CMS caves to pressure: Considering 90-day reporting period

After multiple requests from a range of established organizations and newly created coalitions to relieve the burden of Meaningful Use (MU), the Centers for Medicare & Medicaid Services (CMS) has announced its intent to engage in rulemaking to update the Medicare and Medicaid EHR Incentive Programs beginning in 2015. These intended changes would help to reduce the reporting burden on providers, while supporting the long-term goals of the program, according to a CMS blog post authored by Patrick Conway, MD, CMS chief medical officer and deputy administrator for innovation and quality.

Conway cited the rapid increase in EHR adoption over the past few years and said the new rule “would be intended to be responsive to provider concerns about software implementation, information exchange readiness and other related concerns in 2015. It would also be intended to propose changes reflective of developments in the industry and progress toward program goals achieved since the program began in 2011.”

CMS is considering proposals to:

• Realign hospital EHR 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 CMS quality programs.
• Modify other aspects of the program to match long-term goals, reduce complexity and lessen providers’ reporting burdens.
• Shorten the EHR reporting period in 2015 to 90 days to accommodate these changes.

Professional organizations are offering their enthusiasm. The American Medical Association “welcomes” the announcement, says AMA President-Elect Steven J. Stack, MD.

“We are eager to see the proposed rule as we have been working with CMS and the Office of the National Coordinator for Health IT (ONC) offering solutions to improve the incentive program for quite some time.” Stack cited the AMA’s recommendations for revamping the EHR certification process, blueprint for fixing the Meaningful Use program and framework for improving EHR usability.

“We hope the new rule will be issued expediently to provide the flexibility needed to allow more physicians to successfully participate in the Meaningful Use program and better align Meaningful Use with other quality reporting programs such as the Physician Quality Reporting System and the Value-base Modifier. Additionally, we hope ONC will address problems with interoperability and support technologies that provide the ability for information to be exchanged, incorporated and presented to a physician in a contextual and meaningful manner.

CMS is wise to take action to address concerns, said Peter Basch, MD, medical director for ambulatory EHR and health IT policy at MedStar Health, based in Columbia, Md. “The attestation history in 2014 supports the contention that there are still plenty of providers who either did not or could not get on 2014 certified software by the end 2014, or just squeaked by with a rushed implementation.” Struggling providers and late adopters aren’t necessarily done with MU but CMS letting them face a negative payment adjustment “would be a signal from CMS that Meaningful Use is done with them.”

Whether this is enough relief to keep things on track with the MU timeline is hard to say, according to Basch. “Clearly, it buys breathing room and allows more docs to keep participating while other events take shape.”

The intention of CMS to accelerate its transition to pay-for-value “is the game changer that should have CMS reconsidering a course correction, or perhaps a premature end to the MU program.” A different payment structure means providers need to be more concerned about having an EHR interconnected with information sources and engagement tools and quality measures that help them do better.

“While docs need time in 2015 to stay inside the existing MU rails, CMS and ONC need this time to determine--hopefully with input from other stakeholders--how the MU trajectory needs to change such that doctors and hospitals are ready for pay-for-value.”