Reporting period

The reporting period for Stage 2 generally is a full calendar year for eligible professionals (fiscal year for hospitals). There is one exception to this: 2014. To allow physicians, hospitals and vendors time to complete any necessary system upgrades and to fully understand Stage 2 requirements, the reporting period for 2014 will be one calendar quarter (or fiscal year quarter for hospitals). Rather than permitting any rolling 90-day period, CMS decided to use a standard three-month period to allow for easier comparison of data over time. It can be any quarter during the year. For those concerned about the EHR payment adjustment for payment year 2016 that is based on 2014, you will not be subject to the payment adjustment if you meet the reporting requirement for one quarter of 2014, rather than the full year, because that is the length of the 2014 reporting period.

Because of difficulties eligible professionals and eligible hospitals experienced upgrading to 2014 Edition EHRs, the ACC, American Medical Association and urged CMS and the Office of the National Coordinator for Health Information Technology (ONC) to allow for a three-month reporting period in 2015. On April 10, 2015, CMS released a proposed rule to modify Stage 2 of the EHR Incentive Program by shortening the 2015 reporting period from a full year to 90 days. According to CMS, “the proposed rules align and merge the ‘stages’ of meaningful use requirements by streamlining reporting by removing redundant, duplicative, and topped-out measures; modifying patient action measures in Stage 2 objectives related to patient engagement; and aligning the EHR reporting period for eligible hospitals and critical access hospitals with the full calendar year.” The proposed Stage 3 rule modifies the reporting period to only provide a 90 day reporting period for first time Medicaid meaningful users. For others, it would be a full calendar year for all Medicare participants (both returning and first time meaningful users) and a full calendar year for returning Medicaid participants.

Attestation

With the exception of clinical quality measure (CQM) data, you will continue to report successful participation in the EHR Incentive Program by attestation. As discussed in the section on CQM reporting, participants will have the option to report CQMs electronically through the Physician Quality Reporting System portal with the exception of their first year of participation in the EHR Incentive Program. For the first year of participation, CQMs will also be reported by attestation.

Beginning in 2014, CMS allows groups to attest in batch format. This method allows large group practices to submit a number of attestations at once, while maintaining the individual assessments of participation in the EHR Incentive Program.

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