A collation of 34 provider organizations, including the College of Healthcare Information Management Executives (CHIME), has asked the Centers for Medicare & Medicaid Services to shorten the Meaningful Use reporting period for 2016 from 365 to 90 days.
In a letter dated March 15 to CMS Acting Administrator Andy Slavitt, the coalition expresses its appreciation for the shortened reporting period from 365 days to 90 days for 2015 and requests that the same policy offered then be provided in 2016. The coalition also recommends that CMS allow participants to report on any 90-day period in 2016, as was allowed in 2015.
"Doing so will continue the significant progress providers are making to harness the use of technology to succeed in new payment and care delivery models," the signatories wrote. "Further, announcing this as soon as possible will reduce the number of providers who will feel compelled to rely on filing for a hardship."
The letter also points out that retaining the 365-day reporting period for 2016 leaves providers and vendors with no down time to improve usability and innovation, which it says could result in many providers having no baseline data for quality reporting if they're unable to report in 2016. In addition, the letter notes that a year-round reporting period would make it harder for providers to transition to the Medicare Access and CHIPS Reauthorization Act, which moves most physicians into a different EHR-incentive program, called the Merit Based Incentive Payment System (MIPS).
In a related announcement from CHIME about the "loud chorus" asking CMS to act quickly, CHIME CEO Russell Branzell and Board Chair Marc Probst note that "[u]ntil the final MACRA rules are issued, providers will be greatly challenged to meet the reporting requirements. Maintaining 365-day reporting period also will force providers to pull resources away from using health IT to innovate care processes and workflows."
Additionally, they say, a longer reporting period will limit the amount of time both providers and vendors can spend on improving interoperability and information exchange.
The original regulation required a 365-day reporting period in 2015. CMS issued a new regulation in 2014 providing for more flexibility in reporting, but retained the 365-day reporting period for 2015. A subsequent rule released in 2015 after widespread criticism reduced the reporting period to 90 days, but for 2015 only.
A new law was enacted in December 2015 to enable more providers who couldn't meet the 2015 reporting requirements apply for a hardship exception.