement any required changes in time for 2015 reporting and only 3-5 months before the start of the January 2016 reporting year.
We encourage our QCPR customers to review the proposed rule to understand how it will impact your organization. We also urge you to make contingency plans in case the provisions are included in a Final Rule. You can contact your QuadraMed account executive or send us an email to discuss a path toward implementation.