Protracted release of meaningful use Stage 2 modifications final rule could result in program failure
Medical group practices are asking, 'Where is the final rule?' Despite the April publication of a proposed rule outlining changes to stage 2 of the EHR Incentive (meaningful use) Program, group practices and their EHR vendor partners have been forced to wait for the Centers for Medicare & Medicaid Services (CMS) to issue final program specifications before they can move forward. The delay in finalizing these much-needed modifications has caused unnecessary industry confusion and uncertainty and stalled meaningful use progress. MGMA is very concerned that medical groups will have insufficient time to transition their software and workflow to meet the revised requirements and as a result, we expect that many providers will be unable to attest in 2015. In light of the significantly delayed publication of the final regulation, MGMA urges CMS to extend the 2015 reporting period into the first quarter of 2016.
"Even if the final rule came out today, the window of time that CMS is leaving medical groups and vendors to adjust workflows and update systems is both unacceptable and unrealistic," says Halee Fischer-Wright, MD, MMM, FAAP, CMPE, MGMA president and CEO. "Forcing groups and their EHR vendor partners to scramble in a short period of time to meet the October 3 start date for the last reporting period essentially guarantees that a significant number of program participants will fail in 2015. Adding to this challenge is the fact that the industry is facing the transition to ICD-10 on October 1, yet another demanding government initiative."
The proposed modifications were designed to reenergize the program in response to steadily declining provider participation and success rates by outlining a more appropriate set of reporting requirements, including shortening the reporting period from a full year to 90 consecutive days. However, with the health care industry now left with just one month to complete system updates and comply with new requirements, MGMA is calling on CMS to allow medical groups the option of reporting for 2015 in the last 90 days of 2015 or into the first 90 days of 2016. For the 2016 reporting year, MGMA recommends that the agency move to a 90-day reporting period—permitting those providers who select the first 90 days of 2016 to report 2015 measures three remaining quarters to report 2016 measures.
"Without having a definitive set of program measures, and sufficient time to incorporate them into EHR software and practice workflow, medical groups simply cannot responsibly transition to the modified stage 2 requirements without a massive drop-off in participation," Fischer-Wright states. "Providing this flexibility will permit groups additional time to upgrade their EHRs to the revised stage 2 specifications and test these systems to ensure that they are able to conform to program requirements while meeting the practical needs of clinicians and their patients. An extension of the 2015 reporting year is absolutely vital to continued program success."
Source: Medical Group Management Association