On April 10, 2015, CMS released a proposed rule that would dramatically change the Medicare and Medicaid (EHR) Incentive Program for 2015. We commented on the five most important changes that would affect EHR Meaningful Use Stage 1 and 2 in my April 14 blog, which you can read here.

The five most significant changes, in a nutshell:

  1. Reduced Reporting Period in 2015: The EHR reporting period that was targeted to be a full year in 2015 would be reduced to a 90-day period (not a calendar quarter) based on the calendar year
  2. The most difficult Patient Engagement measures were relaxed
  3. Simplification of the Attestation Process by removing measures that are redundant, duplicative, or had already reached a very high performance level (“topped out”)
  4. Deprecated the Concept of Core and Menu Measures
  5. 2015 Will Be a Back Loaded Year

In my call today with CMS, they confirmed that the 2015 Stage 1 and Stage 2 makeover is delayed and the final rule will not be released until “early fall.”

Our prediction that 2015 would be a back loaded year was correct, although we expected a final rule this summer.

This continued delay is further confirmation of the following:

  1. The Meaningful Use program is very much in flux and there are differing opinions about how to proceed.
  2. The 90-day reporting period is a virtual “lock” to be part of the rule.
  3. We expect most providers will scramble to meet Meaningful Use in the final 90 days of the year, as they will be managing the ICD-10 transition at the same time.

We will keep you posted on further updates regarding 2015 Meaningful Use attestation.