CMS finalizes reporting requirements, shortens reporting from 1 year to 90 days
On November 1, the Centers for Medicare & Medicaid Services (CMS) published a final rule that allows providers participating in the Medicare Electronic Health Record (EHR) Incentive Program to report a 90-day period in 2016 and 2017, instead of reporting a full calendar year.
The Outpatient Prospective Payment System (OPPS) final rule says that this reporting period can be any continuous 90-day period within calendar year (CY) 2016 and CY 2017. This applies to all returning eligible professionals (EPs), eligible hospitals, and critical-access hospitals (CAHs) that have previously demonstrated meaningful use (MU) in the Medicare and Medicaid EHR Incentive Programs.
This is welcome news that has been a result of stakeholder comments that had indicated concerns with implanting Advanced Program Interface (API) functionalities for Stage 3 and program and systems changes in 2017. Others wanted to allow eligible clinicians time to transition to the Merit-based Incentive Payment System (MIPS), and to provide flexibility for all healthcare providers that are preparing for Stage 3 and the implementation of 2015 Edition Certified EHR technology (CEHRT).
CMS also finalized a one-time hardship exception for EPs who are new participants in the EHR Incentive Program in 2017 and are transitioning to MIPS in 2017. They can report once in 2017 to satisfy both MU criteria and the Advancing Care Information section of MIPS. This exemption will help them avoid 2018 penalties.
Physicians have until March 13, 2017 to attest to MU for 2016. The final rule does not change this date, except for physicians and hospitals that have not previously demonstrated MU. Those providers have until October 1, 2017 to meet the modified Stage 2 criteria in the program and avoid penalties in 2018.
Most physicians will be subject to the MIPS next year and will no longer have to meet MU requirements. MIPS will supersede MU. It measures physician performance on quality and clinical practice improvement activities. Under MIPS rules they can meet 1 quality or 1 clinical practice improvement measure, report fully for 90 days, or report for 12 months in 2017. The other option is to join an Alternative Payment Model (APM), such as an accountable care organization (ACO) or patient-centered medical home (PCMH).
Your Quest Diagnostics team can help guide you through these requirements. Talk to a representative at 1.888.835.3409.